1. GENERAL CONSIDERATIONS
This document contains the policies that govern the company SUNNY APP SAS for the processing of personal data. It is published in compliance with Law 1581 of 2012, its regulatory decrees and other Colombian legal regulations on the matter. It fully replaces the document "SUNNY APP PRIVACY POLICIES" which was in force since April 11, 2016.

2. IDENTIFICATION OF THE RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
SUNNY APP SAS , hereinafter referred to as SUNNY APP , is a Colombian commercial company with NIT 900.945.404-2. Its main domicile is in the city of Bogotá DC (Republic of Colombia) and its address is Carrera 11 A No. 134A-33. His contact telephone number is 3158924797, his contact email is [email protected] and his website is www.sunnyapp.com

3. TREATMENT, VALIDITY AND PURPOSES OF THE PROCESSING OF PERSONAL DATA.
The validity of the personal databases and their treatment will depend on the respective purposes for which the data was collected and the applicable legal regulations in each case.
The processing of personal data may be carried out directly by SUNNY APP or through third parties in Colombia or abroad, in which case the respective data must be provided, respecting in any case the pertinent legal provisions.
SUNNY APP may collect, store, classify, update, transmit, transfer, delete and in general use personal data for the purposes that are specifically and directly reported to the owner at the time of collection, and for the purposes indicated below.

2.1 General purposes for the holders of personal data:
A) For the development and fulfillment of the corporate purpose of SUNNY APP and any legal or contractual obligation of SUNNY APP with the owner of the personal data.
B) For the preparation (including the background check and the veracity of the information provided), conclusion, execution, management and settlement of contracts with SUNNY APP. These contracts can be with the owner of the personal data or with a natural or legal person to which the Owner is linked, because the Owner is: employee, contractor, client, among others, of this person. In the latter case, whoever provides the personal data of the third party must have the respective authorization of that Owner.
C) Provide the services or products required by the users of computer platforms and software of any type of SUNNY APP
D) Create and send publicity, marketing and promotion in general of SUNNY APP, its suppliers, its clients, companies with which it has a contractual relationship, or the products, services or events of any of the above.
E) Inform about new products or services and/or about changes in them.
F) Organize, develop and/or invite events and commercial, academic, social, cultural or other types of activities that SUNNY APP considers relevant to the owner of the personal data.
G) Carry out satisfaction surveys regarding the goods and services offered, on consumer preferences, knowledge about the market or certain products or services, research or market studies, academic or otherwise, both internal and external, that are of interest for SUNNY APP.
H) To carry out commercial prospecting activities.
I) To make sales or consumption projections.
J) To measure, evaluate and improve the products or services offered.
K) Manage and respond to procedures and requirements (requests, complaints and claims).
L) The management and development of the administrative, accounting, and financial activities of SUNNY APP, including billing, portfolio collection, verification and reporting in risk centers, accounting records, payroll, among others.
M) To contact, send quotes, returns, guarantees, exchange of commercial documents, and in general for all actions, activities and related processes, linked or referred to clients, contractors or suppliers of the company.
N) For compliance with the statutory and legal obligations of SUNNY APP, including those in relation to its partners and administrators, such as summoning meetings, sending information about the company, preserving a record of these people, the exercise of their rights such as the right of inspection, among others.
O) To advance company restructuring processes such as mergers, acquisitions, divestment, among others.
P) Provide state institutions and respective control agencies with the data required for the exercise of their legal functions.
Q) Provide personal data to third parties with whom SUNNY APP or a third-party contractor of it, have a contractual relationship and that it is necessary to deliver them to comply with legal obligations, the object of the contract or any of the purposes established herein.
R) Carry out internal or external audit processes.
S) Provide, share or send in any way your personal data to affiliated, related, or subordinate companies of SUNNY APP, located in Colombia or abroad, in the event that said companies require the information for the purposes indicated herein.
T) For security purposes of the SUNNY APP assets and of the people and assets that are located and enter the SUNNY APP facilities or where security mechanisms have been provided. For this, it will be possible, among other measures, to register in writing the personal data of those who enter, such as name, ID or telephone number, as well as to make audiovisual, video-only or audio-only recordings. The voice and the image are sensitive data and therefore their authorization is optional.
U) Inform about substantive updates of this policy document or other relevant documents for the owner of the personal data.
V) For compliance with the biosafety protocols established by the competent authorities.

2.2 Specific purposes only for clients and potential clients of SUNNY APP:
W) For the registration of possible new clients and to carry out all the commercial, administrative and legal procedures required for their connection as SUNNY APP clients.
X) For the segmentation of customers or potential customers.
Y) Develop customer service and technical support activities.
Z) Carry out analysis of customer consumption, as well as their behavior in relation to the services provided.

