In compliance with Law 1581 of 2012, which dictates provisions for the protection of personal data, SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S in its capacity as responsible for the processing of personal data, informs the general guidelines in this matter:

        1. General Data

The person responsible for the processing of your personal data is SOFTWARE SOLUTIONS TECNOLOGIES S.A.S, with headquarters in the city of Bogotá with a Web portal. www.sstec.com.co

Contact: Through any of the Customer Service channels that SOFTWARE SOLUTIONS TECHNOLOGIES has available.

INFORMATION OF THE DATA CONTROLLER:

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.SNIT: 900.878.482-1Address: Cra 78 No 17 – 55 Centro comercial Meridiano 13 Oficina 410 Barrio: la felicidad local de Fontibón

Number: 322 [email protected]

        2. LEGAL FRAMEWORK

Political Constitution, article 15.Law 1266 of 2008Law 1581 of 2012Regulatory Decrees 1727 of 2009 and 2952 of 2010, Partial Regulatory Decree 1377 of 2013Sentencias C – 1011 of 2008, and C – 748 of 2011, of the Constitutional Court

        3. DATA PROCESSING POLICY

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S in compliance with its legal and regulatory duty, tends to make effective the constitutional guarantee of protection of the personal and family privacy of all citizens, establishing instruments and expeditious controls in order to give adequate treatment to the information it administers.

The objective of this Policy is to define the necessary guidelines to guarantee the exercise of the right to privacy of individuals, through the protection of personal data contained in the different databases of SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. so that they receive the treatment in accordance with the intended purposes. The Policy for the Processing of Personal Data is applicable to the personal data contained in the databases that are under the responsibility of SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. and that are susceptible to any access or treatment by SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S., its staff or any third party.

These terms and conditions apply to any registration of personal data made in person and / or virtually for linking to any product, service or benefit of SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. The owner of the data registers or delivers his information freely and voluntarily and acknowledges that he has read and expressly accepts these terms and conditions. S SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. is directly responsible for the processing of Personal Data; however, it reserves the right to delegate to a third party such treatment SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S.

Similarly, SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. informs that during several years of experience, for reasons of the provision of software and hardware development services focused on the land transport industry, it has collected, preserved and used information of people, to give it the following treatments, directly or through third parties: consult, be subject to administrative procedure, send information, contact by telephone, request survey completion, collect, store, use, circulate, delete, process, contact, survey, compile, exchange, publish, audit, update and / or dispose of the data that as the owner provides us to incorporate them into the different databases or databases, or in electronic or manual repositories of all kinds that SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. has. These treatments have been carried out for the purpose of providing software and hardware development services focused on the land transport industry, Smart Mtto platform for the management of automotive maintenance in real time, compliance with regulatory, commercial, promotional, informative, security requirements, quality improvement and evaluation of external positioning of the institution and its activities. Later the purposes enunciated according to the types of data handled will be detailed. The other purposes that are not contemplated in this Policy, whose origin is not normative, must be expressly authorized by the owners of the data.

Currently SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. wishes to continue with the processing and collection of information for the purposes described in this Policy, and for this it requires authorization from the owners who provide information for their databases to give them treatment different from those authorized by legal regulations.

        4. SCOPE

This policy will be applicable to personal data registered in any database of SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this specific case on the SMART MTTO platform whose owner is a natural or legal person.

        5. DEFINITIONS

For the purposes of this policy and in accordance with the current normality in terms of personal data protection, the following definitions will be taken into account

    Authorization:

Any manifestation of will, free, specific, informed and explicit, orally or in writing, by which the Owner accepts, either through a statement or unequivocal conduct by which the granting of the processing of personal data concerning him is reasonably inferred.

    Treatment:

Any operation or set of operations, carried out or not through automated procedures, and applied to personal data, such as the collection, registration, organization, conservation, elaboration or modifications, extraction, consultation, use, communication by transmission, dissemination or any other way that facilitates access to them, comparison or interconnection, as well as their blocking, deletion, modification or destruction.

    Privacy Notice:

Verbal or written communication generated by the person in charge, addressed to the Holder for the processing of their personal data, through which they are informed about the existence of the information processing policies that will be applicable to them, the way to access them and the purposes of the treatment that is intended to give to the personal data.

