TERMS AND CONDITIONS

GENERALITIES

This website is operated by Meridian Company Group SAS. Throughout the site, the terms “we”, “us” and “our” refer to Meridian Company Group SAS. Meridian Company Group SAS offers this website, including all information, tools and services offered on this site to you, the user, conditioned upon your acceptance of all terms, conditions, policies and notices stated here.

By visiting our site and/or purchasing something from us, you interact with our “Service” and acknowledge as binding the following terms and conditions (hereinafter referred to as “Terms of Service”, “Terms”), including those additional terms and conditions and policies referenced herein and/or available by hyperlink. These Terms of Service apply to all users of the Site, including but not limited to users who are browsers, suppliers, customers, merchants and/or contributors of content.

Please read these Terms of Service carefully before accessing or using our website. By accessing or using any part of the site, you agree to these Terms of Service. If you do not agree to all of the terms and conditions of this agreement, you may not access the site or use any services. If these Terms of Service are considered an offer, acceptance is expressly limited to these Terms of Service.

New features or tools added to the current store will also be subject to the Terms of Service. You may review the most recent version of the Terms of Service at any time on this page. We reserve the right to update, change or replace any part of these Terms of Service by posting updates or changes on our website. It is your responsibility to check this page periodically for changes. Your continued use of or access to the website following the posting of any changes constitutes acceptance of those changes.

SECTION 1: ONLINE STORE TERMS

By agreeing to these Terms of Service, you represent that you are of the age of majority in your state or province of residence, or that you are of the age of majority in your state or province of residence and that you have given us your consent to allow any of your minor dependents to use this site.

You may not use our products for any illegal or unauthorized purpose nor may you, by using the Service, violate the laws of your jurisdiction (including, without limitation, copyright laws).

You will not transmit any computer worms or viruses or any code of a destructive nature.

Failure to comply with or breach of any of the Terms will result in immediate termination of your Services.

SECTION 2: TERMS AND CONDITIONS

We reserve the right to refuse service to anyone, for any reason, at any time.

You understand that your content (not including credit card information) may be transferred unencrypted and involve (a) transmissions over various networks; and (b) changes to conform to and comply with technical requirements of connecting networks or devices. Credit card information is always encrypted during transfer over networks.

You agree not to reproduce, duplicate, copy, sell, resell or exploit any portion of the Service, use of the Service or access to the Service or any contact on the website through which the Service is provided, without our express written permission.

The headings used in this agreement are for convenience only and shall not limit or affect these Terms.

SECTION 3: ACCURACY, COMPLETENESS AND TIMELINESS OF INFORMATION

We shall not be liable if the information available on this site is not accurate, complete or up to date. The material presented on this site is provided for general information only and should not be relied upon or used as the sole basis for making decisions without consulting primary, more accurate, more complete or more recent sources of information. Your reliance on any material on this site is at your own risk.

This site may contain certain historical information. Historical information is, inevitably, not current and is provided for reference only. We reserve the right to modify the content of this site at any time, but we have no obligation to update any information on our site. You agree that it is your responsibility to monitor changes to our site.

SECTION 4: MODIFICATIONS TO SERVICE AND PRICES

The prices of our products are subject to change without notice.

We reserve the right to modify or discontinue the Service (or any part or content thereof) without notice at any time.

We will not be liable to you or any third party for any modification, price change, suspension or discontinuance of the Service.

SECTION 5: PRODUCTS OR SERVICES (if applicable)

Certain products or services may be available exclusively online through the Website. These products or services may have limited quantities and are subject to return or exchange only in accordance with our Return Policy.

We have made every effort to display as accurately as possible the colors and images of our products that appear in the store. We cannot guarantee that the display of any color on your computer monitor will be accurate.

We reserve the right, but are not obligated, to limit sales of our products or services to any person, geographic region or jurisdiction. We may exercise this right on a case-by-case basis. We reserve the right to limit the quantities of any products or services we offer. All product descriptions or product prices are subject to change at any time without notice at our sole discretion. We reserve the right to discontinue any product at any time. Any offer for any product or service made on this site is void where such product or service is prohibited.

We do not warrant that the quality of any product, service, information or other material you have purchased or obtained will meet your expectations, or that any errors in the Service will be corrected.

