This policy applies to all AVANXO processes involving the collection, storage, use, disclosure or deletion of personal data of customers, suppliers, prospects, employees or any other person providing personal information to AVANXO for any reason related to its corporate purposes.


In order to ensure a systematic interpretation of this policy, the following legal definitions shall apply with respect to the right of habeas data and the protection of personal information: -Authorization. Prior express and informed consent by the Data Subject for the processing of personal data. -Privacy notice. Verbal or written communication generated by the Controller, addressed to the Data Subject for the Processing of their personal data, informing them about the existence of the applicable information processing policies, how to access them and the purpose of Processing of personal data. -Database Organized set of personal data subject to Processing. -Personal Data: Any information relating to, or that can be associated with, one or more identified or identifiable individuals; -Private data: Data that is relevant only to the Data Subject. -Public Data: Any data that is not semiprivate, private or sensitive. Public data includes, among others, data regarding the marital status of persons, their profession or activity and their capacity as entrepreneurs or public servants. Due to its nature, public data may be contained, among others, in public registries, public documents, official gazettes and bulletins and court judgments that have been duly executed and are not subject to confidentiality restrictions. -Semi-private data: Semi-private data is defined as that which is not private, confidential or public in nature and the knowledge or disclosure of which may be of interest, not only to the data subject, but also third parties or to society in general. -Sensitive data: Sensitive data is understood as any information affecting the privacy of the Data Subject, or where improper use may lead to discrimination, such as data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, membership in trade unions, social or human rights organizations, promotion of the interests of any political party or assurance of the rights and guarantees of opposition parties, as well as information related to health, sexual preference and biometrics. -Data Processor: Public or private individual or legal entity, which, by itself or in association with others, carries out the Processing of personal data on behalf of the Controller; -Controller: Public or private individual or legal entity, which, by itself or in association with others, makes decisions with regard to the database and or the Processing of the data. -Data Subject: Individual whose personal data are subject to processing. -Processing: Any operation or set of operations with respect to personal data, such as collection, storage, use, disclosure or deletion. -Transfer: Data transfers occur when the Controller and/or Data Processor sends the information or personal data to a receiver, who is in turn a Controller located in the country or abroad. -Transmission: Personal data processing that entails communication within or outside the territory of the Republic of Colombia, with the purpose of information Processing by the Data Processor on behalf of the Controller.


AVANXO is the controller of personal data to which it may gain access during the performance of its corporate purpose. In this sense it acts as the guarantor for the appropriate management and use of the databases where said information is stored in accordance with its legal obligations.


AVANXO asks the Data Subjects for prior express authorization, informing them of the purpose of collection and processing. Likewise, it keeps copies of the authorization issued by the data subjects, by means of physical or electronic records. Subject to the Data Subject's authorization, AVANXO may collect, store, use, distribute, update, transfer, transmit or delete the personal data for administrative, financial, labor-related, commercial, promotional, information or marketing purposes, as the case may be, including: a). The procedure for incorporation as a customer or supplier and the process of negotiation, performance and fulfillment of executed agreements. b). Control and prevention of fraud, money laundering and financing of terrorism. c). Inquiries and reports to and from Credit Rating entities. d). Commercial and collection management, and maintenance of information and documents as required by accounting regulations. e). Dissemination of advertising information for commercial purposes and marketing activities related to invitations to onsite or online events and promotion of technological solutions. f). Improving market knowledge in the use of technological applications. g). Performance of surveys to measure satisfaction with the services rendered. h). Requirements and obligations derived from the employment agreement, with the objective of correctly administering and executing the labor relationship with employees regarding payroll, benefits, occupational health and social security, selection processes, information systems, security policies, and related purposes. i). Management, administration, enhancement and expansion of the various services, generation of statistical information, incident follow-up, delivery of communications and any other purpose directly related to the performance of AVANXO’s corporate purpose, legal obligations and/or government requirements.