    Personal data processing policies:

Set of guidelines that aim to inform and define both the rules of processing of personal data in an organization and the guidelines for the owner to exercise their rights.

    Responsible for the treatment:

Natural or legal person, public or private, who by himself or in association with others, decides on the database and / or the processing of data.

    Data processor:

Natural or legal person, public or private, who by himself or in association with others, carries out the processing of personal data on behalf of the person responsible for the treatment.

    Database:

Any structured set of personal data, accessible according to specific criteria.

Owner of the data:

Natural person who owns the information provided, which is the subject of the treatment.

    Delegate or responsible area:

Natural person or area of the Company delegated for: i) the implementation and correct functioning of the policies of the processing of personal data; ii) process and respond to requests from the Owner of the information; iii) Cooperate and provide a timely response to requests from the supervisory authority.

    Public data:

It is the data that is not semi-private, private or sensitive. Public data are considered, among others, data relating to the marital status of persons, their profession or trade and their status as a trader or public servant. By their nature, public data may be contained, among others, in public registers, public documents, gazettes and official gazettes and duly enforceable court judgments that are not subject to reservation.

    Sensitive data:

Sensitive data is understood to be those that affect the privacy of the Owner or whose improper use may generate discrimination, such as revealing racial or ethnic origin, political orientation, religious or philosophical convictions, membership of trade unions, social organizations, human rights or that promotes the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data relating to health, sex life, and biometric data.

    Transfer:

the transfer of data takes place when the person responsible and/or in charge of the processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is responsible for the treatment and is located inside or outside the country.

    Transmission:

processing of personal data that implies the communication of the same inside or outside the territory of the Republic of Colombia when it has as its object the realization of a treatment by the person in charge on behalf of the person in charge.

        5. PRINCIPLES

For the purposes of guaranteeing the protection of personal data, SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. apply in a harmonious and integral manner the following principles, in the light of which the processing, transfer and transmission of personal data must be carried out

Principle of legality regarding Data Processing:

The processing of data is a regulated activity, which must be subject to the legal provisions in force and applicable govern the subject.

Principle of purpose:

The activity of the processing of personal data carried out by SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case on the SMART MTTO platform or to which it has access, they will obey a legitimate purpose in accordance with the Political Constitution of Colombia, which must be informed to the respective owner of the personal data.

Principle of freedom:

The processing of personal data can only be carried out with the prior, express and informed consent of the Owner. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal, statutory, or judicial mandate that relieves consent.

Principle of truthfulness or quality:

The information subject to Personal Data Processing must be truthful, complete, accurate, up-to-date, verifiable and understandable. The processing of partial, incomplete, fractional or misleading data is prohibited.

Principle of transparency:

In the processing of personal data, SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. will guarantee the Owner its right to obtain at any time and without restrictions, information about the existence of any type of information or personal data that is of interest or ownership.

Principle of access and restricted movement:

The processing of personal data is subject to the limits that derive from the nature of these, from the provisions of the law and the Constitution. Consequently, the treatment can only be done by persons authorized by the owner and / or by the persons provided for by law. Personal data, except for public information, may not be available on the internet or other means of dissemination or mass communication, unless access is technically controllable to provide restricted knowledge only to the owners or third parties authorized under the law. For these purposes the obligation of SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. it will be medium.

Principle of safety:

The information subject to treatment by SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case the information registered on the SMART MTTO platform must be handled with the technical, human and administrative measures that are necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

Principle of confidentiality:

All persons who work or have links in SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case with the SMART MTTO platform who, manage, manage, update or have access to information of any kind found in Databases, are obliged to guarantee the reservation of the information, so they undertake to keep and keep strictly confidential and not to disclose to third parties, all the information they come to know in the execution and exercise of their functions; except in the case of activities expressly authorized by data protection law. This obligation persists and will be maintained even after the end of your relationship with any of the tasks included in the Treatment.

6. RIGHTS OF THE OWNER OF THE INFORMATION

In accordance with the provisions of the applicable current regulations on data protection, the following are the rights of the holders of personal data:

Holder

For the purposes of this Policy, the holders of personal data, natural or legal persons, including patients and users of the health service, suppliers, customers, benefactors, students, health professionals and employees in general, will be understood as holders of personal data.

