MekaGroup SAS (hereinafter “CubiQ”) company incorporated in Colombia is respectful of the use of personal data provided by their current, past and potential customers, business partners, current, past and potential suppliers, current, past and potential employees (hereinafter the “holders”).

The present personal data protection and treatment policy establishes the purposes, measures and procedures of our databases, as well as the mechanisms that the holders have to know, update, rectify, suppress the data provided or revoke the authorization granted with the acceptance of the present policy or with their link as a customer, supplier, employee or candidate to employee in accordance with the Law 1581 of 2012.

The acquisition of our products, the subscription to our website (cubiqnet.com) and/or the acceptance of this policy, implies the acceptance by the holders of this policy and their authorization for the uses and processing of personal data described here.

1. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

The responsible for processing the personal data of the owners is the company MekaGroup S.A.S. Identified with the NIT. 900.472-103-2, headquarters address: calle 12 sur # 51 – 79 Medellín , Colombia, phone: (4) 2181212, email: info@cubiqnet.com

2. LEGAL

The present policy of protection and treatment of personal data is in accordance with the provisions of Law 1581 of 2012, Decree 1377 of 2013, Circular 02 of the Superintendence of Industry and Commerce of November 2015 and the rules that modify or complement it.

The purpose of the law is to develop the constitutional right of all persons to know, update and rectify the information that has been collected about them in databases or files, and the other constitutional rights, freedoms and guarantees referred to in Article 15 of the Political Constitution of Colombia (right to personal and family privacy and good name), as well as the right to information enshrined in Article 20 of the same.

They are exempted from the application of Law 1581 of 2012 and Decree 1377 of 2013, regarding databases maintained exclusively in a personal or domestic environment, i.e., activities within the framework of the private or family life of natural persons and the others specified in Article 2 of the aforementioned law.

3. DEFINITIONS CubiQ

It takes into account the following definitions in the processing of personal data:

a) Authorization: prior, express and informed consent of the owner to carry out the processing of personal data.

b) Data Base: organized set of personal data that is the object of treatment.

c) Personal data: any information linked or that can be associated to one or more determined or determinable natural persons.

d) Data processor: natural or legal person, public or private, that by itself or in association with others, carries out the processing of personal data on behalf of the data controller.

e) Data controller: natural or legal person, public or private, that by itself or in association with others, decides about the data base and the data processing.

f) Owner: natural person whose personal data are processed.

g) Processing: any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

4. DATA COLLECTED AND FORM OF COLLECTION

CubiQ may expressly request the information from the holders or collect the data necessary to fulfill the purpose of the databases, which are -among others- their name and surname, identification number, date of birth, correspondence address, contact telephone, e-mail, experience, commercial and legal background, commercial relations with other companies or public entities, place of work, references and work history, needs and interests.

Data may be explicitly provided to CubiQ by means of entry or linkage formats, authorization formats, collected personally through its employees and service providers or from the unequivocal behavior and conduct of the holders such as complaints, requests for quotations, proposals, offers, applications for employment, participation in projects, signing contracts with CubiQ, among others.

In any case, the holders commit themselves that the information given in relation to their personal data is true and verifiable so CubiQreserves the right to remove information that does not comply with these conditions from its databases and in any case without requiring authorization from the respective owner.

5. AUTHORIZATION FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA AND OTHER INFORMATION

By voluntarily providing any of the personal data in the manner indicated in the previous numeral, and/or the express authorization, the holder expressly and unequivocally authorizes CubiQ to collect your personal data and any other information you provide, and to process your personal data in accordance with this policy and the law.

The authorization mentioned may be given in writing, orally or by means of unequivocal conduct by the holder, which allows for a reasonable conclusion that the authorization was granted, since if the conduct had not been provided, the data would not have been captured and stored in the databases, such as the subscription and creation of a profile on the website: cubiqnet.com

6. USE AND PURPOSE OF PERSONAL DATA COLLECTED BY CUBIQ

CUBIQ,treats and handles the personal data of the holders, within the framework of the natural turn of its management and corporate purpose as a supplier of technological devices for the cubing of goods aimed at sectors such as logistics, retail and transport in Colombia and the United States, specifically for the following purposes:

a) To carry out marketing, promotion and/or advertising activities of our products and services, through the different means used in our company such as personal visits to customers, e-mail, telemarketing and for sending information by physical and electronic means.

b) Provide the client with information that allows him to access offers and promotions.

c) Inform about new products and/or services.

d) Fulfill our obligations to our customers, suppliers and employees.

e) Inform about changes in our products and/or services.

f) Evaluate the quality of our products and/or services.

g) Socialization of policies, programs, results and organizational changes.

h) Information analysis for the development and implementation of business strategies in compliance with the company’s business objective.

i) Establish communication between CubiQand the holders for any purpose related to the purposes set forth in this policy, whether through calls, text messages, emails and/or physical.

j) Carry out or implement the acquisition or offer of products or services by CubiQ.

k) Audit, study, analyze and use the information in the database to design, implement and develop programs, projects and events.