2.3 Specific purposes only for employees, contractors or potential employees or contractors:
AA) The preparation, celebration, management, development, control and termination of labor or contractual relationships of all kinds with SUNNY APP.
BB) For all the activities necessary for the selection of personnel for SUNNY APP, including conducting interviews and tests, as well as verifying the person's background and suitability for the position, verifying the veracity of the information provided, classification and storage of the resume and other personal information of the person for future calls or personnel connection needs, among others.
CC) To communicate with the Holder, due to the functions, activities and obligations performed due to a contract signed with SUNNY APP or a third party, and in general for the fulfillment of the object of said contract.
DD) For historical, registration and internal archiving purposes, as well as compliance with legal obligations such as the certification of the contractual relationship held with SUNNY APP by a person.
EE) For compliance with the regulations related to the Occupational Health and Safety Management System, including, among others, the registration of the participants in the drills.
FF) Keep records and control of inputs, materials and elements of any kind that are delivered to the Owner.
GG) To ensure compliance with the Internal Work Regulations, control the performance of the employee or contractor, carry out the necessary investigations and disciplinary processes and in general seek to guarantee compliance with the contractual or legal obligations of contractors and employees.
HH) Register and keep updated the information of contractors, employees and/or pensioners (active and inactive) in the SUNNY APP databases, in order to guarantee any of the purposes established in this document, or at the time of collecting the data. data or in the law.
II) The development of the other activities of human management and contractors in general, that have not been specifically mentioned up to now, such as: affiliations and procedures with entities of the general social security system; contact with the employee or contractor, their family members or emergency contact persons; social, welfare and training activities; payment of salaries, fees or any other money owed, as well as the administrative activities associated with this, such as issuing payment receipts or sending payment vouchers; performance of occupational medical examinations; compliance with agreements with employee funds; and any other contractual or legal obligations that may exist.

2.4 General provisions in relation to the purposes:
2.4.1 For the fulfillment of any purpose of the processing of personal data, software, devices or tools of any kind that use artificial intelligence, such as automatic learning ( machine learning ), among others, may be used.
2.4.2 Likewise, to establish communication with the Holder for the fulfillment of any purpose of the processing of personal data, any available physical or digital means may be used to communicate, such as emails, instant messaging (Whatsapp, Telegram, etc. .), social networks or text messages, depending on the need and availability.

4. RIGHTS OF PERSONAL DATA HOLDERS
The rights of the holders of personal data are:
a) Know, update and rectify your personal data before SUNNY APP or the Treatment Managers. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Treatment is expressly prohibited or has not been authorized.
b) Request proof of the authorization granted to SUNNY APP except when expressly excepted as a requirement for Treatment, in accordance with the provisions of current legal regulations.
c) Be informed by SUNNY APP or the Treatment Manager, upon request, regarding the use that has been given to your personal data.
d) Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of current legal regulations. For this, you must previously exhaust the procedural requirement, that is, the consultation or claim process before SUNNY APP.
e) Revoke the authorization and/or request the deletion of the data when the Treatment does not respect the constitutional and legal principles, rights and guarantees. The revocation and/or deletion will proceed when the Superintendence of Industry and Commerce has determined that in the SUNNY APP Treatment or the Manager they have incurred in conduct contrary to the Constitution and the law.
f) Free access to your personal data that have been processed.

5. INQUIRIES.
The Owners or their successors in title or their duly authorized representatives or attorneys-in-fact, may consult the personal data of the Owner that rests in any SUNNY APP database. The query can be made by sending a message to the email [email protected] providing at least the following information:
- Full name.
-Contact details (physical and/or electronic address and contact telephone numbers).
-Identification of the owner and, if applicable, his successor in title, representative or proxy . For this you must provide a copy of the identity document. If it is a proxy or representative, you must also provide a copy of your document and the respective power of attorney or document that duly accredits such quality.
-Clear request of the personal data that you want to consult, whether this consultation of all the data or of some personal data in particular.
In case of not complying with any of the above requirements, within five (5) days of receiving the query, SUNNY APP will require the interested party to correct what is necessary. If, after two (2) months, the rectification requirement has not been duly addressed, the consultation will be understood to have been withdrawn.
If the minimum requirements are met, the query will be answered within a maximum term of ten (10) business days from the date of receipt of the same. When it is not possible to attend to the query within said term, the interested party will be informed stating the reasons for the delay and indicating the date on which it will be attended, which in no case will be more than five (5) business days following the expiration of the foreground.

6. CLAIMS.
The Owners or their successors in title or their duly authorized representatives or proxies who consider that the information contained in a SUNNY APP database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in this document or in the law, they may file a claim by sending a message to the email [email protected] providing at least the following information:
-Full name .
-Contact details (physical and/or electronic address and contact telephone numbers).
-Identification of the owner and, if applicable, his successor in title, representative or proxy . For this you must provide a copy of the identity document. If it is a proxy or representative, you must also provide a copy of your document and the respective power of attorney or document that duly accredits such quality.
-Reason(s)/fact(s) that give rise to the claim with a brief description of the right you wish to exercise (to know, update, rectify, request proof of the authorization granted, revoke it, etc.)
-Documents that you want to assert with the claim.
In case of not complying with any of the above requirements, within five (5) days after receipt of the claim, SUNNY APP will require the interested party to correct what is necessary. If, after two (2) months, the rectification requirement has not been duly met, the claim will be deemed to have been withdrawn.
In the event that SUNNY APP is not competent to resolve the claim, it will notify the corresponding person within a maximum term of two (2) business days and inform the interested party of the situation.
Once the minimum requirements for the claim have been met, a legend that says "claim in process" and the reason for it will be included in the database within a term of no more than two (2) business days from its receipt. This legend must be maintained until the claim is decided.
Likewise, once the minimum requirements are met, the claim will be dealt with within a maximum term of fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

7. AREA IN CHARGE OF HANDLING REQUESTS, QUERIES AND CLAIMS
The legal area of ​​SUNNY APP is in charge of processing the requests of the owners to make their rights effective. The channel to make any request is the email [email protected] , according to what is indicated in points 5 and 6 of this document.

8. LEGAL REFERRAL
In what is not established in this document, the provisions of the current legal regulations will be followed.

9. VALIDITY AND CHANGES
This document is valid from June 17, 2021.

SUNNY APP SAS
NIT 900.945.404-2
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