SECTION 6: ACCURACY OF BILLING AND ACCOUNT INFORMATION

We reserve the right to refuse any order you place with us. We may, in our sole discretion, limit or cancel quantities purchased per person, per household or per order. These restrictions may include orders placed with the same customer account, the same credit card, or orders using the same billing or shipping address. In the event we make a change to or cancel an order, we will attempt to notify you via email or the billing address/phone number provided at the time the order was placed. We reserve the right to limit or prohibit orders that, in our sole discretion, appear to have been placed by dealers, resellers or distributors.

You agree to provide complete and accurate current purchase and account information for all purchases made at our store. You agree to promptly update your account and other information, including your e-mail address, credit card numbers and expiration dates, so that we can complete your transactions and contact you as needed.

SECTION 7: OPTIONAL TOOLS

We may provide you with access to third party tools that we do not monitor, have no control over, or contribute to.

You acknowledge and agree that we provide access to such tools on an “as is” and “as available” basis without warranties, representations or conditions of any kind and without any endorsement. We shall have no liability whatsoever arising out of or in connection with your use of optional third party tools.

Any use you make of optional tools offered through the Site is at your own risk, and you should ensure that you are familiar with and approve of the terms on which such tools are provided by the relevant third party providers.

We may also, in the future, offer new services or features through the site (including, the release of new tools and resources). These new features or services will also be subject to these Terms of Service.

SECTION 8: THIRD PARTY LINKS

Some content, products and services available through our Service may include third party resources.

Third-party links on this site may direct you to third-party websites that are not affiliated with us. We are not responsible for examining or evaluating the content or accuracy, nor do we warrant or assume any liability or responsibility for any third-party resources or websites, or any other materials, products or services of third parties.

We are not liable for any damages or injury related to the purchase or use of goods, services, resources, content or any other transactions made in connection with third-party websites. Please review carefully the policies and practices of third parties and make sure you understand them before engaging in any transaction. Complaints, claims, concerns or questions regarding third party products should be directed to third parties.

SECTION 9: USER COMMENTS, FEEDBACK AND OTHER COMMUNICATIONS

If, at our request, you submit certain specific communications (e.g., contest entries) or, without a request from us, submit creative ideas, suggestions, proposals, plans or other materials, whether online, by email, by postal mail, or otherwise (hereinafter collectively referred to as ‘feedback’), you agree that we may, at any time, without restriction: edit, copy, publish, distribute, translate and use in any medium any feedback you submit to us. We do not and will not have any obligation (1) to keep any Comments confidential; (2) to pay any compensation for any Comments; or (3) to respond to any Comments.

We may, but have no obligation to, monitor, edit or remove content that we determine in our sole discretion to be unlawful, offensive, threatening, libelous, defamatory, defamatory, pornographic, obscene or objectionable, or that infringes any party’s intellectual property or these Terms of Service.

You agree that your comments will not infringe any third party rights, including copyright, trademark, privacy, personality or other personal or proprietary rights. You further agree that your comments will not contain defamatory, libelous, unlawful, abusive or obscene material, or contain any computer viruses or other harmful software that may in any way affect the operation of the Service or any related website. You may not use a false e-mail address, pretend to be someone else, or otherwise mislead us or any third party as to the origin of any comments. You are solely responsible for the comments you make and their accuracy. We assume no responsibility or liability for any comments posted by you or any third party.

SECTION 10: PERSONAL INFORMATION

Your submission of personal information through the Store is governed by our Privacy Policy. To view our Privacy Policy. 

SECTION 11: ERRORS, INACCURACIES AND OMISSIONS

There may be information on our site or in the Service that, from time to time, contains typographical errors, inaccuracies or omissions that may relate to product descriptions, pricing, promotions, offers, product shipping charges, transit times and availability. We reserve the right to correct any errors, inaccuracies or omissions, to change or update information, or to cancel orders if any information on the Service or any related website is inaccurate at any time without notice (including after you have submitted your order).

We undertake no obligation to update, modify or clarify information on the Service or any related website, including but not limited to pricing information, except as required by law. No update specified or update date applied on the Service or any related website shall be taken to indicate that all information on the Service or any related website has been modified or updated.

