INTRODUCTION

SOLUCIONES DE TRÁFICO S.A.S., identified with NIT 811.017.887-2, located in Medellín (Carrera 73 No. 26-45), in compliance with Law 1581 of 2012 and regulatory norms, adopts this Manual of Personal Data Processing and Protection Policies with the purpose of protecting the fundamental rights of data subjects, especially the right to privacy, intimacy, good name, and informational self-determination.This manual applies to all physical or digital databases containing personal data collected, stored, processed, or transmitted by SOLUCIONES DE TRÁFICO S.A.S., in its capacity as data controller and/or data processor.

GUIDING PRINCIPLES OF DATA PROCESSING

The processing of personal data at SOLUCIONES DE TRÁFICO S.A.S. is governed by the principles established in Article 4 of Law 1581 of 2012:

• Legality

• Purpose

• Freedom

• Truthfulness or quality

• Transparency

• Restricted access and circulation

• Security

• Confidentiality

MANUAL CONSULTATION

This manual will be permanently available for public consultation on the official website: www.solucionesdetrafico.co, as well as at its physical facilities. Any request may be addressed through the email info@solucionesdetrafico.co or the telephone number +57 317 326 6027.

DATA PROCESSING AND SCOPE

Data processing will be carried out under the terms of the authorization granted by the data subject or when a legal regulation permits it without authorization.All information collected in the course of the business activities of SOLUCIONES DE TRÁFICO S.A.S. is its property. No natural or legal person may use such information without prior and express authorization.

DATA PROCESSING PURPOSE

Personal information will be used for the following purposes:

• Respond to requests, inquiries, and comments from clients and visitors.
• Provide services related to the corporate purpose.
• Manage contractual relationships with clients, suppliers, employees, contractors, and shareholders.
• Execute administrative, commercial, strategic, labor, and security processes.
• Comply with legal, contractual, or regulatory obligations.
• Implement prevention measures against illicit activities.
• Conduct surveys, market studies, and statistical analyses.
• Communicate commercial or promotional updates.

For new purposes not contemplated herein, express, prior, and informed authorization will be requested from the data subject.

DATA COLLECTION

Data may be collected through:

• Web or physical forms.
• Email.
• Phone calls.
• Digital platforms.
• Any other legitimate means enabled by the company.

INFORMATION SECURITY

SOLUCIONES DE TRÁFICO S.A.S. implements technical, human, and administrative measures to protect personal data against loss, alteration, misuse, unauthorized access, or fraud.However, it is clarified that no system is 100% infallible, and therefore, no liability is assumed for illegal access or misuse by unauthorized third parties.

DATA SUBJECTS’ RIGHTS

According to Article 8 of Law 1581 of 2012, personal data subjects have the right to:

• Access, update, and rectify their data.
• Request proof of the authorization granted.
• Be informed about how their data is used.
• Revoke authorization or request deletion, when applicable.
• Access their data free of charge.

AUTHORIZATION FOR DATA PROCESSING

Authorization shall be clear, prior, express, and informed. It may be obtained through physical, digital, or electronic means, including:

• Physical or virtual forms.
• Text messages or email.
• Unequivocal actions that demonstrate the data subject’s will.

REVOCATION AND DATA DELETION

The data subject may revoke their consent or request the deletion of their personal data through a written request addressed to the authorized channels, unless there is a legal or contractual obligation to retain them.Revocation may be total (regarding all authorized purposes) or partial (regarding specific purposes only).

GUARANTEE OF ACCESS TO INFORMATION

SOLUCIONES DE TRÁFICO S.A.S. guarantees free access to personal data by data subjects through appropriate and secure means, including electronic channels.

DATABASE UPDATES

Databases will be permanently updated in compliance with Law 1581 of 2012 and its regulatory decrees.

PROCEDURES FOR EXERCISING RIGHTS

The following procedures may only be requested by the data subject or their duly accredited representative:

Inquiries:

The data subject may consult their personal information stored in our databases free of charge. The maximum response time will be 10 business days.

Correction, Update, or Deletion:

Requests may be submitted by email, postal mail, or in person. If the request is incomplete, the applicant will be asked to complete it within five (5) business days. The response time is 15 business days.

Revocation of Consent:

Requests may be submitted through the same channels used to grant the authorization. Revocation will not apply if there is a legal or contractual obligation to retain the information.

Required Information to Exercise Rights:

• Name and identification of the data subject.
• Specific request.
• Supporting evidence (if applicable).
• Contact information.

GUARANTEE OF ACCESS TO INFORMATION

SOLUCIONES DE TRÁFICO S.A.S. guarantees free access to personal data by the data subjects through appropriate and secure means, including electronic channels.

DATABASE UPDATING

The databases will be permanently updated, in compliance with Law 1581 of 2012 and its regulatory decrees.

PROCEDURES FOR EXERCISING RIGHTS

The procedures described below may only be requested by the data subject or their duly accredited representative:

Inquiries:

The data subject may consult their personal information free of charge as stored in our databases. The maximum response time is 10 business days.

Correction, Updating, or Deletion:

This may be requested by email, postal mail, or in person. If the request is incomplete, additional information will be required within five (5) days. The response time is 15 business days.

Revocation of Consent:

This may be requested through the same channels used to grant authorization. It will not proceed if there is a legal or contractual obligation to retain the information.

Information required to exercise rights:

• Name and ID of the data subject.
• Specific request.
• Supporting evidence for the request (if applicable).
• Contact information.

INFORMATION TRANSFER

In the event of a merger, spin-off, asset sale, or corporate reorganization, SOLUCIONES DE TRÁFICO S.A.S. may transfer personal data to affiliated entities, ensuring continuity of this policy and respect for the rights of the data subjects.

DATA PROCESSING MANAGER

SOLUCIONES DE TRÁFICO S.A.S. may delegate data processing to third parties, who will act as processors under strict confidentiality and subject to this policy and Law 1581 of 2012.

PRIVACY NOTICE

The privacy notice complements this policy and is an integral part of the personal data collection processes.

APPLICABLE LAW

This manual is issued in accordance with:

• Law 1581 of 2012
• Decree 1377 of 2013
• Decree 886 of 2014
• Unified Decree 1074 of 2015
• Decree 090 of January 18, 2018

EFFECTIVE DATE

This manual takes effect from the date of its publication and will remain in force until it is modified or replaced.Publication date: July 2025 Data Controller: SOLUCIONES DE TRÁFICO S.A.S. Contact: info@solucionesdetrafico.co Phone: +57 317 326 6027 Address: Carrera 82 No. 49DD-32, Medellín, Colombia