Corporate protection policy
of personal data

At INTELLIGENT CUSTOMER ACQUISITION, S.L.U we care about the protection of personal data that we process in the framework of the activities we carry out.

The personal data to be protected includes all those that are subject to treatment by us (whether it is data of clients, potential clients, suppliers, workers, contacts, external collaborators, etc.).

Therefore, both INTELLIGENT CUSTOMER ACQUISITION, S.L.U, and all its personnel, whether internal or external, who are involved in any way in the processing of personal data, must:

Keep secret and confidentiality of the information processed.

Protect the personal data that is being processed and safeguard them so that unauthorized personnel do not have access to them.

Comply with the principles of data protection (legality, loyalty and transparency, purpose limitation, data minimization, accuracy, limitation of the conservation period, integrity and confidentiality and proactive responsibility).

Guarantee that the interested parties can exercise their rights (information, access, rectification, deletion, limitation of treatment, data portability, opposition and automated individual decisions).

Comply, and where appropriate, enforce, the controls and security measures that INTELLIGENT CUSTOMER ACQUISITION, SLU has implemented to protect the security of personal data, preventing the confidentiality, integrity or availability of said data from being compromised. data.

Communicate immediately, according to the procedures enabled for it, incidents that may affect the security of personal data and that may compromise its confidentiality, integrity or availability, as well as non-compliance with the requirements provided by the protection regulations of personal data.

Comply with all the legal requirements and obligations imposed by the personal data protection regulations.

Complete information on data protection

1. Who is responsible for the processing of your data?

INTELLIGENT CUSTOMER ACQUISITION, S.L.U
B87994679
Paseo de la Habana 1, 15th floor, - 28003 - Madrid - MADRID
+34 911879897
info@dposa.es

1.1. Contact details of the Data Protection Officer (DPD):

Victor M. Trujillo Sanchez
Paseo de la Castellana 95- Floor 15
infosec@dposa.eu

To which recipients will your data be communicated?

No data will be transferred to third parties, except legal obligation.

3. Data transfers to third countries

No data transfers to third countries are foreseen.

4. What are your rights when you provide us with your data?

4. ¿Cuáles son sus derechos cuando nos facilita sus datos?

Cualquier persona tiene derecho a obtener confirmación sobre si en INTELLIGENT CUSTOMER ACQUISITION, S.L.U. estamos tratando, o no, datos personales que les conciernan. Las personas interesadas tienen derecho a acceder a sus datos personales, así como a solicitar la rectificación de los datos inexactos o, en su caso, solicitar su supresión cuando, entre otros motivos, los datos ya no sean necesarios para los fines que fueron recogidos. Igualmente tiene derecho a la portabilidad de sus datos.

En determinadas circunstancias, los interesados podrán solicitar la limitación del tratamiento de sus datos, en cuyo caso únicamente los conservaremos para el ejercicio o la defensa de reclamaciones. En determinadas circunstancias y por motivos relacionados con su situación particular, los interesados podrán oponerse al tratamiento de sus datos. En este caso, INTELLIGENT CUSTOMER ACQUISITION, S.L.U. dejará de tratar los datos, salvo por motivos legítimos imperiosos, o el ejercicio o la defensa de posibles reclamaciones.

Podrá ejercitar materialmente sus derechos de la siguiente forma: dirigiéndose a infosec@dposa.eu o Paseo de la Castellana 95 Planta 15. Cuando se realice el envío de comunicaciones comerciales utilizando como base jurídica el interés legítimo del responsable, el interesado podrá oponerse al tratamiento de sus datos con ese fin.

Si ha otorgado su consentimiento para alguna finalidad concreta, tiene derecho a retirar el consentimiento otorgado en cualquier momento, sin que ello afecte a la licitud del tratamiento basado en el consentimiento previo a su retirada. En caso de que sienta vulnerados sus derechos en lo concerniente a la protección de sus datos personales, especialmente cuando no haya obtenido satisfacción en el ejercicio de sus derechos, puede presentar una reclamación ante la Autoridad de Control en materia de Protección de Datos competente a través de su sitio web: www.aepd.es.

How have we obtained your data?

The personal data that we process at INTELLIGENT CUSTOMER ACQUISITION, S.L.U. come from: the interested party.

Privacy Policy

Next, we indicate in detail the processing of personal data that we carry out, as well as all the information related to them.