The Data Subjects may exercise their rights at any time to know, update, correct and delete any personal information they may have supplied to AVANXO, by means of a message sent through the following email: The Data Subjects' rights may be exercised by: The Data Subject, who must accredit his/her identity in a suitable manner through one of the various means made available by the Controller; by his/her assign or successor, who must accredit said capacity; by the Data Subject's representative or agent, subject to accreditation of said representation or power of attorney; or by authorization in the name of or for a third party.


The Data Subjects or their assigns or successors may consult the Data Subject's personal information stored in any AVANXO database. In such cases, AVANXO shall provide them with the entire information contained in the individual records or linked with the Data Subject's identification.

The inquiry shall be answered within a maximum period of ten (10) business days from the date of receipt. In the event that it is not possible to handle the inquiry within the aforementioned term, the interested party shall be notified about the reasons for the delay, indicating the date when the inquiry will be answered, which in no case may exceed five (5) additional business days.


In the event that the Data Subject or their assigns consider that the information contained in the AVANXO database must be corrected, updated or deleted, they may submit a claim to AVANXO.

The claim must be submitted as a request addressed to AVANXO, including the following information: Identification of the Data Subject, description of the events that gave rise to the claim, the address and the documents backing the request. If the claim is incomplete, the interested party shall be notified within five (5) days from the date of receipt, in order to correct any errors. If, after two (2) months from the date of being notified, the claimant has not provided the required information, it shall be understood that the claim has been withdrawn. In the event that the person receiving the claim lacks the authority to resolve the issue, they shall forward it to a competent party within two (2) business days and shall inform the claimant accordingly. Claims will be answered within fifteen (15) business days following the date of receipt. In the event that it is not possible to handle the claim within the aforementioned term, the claimant shall be notified about the reasons for the delay, indicating the date when the claim will be resolved, which in no case may exceed eight (8) additional business days.


AVANXO is directly responsible for the processing and custody of the collected and stored Personal Data; however, it reserves the right to delegate such processing to a third party, in which case it will require the processor to implement suitable procedures to ensure the protection and strict confidentiality of personal data. In addition, AVANXO engages technological service providers with international certifications, thus ensuring the highest standards of security, confidentiality and privacy of the users' information.


AVANXO will not collect information considered as Sensitive Data, such as racial or ethnic origin, sexual preference, political opinions, religious or philosophical beliefs, trade-union memberships, affiliation with social, political or human rights organizations, among others. In the event that AVANXO should have access to information regarding health, biometrics or other information about minors who are beneficiaries of our employees, use of such information shall require prior authorization and will be restricted exclusively to statistical sampling and/or workplace well-being, security and health-related purposes and in any case AVANXO will ensure that special care is exercised for their protection.


AVANXO has adopted the necessary technical, human and administrative measures to ensure the security and confidentiality of the personal information and to prevent its alteration, loss, database search, use or unauthorized access. Any personal data provided by the Data Subject to AVANXO by any means, shall be managed on a confidential basis, under the constitutional, legal and regulatory guarantees that are applicable to personal data protection. Access to the various databases shall only be granted to those individuals who need to know the information for the performance of their duties. Our employees sign confidentiality agreements and are committed to the appropriate handling of databases in accordance with the personal data processing procedures established by law. Physical files are protected in a safe location with restricted access for authorized personnel only. In addition, the information systems on which the databases are stored are equipped with privacy protocols and international certifications. Our IT systems guarantee the highest standards of security and enable access to the information in accordance with roles, profiles and/or by assigning user names and passwords. In addition, these systems enable management of incidents resulting from loss, alteration or theft of information.


The Data Subject declares that he/she has read and accepts this AVANXO Personal Data Processing Policy. The Data Subjects may exercise their rights at any time to request a correction, update or deletion of their personal data.


This personal data processing policy shall be in effect as of its posting on the AVANXO Web Portal. AVANXO may update this policy at any time, whether to reflect legal, regulatory or case-law changes or developments, internal policies, or for any other reason, which will be duly communicated to the Data Subjects through a suitable medium, enabling them to access the most recent version and to exercise their rights. We recommend that the Data Subject check this Policy regularly to ensure that they have read the most recent version.

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