Authorization

SMART MTTO requires the prior informed and express authorization of the owner which will be obtained by written means either physical or electronic, in such a way that it can be subject to subsequent consultation.

When requesting the information from the Owner, the purpose for which the personal data is collected must be clearly informed, the treatment to which the personal data may be submitted, their rights and the means through which they can exercise them and the power to authorize or not the treatment in case of sensitive data.

No authorization is required from the Owner of the personal data in the case of:

1. Respond to a court order or when requested by a public or administrative entity in the exercise of its legal functions;

2. personal data of a public nature;

3. cases of medical or health emergency;

4. information authorized by law for historical, statistical or scientific purposes

5. data related to the civil registry of persons.

Rights of the owner

The Owner will have the right to know how to rectify and update their personal data, request proof of authorization except in exceptional cases by law, be informed about the use given to their personal data, submit consultations and file complaints, request revocation to SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. for breach of regulations and to access free of charge the personal data that have been processed.

Duties of the holder

The Owner must guarantee the veracity of the information provided to SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case to the SMART MTTO platform and update your information in a timely manner. In case of falsity in the information provided to SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case to the SMART MTTO platform is exempt from any responsibility.

Duties of the person in charge

The person in charge undertakes to proceed under the regulatory guidelines to guarantee, to the extent that corresponds to him, the exercise of the rights of the Holders of the personal data, obtained in the development of their functions.

7. TYPE OF INFORMATION RECORDED

To facilitate contact with the Holders, we register and keep personal data or any linked information that may be associated with the person. SMART MTTO obtains information through the following sources:

• When the patient or user voluntarily provides information.

• In the care processes.

• In the processes of billing of services.

• Other sources, which provide information related to the service that the user requires.

• In the processes of commercial activities

• In development of educational activities

• In the exercise of labor processes

• Name, addresses, and phone numbers

• Date and place of birth, as well as your gender

• Email addresses.

• Information necessary to facilitate contact or other services, including information

• family or work.

• ID number, passport, nationality and country of residence

• Identification, representation and existence in the case of legal persons

• Use of services.

• Personal information provided through surveys or other research methods.

• Personal information provided to the Customer Service office.

• The personal information collected may include, but is not limited to:

8. USE OF INFORMATION

In addition to the general purposes set forth in the introductory part of this Policy, there are the following, which are common to the data of all types of owners: Efficient communication related to services and alliances through different means. Verify the veracity of the data provided. Offer information about campaigns, research, special programs. Inform and invite marketing campaigns, promotion of services and user education. Conduct a service satisfaction survey. Response, management and follow-up to requests for improvement, requests and suggestions.

S SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case, the SMART MTTO platform, taking into account the different relationships it has with the types of personal data subjects, may have special purposes in the processing of the data, which are indicated below. The different types of holders can be: collaborators, contractors or suppliers, representatives or collaborators of entities responsible for payment of health services or user in general.

8. PURPOSES OF USE OF THE INFORMATION

Special purposes for the processing of user data: Obtain fundamental data, Special purposes for the processing of personal data of collaborators realization of internal and external publications Opening and management of access and support to technological platforms of the organization Provide information to companies that request to verify internal data. The above, after verification of source and use of data, should focus on verification but not on the provision of information. Be contacted directly if required, due to their functions. Detect training needs Inform and shape internal election and promotion processes.

Special purposes for the processing of personal data of suppliers and contractors: Evaluation of goods and services provided by suppliers and contractors. Monitoring and management of the contractual relationship. Verify the suitability for performance of the use of the SMART MTTO platform.

Special purposes of the personal data of representatives or collaborators of entities responsible for payment of the provision of the services of use of the SMART MTTO platform for the management of automotive maintenance in real time.

In addition to using it to process, confirm and comply with the purpose of operation of SMART MTTO or any other service that the Owner requests, SMART MTTO may use this information for administrative and analytical purposes, such as administration of information systems, billing, accounting and auditing, commercial relationship, processing and verification of means of payment, correspondence of our Customer Service area, and/or for the operation of the promotional programs that may be implemented.