Treatment of job candidate data

Basic information on Data Protection
Responsible:	INTELLIGENT CUSTOMER ACQUISITION, S.L.U
Purpose:	Carry out the personnel selection processes.
Legitimation:	Execution of a contract. Execution of a contract.
Recipients:	No data will be transferred to third parties, except legal obligation.
Rights:	You have the right to access, rectify and delete the data, as well as other Rights, indicated in the additional information, which you can exercise by contacting infosec@dposa.eu o Paseo de la Castellana 95- Floor 15.
Origin:	The interested party himself

1. For what purpose do we process your personal data?

At INTELLIGENT CUSTOMER ACQUISITION, S.L.U. We treat the information provided by interested persons in order to manage the Curriculum Vitae received and carry out the personnel selection processes, interviews and other necessary procedures for the search for the best possible candidate for a specific job position. In the event that you do not provide your personal data, we will not be able to fulfill the purposes described. Automated decisions will not be made based on the data provided.

2. How long will we keep your data?

Two (2) years since the last interaction.

3. What is the legitimacy for the processing of your data?

We indicate the legal basis for the treatment of your data: Execution of a contract: Management of the Curriculum Vitae delivered by the candidate to carry out the personnel selection processes to search for the best possible candidate for a given job position. (RGPD art. 6.1.b).

Treatment of customer data

Basic information on Data Protection
Responsible:	INTELLIGENT CUSTOMER ACQUISITION, S.L.U
Purpose:	Respond to your request and send you commercial communications.
Legitimation:	Execution of a contract. Consent of the interested party. Legitimate interest of the Responsible.
Recipients:	No data will be transferred to third parties, except legal obligation.
Rights:	You have the right to access, rectify and delete the data, as well as other Rights, indicated in the additional information, which you can exercise by contacting infosec@dposa.eu o Paseo de la Castellana 95- Floor 15.
Origin:	The interested party himself

Complete information on data protection

1. For what purpose do we process your personal data?

At INTELLIGENT CUSTOMER ACQUISITION, S.L.U. We treat the information provided by interested persons in order to carry out the administrative, accounting and tax management of the requested services, as well as to send commercial communications about our products and services. In the event that you do not provide your personal data, we will not be able to fulfill the purposes described. No automated decisions will be made based on the data provided.

2. How long will we keep your data?

The data will be kept as long as the interested party does not request its deletion, and where appropriate, during the years necessary to comply with legal obligations.

3. What is the legitimacy for the processing of your data?

We indicate the legal basis for the treatment of your data: Execution of a contract: Fiscal, accounting and administrative management of clients. (RGPD art. 6.1.b). Legitimate interest of the Responsible: Sending commercial communications even electronically. (RGPD Recital 47, LSSICE art. 21.2).

4. To which recipients will your data be communicated?

The data will be communicated to the following recipients: Tax Administration, in order to comply with legal obligations (legal requirement). Financial entities, in order to issue the corresponding receipts (contractual requirement).

Treatment of the data of potential clients and contacts

Basic information on Data Protection
Responsible:	INTELLIGENT CUSTOMER ACQUISITION, S.L.U
Purpose:	Manage the provision of the contracted services.
Legitimation:	Execution of a contract. Legitimate interest of the Responsible.
Recipients:	Data transfers are planned to: Tax Administration; Entities financial
Rights:	You have the right to access, rectify and delete the data, as well as other Rights, indicated in the additional information, which you can exercise by contacting infosec@dposa.eu o Paseo de la Castellana 95- Floor 15.
Origin:	The interested party himself

1. For what purpose do we process your personal data?

At INTELLIGENT CUSTOMER ACQUISITION, S.L.U. We treat the information provided by interested persons in order to manage potential clients who have been interested in our products and / or services, as well as other commercial contacts and carry out, where appropriate, the sending of commercial communications including by electronically. In the event that you do not provide your personal data, we will not be able to fulfill the purposes described. Automated decisions will not be made based on the data provided.

2. How long will we keep your data?

The data will be kept as long as the interested party does not request its deletion.

3. What is the legitimacy for the processing of your data?

Execution of a contract: Management of potential clients who have been interested in our products and / or services. (RGPD, art. 6.1.b). Consent of the interested party: Send commercial communications, including electronically. (RGPD, art. 6.1.a, LSSICE art.21). Legitimate interest of the Responsible: Management of professional contact data (LOPDGDD art.19, RGPD art. 6.1.f).

Treatment of supplier data

Basic information on Data Protection
Responsible:	INTELLIGENT CUSTOMER ACQUISITION, S.L.U
Purpose:	Manage the provision of the contracted services.
Legitimation:	Execution of a contract. Legitimate interest of the Responsible.
Recipients:	Data transfers are planned to: Tax Administration; Entities financial
Rights:	You have the right to access, rectify and delete the data, as well as other Rights, indicated in the additional information, which you can exercise by contacting infosec@dposa.eu o Paseo de la Castellana 95- Floor 15.
Origin:	The interested party himself

1. For what purpose do we process your personal data?

At INTELLIGENT CUSTOMER ACQUISITION, S.L.U. We treat the information provided by interested persons in order to carry out tax, accounting and administrative management of suppliers as well as professional contact information. In the event that you do not provide your personal data, we will not be able to fulfill the purposes described. Automated decisions will not be made based on the data provided.