7. RIGHTS OF THE HOLDER OF THE INFORMATION

The following are rights of the holders as established in Article 8 of Law 1581 of 2012:

a) Know, update and rectify your personal data in front of CubiQ.

b) Request proof of authorization given to CubiQ, except in cases expressly excepted by law.

c) Be informed by CubiQ,upon request, regarding the use of your personal data.

d) Submit to the Superintendence of Industry and Commerce, complaints for violations to the provisions ofLaw 1581 of 2012 and other regulations that modify, add or complement it.

e) Revoke the authorization and/or request the deletion of data when the processing does not respect the constitutional and legal principles, rights and guarantees, except in cases where the holder has a legal or contractual duty to remain in the database of the person responsible or in charge.

f) Access free of charge to your personal data that have been processed. The information requested by the holder may be provided by any means, including electronic, as required by the holder.

To exercise their rights, they may request it by writing to info@cubiqnet.com or by calling the telephone number in Medellín: phone (+574) 255 44 62.

8. REVOCATION OF AUTHORIZATION

The holders of the personal data may at any time revoke consent to the processing of their personal data, provided that the holder does not have a legal or contractual duty to remain in the database. This revocation must be requested by the owner by sending a written communication to the e-mail info@cubiqnet.com.

9. CONTENT OF REQUESTS FOR CONSULTATIONS, CLAIMS, COMPLAINTS, REQUESTS AND REVOCATION OF AUTHORIZATION

The request must be sent to the e-mail address established in this policy and must contain: the full name of the holder, his/her identification number, physical address, e-mail, description of the facts that give rise to the request and the documents that he/she wishes to assert.

10. CONSULTATION PROCEDURE

The consultations can be requested through the e-mail info@cubiqnet.com. In any case, the consultations will be attended in a maximum term of ten (10) working days from the date of their receipt.

When it is not possible to attend the consultation within said term, the interested party will be informed, before the expiration of ten (10) working days, expressing the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (5) working days after the expiration of the first term.

11. PROCEDURE FOR COMPLAINTS, REVOCATION OF AUTHORIZATION, WITHDRAWAL OR SUPPRESSION OF DATABASES

The application may be submitted by the owner, taking into account the information indicated in Article 15 of Law 1581 of 2012, through the e-mail info@cubiqnet.com. At any time and free of charge, the holder or his or her assignees may request the rectification, updating or deletion of their personal data, by sending the above-mentioned e-mail, after proving their identity.

The request must contain, as a minimum, the name and address of the owner or any other means to receive the answer, documents that prove the identity or personality of the owner’s representative, documents that he or she wishes to assert, a description of the facts that give rise to the claim and a clear and precise description of the personal data with respect to which the owner seeks to exercise his or her right of claim.

If the claim is incomplete, the claimant will be required within five (5) days of receipt of the claim to correct the deficiencies. After two (2) months from the date of the request, without the applicant presenting the required information, it will be understood that he has desisted from the claim.

In case the person who receives the complaint is not competent to resolve it, he will transfer it to the corresponding person in a maximum term of two (2) working days and will inform the interested party of the situation. The maximum term to attend the claim will be fifteen (15) working days from the day following the date of its receipt.

When it is not possible to attend to the claim within said term, the interested party shall be informed of the reasons for the delay and the date in which his claim will be attended to, which in no case may exceed eight (8) working days following the expiration of the first term.

12. APPLICATION FOR AUTHORISATION FOR NEW USES

The owner may express his or her disagreement with the use or circulation of his or her data or information for purposes other than those expressed in this policy, expressly stating this to the following contact e-mail: info@cubiqnet.com.

Such changes will in any case be published in the personal data processing policy on the website cubiqnet.com or in any public medium that CubiQ deems appropriate in each case.

13. INFORMATION AND DATA OF MINORS

CubiQdoes not store or use personal data of minors. However, in case of doing so, such treatment will be done within the framework established byLaw 1581 of 2012, Decree 1377 of 2013 and other concordant regulations and with the previous authorization of the parents or legal guardians.

It is clarified that in any case, the response to questions about information from children and adolescents will be optional.

14. SENSIBLE DATA

The processing of sensitive data will be carried out in accordance with the principles set out in Article 6 of Law 1581 of 2012. In any case, the answer to questions about sensitive information will be optional.

15. STORAGE OF PERSONAL DATA

The holder expressly authorizes CubiQ to store its personal data in the manner it deems most appropriate and to comply with the security required for the protection of the holders’ data.

16. SECURITY MEASURES FOR THE PROTECTION OF PERSONAL DATA AND OTHER INFORMATION

CubiQ’ssecurity measures seek to protect the data of the owners in order to prevent its adulteration, loss, unauthorized use and access.

To this end, CubiQdiligently implements human, administrative and technical protection measures that are reasonably available to minimize the risks in any misuse of their databases, always looking for ways to provide greater and more efficient protection of information.

The owner expressly accepts this form of protection and declares that he considers it convenient and sufficient for all purposes. In any case, should a scenario arise that involves the security of your personal data, you can contact the following email address: info@cubiqnet.com

17. CONTACT

Any doubt or additional information will be received and processed by sending it to the contact addresses established in this policy.

This policy is effective as of the fifth day (9th) of August 2019.

Mekagroup S.A.S.