9. TRANSFER AND TRANSMISSION OF PERSONAL DATA

SMART MTTO complies with the provisions of article 26 of Statutory Law 1581 of 2012 and refrains from transferring personal data of the Holders to other countries that do not have equal or higher standards of protection. However, the following exceptions shall apply:

This prohibition shall not apply in the case of:

a) Information with respect to which the Owner has granted his express and unequivocal authorization for the transfer.

b) Bank or stock exchange transfers, in accordance with the legislation that is applicable to them.

c) Transfers agreed within the framework of international treaties to which the Republic of Colombia is a party, based on the principle of reciprocity.

c) Transfers necessary for the execution of a contract between the Owner and the person responsible for the Treatment, or for the execution of pre-contractual measures as long as you have the authorization of the Owner.

10. RIGHTS OF CHILDREN AND ADOLESCENTS

In the processing of personal data, respect for the prevailing rights of minors will be ensured. The processing of personal data of minors is prohibited, except for those data that are of a public nature, and in this case the treatment must comply with the following parameters:

to. Respond to and respect the best interests of minors.b. Ensure respect for the fundamental rights of minors.

It is the task of the State and educational entities of all kinds to provide information and train legal representatives and guardians on the possible risks faced by children and adolescents regarding the improper treatment of their personal data, and to provide knowledge about the responsible and safe use by children, girls and adolescents of their personal data, their right to privacy and protection of their personal information and that of others.

11. REFUSAL TO PROCESS INFORMATION

If the user considers that SMART MTTO should not use or share their personal information for the purposes set out herein, or does not want to receive informative materials related to SMART MTTO, they must write to the email jesus,[email protected], expressing their refusal.

12. DUTIES OF SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. AS RESPONSIBLE AND IN CHARGE OF THE PROCESSING OF PERSONAL DATA

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case SMART MTTO recognizes the ownership of the personal data held by the people and consequently they can exclusively decide on them. Therefore, SMART MTTO will use personal data for the fulfillment of the purposes expressly authorized by the owner or by the regulations in force.

In the processing and protection of personal data, SMART MTTO will have the following duties, without prejudice to others provided for in the provisions that regulate or come to regulate this matter:

to. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.b. Request and keep, copy of the respective authorization granted by the owner for the processing of personal data.c. Duly inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.e. Ensure that the information is truthful, complete, accurate, up-to-date, verifiable and understandable.f. Timely update the information, thus attending to all the news regarding the data of the owner. Additionally, all necessary measures must be implemented so that the information is kept up to date.g. Rectify the information when it is incorrect and communicate the pertinent.h. Respect the conditions of security and privacy of the information of the owner.i. Process the queries and claims formulated in the terms indicated by the law.j. Identify when certain information is under discussion by the owner.k. Inform at the request of the owner about the use given to their data.l. Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the holders. Comply with the requirements and instructions issued by the Superintendence of Industry and Commerce on the subject in particular. Use only data whose treatment is previously authorized in accordance with the provisions of Law 1581 of 2012.

or. Ensure the proper use of the personal data of children and adolescents, in those cases in which the processing of their data is authorized.p. Register in the database the legends "claim in process" in the way it is regulated in the law.

q. Insert in the database the legend "information under judicial discussion" once notified by the competent authority about judicial processes related to the quality of personal data.r. Refrain from circulating information that is being disputed by the owner and whose blocking has been ordered by the Superintendence of Industry and Commerce

s. Allow access to information only to those who may have access to it. Use the personal data of the owner only for those purposes for which it is duly empowered and respecting in any case the current regulations on the protection of personal data.

13. AUTHORIZATION AND CONSENT OF THE HOLDER

SMART MTTO requires the free, prior, express and informed consent of the owner of the personal data for the processing thereof, except in cases expressly authorized by law, namely:

to. Information required by a public or administrative entity in the exercise of its legal functions or by court order.b. Data of a public nature.c. Cases of medical or health emergency.

d. Processing of information authorized by law for historical, statistical or scientific purposes. and. Data related to the Civil Registry of Persons.