2. How long will we keep your data?

The data will be kept as long as the interested party does not request its deletion, and where appropriate, during the years necessary to comply with legal obligations.

3. What is the legitimacy for the processing of your data?

We indicate the legal basis for the treatment of your data:
Execution of a contract: Carry out the administrative, accounting and fiscal management of the contracted services. (RGPD art. 6.1.b).
Legitimate interest of the Responsible: Management of professional contact data. (LOPDGDD art.19, RGPD art. 6.1.f).

4. To which recipients will your data be communicated?

The data will be communicated to the following recipients:
Tax Administration, in order to comply with legal obligations (legal requirement).
Financial entities, in order to make the corresponding payments (contractual requirement).

Privacy notice

Federal Law on Protection of Personal Data Held by Private Parties

In compliance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter, "LDPDPPP"), in order to inform CLIENTS whose personal data are in our databases, that : INTELLIGENT CUSTOMER ACQUISITION, SA DE C.V. (hereinafter, "CONVERTIA"), with RFC: ICA1610139K1, with address at Avenida Ejército Nacional 373, Office 401-402, Colonia Granada, Miguel Hidalgo Mayor's Office, postal code 11520, Mexico City, is responsible for the treatment.

It states that the personal data included in its databases have been collected for the following purpose: billing in the corporate ERP. The use and handling of these is carried out under strict standards of responsibility, within which there is respect for due process and the protection of information.

The data registered in our databases are: addresses, telephones, emails and dates of birth. In any case, at any time, the owner of the information may revoke its consent and exercise its right in accordance with the provisions of the LDPDPPP .

The rights of the holders are:

• Know, update and rectify your personal data.
• Revoke the authorization granted for the processing of your personal data.
• Request the deletion of your personal data.
• Request proof of authorization granted.
• Be informed about the use given to your data.
• File complaints with the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI), for infractions of the provisions of the law, once the consultation or claim process has been exhausted before CONVERTIA.
• Free access to your personal data being processed.

Said rights may be exercised through the email ldpdppp@convertia.com or by writing to the aforementioned postal address.

Privacy notice

Habeas Data

In compliance with the provisions of Law 1581 of 2012 and Decree 1377 of 2013, in order to inform all people whose personal data are in our databases, INTELLIGENT CUSTOMER ACQUISITION SAS , with address at Calle 93B No 19-35, Office 201, Bogotá DC, Colombia, states that the personal data included in its databases have been collected for the development of various procedures directly related to its corporate purpose.

The use and handling of them is carried out under strict standards of responsibility, within which there is respect for due process and the protection of information.

The data registered in our databases are, among others: public reviews, such as addresses, telephone numbers, emails and date of birth.

In any case, at any time, the owner of the information may revoke his consent and exercise his right to delete personal data enshrined in Law 1581 of 2012 and Decree 1377 of 2013.

The rights of the holders are:

• Know, update and rectify your personal data.
• Revoke the authorization granted for the processing of your personal data.
• Request the deletion of your personal data.
• Request proof of authorization granted.
• Be informed about the use given to your data.
• File complaints with the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI), for infractions of the provisions of the law, once the consultation or claim process has been exhausted before CONVERTIA.
• Free access to your personal data being processed.

We invite you to know the Personal Data Protection Policy of CONVERTIA, which includes the procedures so that the holders of Personal Data can exercise their rights to know, update, rectify and delete the information and revoke the authorization, and is available for consultation on the website
https://convertia.com/p/home/politicas-privacidad.html

Privacy notice

Personal Data Protection Law / Law No. 29733

INTELLIGENT CUSTOMER ACQUISITION PERU SAC guarantees the confidentiality and security of the data provided by each user, complying with the provisions of Law No. 29733, Personal Data Protection Law (hereinafter, “LPDP ”) And Supreme Decree No. 3-2013-JUS, Regulation of the Personal Data Protection Law (hereinafter, the“ Regulation ”).

Personal data will be treated with the appropriate degree of protection, taking the necessary security measures established in the LPDP and its Regulations to prevent their alteration, loss, treatment or unauthorized access by third parties. The personal data provided by you is necessary for billing purposes in the corporate ERP.

For this reason, the personal data requested is mandatory, if applicable. The user grants INTELLIGENT CUSTOMER ACQUISITION PERU SAC , by virtue of this notice, the right to transfer and cross-border flow of the information provided by the user between the entities belonging to CONVERTIA, for the aforementioned purposes.

If you have any questions or comments about the way INTELLIGENT CUSTOMER ACQUISITION PERU S.A.C. uses the data of its users, please write to INTELLIGENT CUSTOMER ACQUISITION PERU S.A.C. to the email lopd@convertia.com.