Authorization to SMART MTTO for the processing of personal data will be granted by:• The owner, who must prove his identity sufficiently by the different means that he makes available • The representative and / or proxy of the holder, prior accreditation of the representation or proxy.• Another in favor or for which the owner has stipulated.

14. MEANS OF GRANTING AUTHORISATION

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case, the SMART MTTO platform will obtain authorization through different means, including the physical document, electronic, data message, Internet, Websites, or in any other format that in any case allows the obtaining of consent through unequivocal conduct through which it is concluded that if it has not been provided by the owner or the person legitimized for it, the data would not have been stored or captured in the database. The authorization will be requested by SMART MTTO prior to the processing of personal data.

Proof of authorisation

SMART MTTO will keep proof of the authorization granted by the holders of the personal data for its treatment, for which it will use the mechanisms available at its disposal at present as well as adopt the necessary actions to maintain the record of the form and date and in which it obtained it. Consequently, SMART MTTO may establish physical files or electronic repositories made directly or through third parties contracted for this purpose.

15. TREATMENT TO WHICH THE DATA WILL BE SUBJECTED AND PURPOSE OF THE SAME

For the processing of personal data of children and adolescents, it will proceed in accordance with the provisions of this policy in the section related to their rights.

Sensitive data

In the case of sensitive personal data, SMART MTTO may make use of and process them when:a. The holder has given his explicit authorization, except in cases where by law the granting of such authorization is not required.

b. The treatment is necessary to safeguard the vital interest of the Owner and he is physically or legally incapacitated. In these events, the legal representatives must grant their authorization.

c. The processing is carried out in the course of legitimate activities and with due guarantees by a foundation, NGO, association or any other non-profit organization, whose purpose is political, philosophical, religious or trade union, provided that they refer exclusively to its members or to persons who maintain regular contacts by reason of their purpose. In these events, the data may not be provided to third parties without the authorization of the owner.

d. The Treatment refers to data that are necessary for the recognition, exercise or defense of a right in a judicial process.

and. The Treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of the identity of the holders must be adopted.

Without prejudice to the exceptions provided for by law, the processing of sensitive data requires the prior, express and informed authorization of the owner, which must be obtained by any means that may be subject to consultation and subsequent verification.

16. PRIVACY NOTICE

The Privacy Notice is the physical, electronic or any other format document, made available to the owner to inform him about the processing of his personal data. Through this document, the owner is informed of the information related to the existence of smart MTTO's information processing policies and that will be applicable to him, the way to access them and the characteristics of the treatment that is intended to be given to personal data.

The privacy notice must contain, at a minimum, the following information:

to. The identity, address and contact details of the data controller.b. The type of treatment to which the data will be subjected and the purpose thereof.c. The rights of the holder. The general mechanisms provided by the person in charge so that the owner knows the information processing policy and the substantial changes that occur in it. In all cases, you must inform the owner how to access or consult the information processing policy. and. The optional nature of the answer to questions about sensitive data.

17. GUARANTEES OF THE RIGHT OF ACCESS

To guarantee the right of access of the owner of the data, SMART MTTO will make available to him, after accreditation of his identity, legitimacy, or personality of his representative, without cost or expenditure, in a detailed and detailed manner, the respective personal data through all types of means, including electronic means that allow direct access of the owner to them. Such access must be offered without any limit and must allow the holder the possibility of knowing and updating them online.

18. PROCEDURE FOR THE ATTENTION OF CLAIMS, REQUESTS FOR RECTIFICATION, UPDATING AND DELETION OF DATA

to. Claims

The Owner who considers that the information contained in a database should be subject to correction, updating or deletion, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. which will be processed under the following rules:

1. The claim of the Holder will be formulated by means of a request addressed to SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S., subject of non-conformity SMART MTTO to the email [email protected], If the claim is incomplete, the interested party will be required within five (5) days following receipt of the claim to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the claim. In the event that the person who receives the claim is not competent to resolve it, he will transfer it to the corresponding person within a maximum period of two (2) business days and will inform the interested party of the situation.

2. Once the complete claim has been received, it will be cataloged with the label "claim in process" and the reason for it, in a term not exceeding two (2) business days. Such label will remain until the claim is decided.

3. The maximum term to attend the claim will be fifteen (15) business days counted 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 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.

b. Request for updating and/or rectification

SMART MTTO will rectify and update, at the request of the owner, the information of the latter that turns out to be incomplete or inaccurate, in accordance with the procedure and the terms indicated above, for which it will be taken into account:

1. The owner must send the request to the email [email protected]

2. SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case, what is related to the SMART MTTO platform may enable mechanisms that facilitate the exercise of this right to the owner, as long as they benefit him. Consequently, electronic or other means that it deems pertinent may be enabled, which will be informed in the privacy notice and will be made available to interested parties on the website.

c. Request for deletion of data

The owner of the personal data has the right to request SMART MTTO deletion (deletion) in any of the following events:

1. Consider that they are not being treated in accordance with the principles, duties and obligations provided for in current regulations.

2. They are no longer necessary or relevant to the purpose for which they were collected.

3. The period necessary for the fulfillment of the purposes for which they were collected has been exceeded.

This deletion implies the total or partial elimination of personal information in accordance with what is requested by the owner in the records, files, databases or treatments carried out by SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S.. However, this right of the owner is not absolute and consequently SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. may deny the exercise of the same when:

to. The owner has a legal or contractual duty to remain in the database.b. The deletion of data hinders judicial or administrative proceedings linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions. The data are necessary to protect the legally protected interests of the owner; to carry out an action in the public interest, or to comply with an obligation legally acquired by the owner.

19. NATIONAL DATABASE REGISTRY

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. reserves, in the events contemplated in the law and in its statutes and internal regulations, the power to maintain and catalog certain information that rests in its databases or databases, as confidential in accordance with the current rules, its statutes and regulations.

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. will proceed in accordance with current regulations and regulations issued for this purpose by the National Government, to register its databases, before the National Registry of Databases (RNBD) that will be administered by the Superintendence of Industry and Commerce. The RNBD., is the public directory of the databases subject to Treatment that operate in the country; and that it will be freely consulted by citizens, in accordance with the regulations issued for this purpose by the National Government.

20. INFORMATION SECURITY

In compliance with the principle of security established in current regulations, SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case the information registered in SMART MTTO will adopt the technical, human and administrative measures that are necessary to provide security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

21. USE AND INTERNATIONAL TRANSFER OF PERSONAL DATA AND PERSONAL INFORMATION BY BILYM SERVICIOS SAS

In compliance with the institutional mission and the strategic development plan of SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. and taking into account the nature of the permanent or occasional relationships that any person holding personal data may have for SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. this may make the transfer and transmission, including international, of all personal data, provided that the applicable legal requirements are met; and consequently the owners with the acceptance of this policy, expressly authorize to transfer and transmit, even internationally, personal data. The data will be transferred, for all the relationships that may be established with SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S.

For the international transfer of personal data of the owners, SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case the personal data registered in SMART MTTO will take the necessary measures so that the third parties know and undertake to observe this policy, under the understanding that the personal information they receive, may only be used for matters directly related to SMART MTTO and only while it lasts and may not be used or destined for a different purpose or purpose. For the international transfer of personal data, the provisions of article 26 of Law 1581 of 2012 will be observed.

The international transmissions of personal data made by SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S., will not require to be informed to the owner or have his consent when there is a contract for the transmission of personal data in accordance with article 25 of Decree 1377 of 2013.

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. in this case the personal information registered with SMART MTTO may also exchange personal information with governmental or public authorities of another type (including, among other judicial or administrative authorities, tax authorities and criminal, civil, administrative, disciplinary and fiscal investigation bodies), and third parties participating in civil legal proceedings and their accountants, auditors, attorneys, and other advisors and representatives, because it is necessary or appropriate: (a) to comply with applicable laws, including laws other than those of your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, and to respond to requests from public and government authorities other than those of your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, yours or those of third parties; and (g) obtain applicable damages or limit damages that may affect us.

22. RESPONSIBLE AND PROCESSOR OF PERSONAL DATA

SOFTWARE SOLUTIONS TECHNOLOGIES S.A.S. will be responsible for the processing of personal data.

23. TERM

This policy applies from its approval.