SECTION 12: PROHIBITED USES

In addition to the prohibitions set forth in the Terms of Service, you are prohibited from using the Site or its content (a) for any unlawful purpose; (b) to solicit others to perform or participate in any unlawful act; (c) to violate any international, federal, provincial or state regulation, rule, law or local ordinance; (d) to infringe or violate our intellectual property rights or the intellectual property rights of others; (e) to harass, abuse, insult, harm, defame, libel, slander, denigrate, intimidate or discriminate on the basis of gender, sexual orientation, religion, ethnicity, race, age, national origin or disability; (f) to post false or misleading information;

(g) upload or transmit viruses or any other harmful code that affects or may affect the functionality or operation of the Service or any related website, other websites or the Internet; (h) collect or track the personal information of others; (i) spam, phish, pharm, pretext, spider, track or mine; (j) for any obscene or immoral purpose; or (k) to interfere with or circumvent the security features of the Service or any related website, or other websites or the Internet. We reserve the right to terminate your use of the Service or any related website for violating any of the prohibited uses.

SECTION 13: DISCLAIMER OF WARRANTIES; LIMITATION OF LIABILITY

We do not warrant, represent or guarantee that your use of our service will be uninterrupted, timely, secure or error-free.

We do not warrant that the results that may be obtained from the use of the service will be accurate or reliable.

You agree that from time to time, we may remove the service for indefinite periods of time or cancel the service at any time without notice to you.

You expressly agree that your use of the service or inability to use the service is at your own risk. The service and all products and services delivered to you through the service (unless otherwise specified by us) are provided “as is” and “as available” for your use, without any representation, warranty or condition of any kind, either express or implied, including all implied warranties or conditions of merchantability, merchantable quality, fitness for a particular purpose, durability, title and non-infringement.

In no event shall Meridian Company Group SAS, our directors, officers, employees, affiliates, agents, contractors, interns, suppliers, service providers or licensors be liable for any injury, loss, claim or any direct, indirect, incidental, punitive, special or consequential damages of any kind, including but not limited to; loss of profits, loss of revenue, loss of savings, loss of data, replacement costs or similar damages, whether in contract, tort (including negligence), strict liability or otherwise, arising out of your use of any of the service or any product purchased through the service, or for any other claim related in any way to your use of the service or any product, including, without limitation, any errors or omissions in any content, or any loss or damage of any kind incurred as a result of your use of the service or any content (or product) posted, transmitted or made available through the service, even if advised of their possibility.

Because some states or jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, in such states or jurisdictions, our liability shall be limited to the maximum extent permitted by law.

SECTION 14: INDEMNIFICATION

You agree to indemnify, defend and hold harmless Meridian Company Group SAS and our parent, subsidiaries, affiliates, partners, officers, directors, agents, contractors, licensors, service providers, subcontractors, suppliers, interns and employees, harmless from any claim or demand, including reasonable attorneys’ fees, incurred by any third party due to or arising out of your breach of these Terms of Service or the documents they incorporate by reference, or your violation of any law or the rights of a third party that you make.

SECTION 15: SEVERABILITY

In the event that any provision of these Terms of Service is determined to be unlawful, void or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed severable from these Terms of Service, without such determination affecting the validity and enforceability of the remaining provisions.

SECTION 16: TERMINATION

The obligations and liabilities of the parties incurred prior to the date of termination shall survive termination of this agreement for all purposes.

These Terms of Service are effective unless terminated by either you or us. You may terminate these Terms of Service at any time by notifying us that you no longer wish to use our Services or when you cease using our site.

If in our sole judgment you breach, or we suspect that you have breached, any term or provision of these Terms of Service, we may also terminate this agreement at any time without notice and you will remain liable for all amounts due, up to and including the date of termination; and/or we may deny you access to our Services (or any part thereof) as a result.

SECTION 17: ENTIRE AGREEMENT

Our failure to exercise or enforce any right or provision of these Terms of Service shall not constitute a waiver of such right or provision.

These Terms of Service and any policies or operating rules posted by us on this site or with respect to the Service constitute the entire agreement and understanding between you and us and govern your use of the Service, superseding any prior or contemporaneous agreements, communications or proposals, whether oral or written, between you and us (including, without limitation, prior versions of the Terms of Service).

Any ambiguity in the interpretation of these Terms of Service shall not be construed against the drafting party.

SECTION 18: GOVERNING LAW

These Terms of Service and any separate agreements whereby we provide you Services shall be governed by and construed in accordance with the laws of trans 1b east 7a-08, Bogota, AL, 110111, Colombia.

SECTION 19: CHANGES TO TERMS OF SERVICE

You may review the most recent version of the Terms of Service at any time on this page.

We reserve the right, at our sole discretion, to update, change or replace any part of these Terms of Service by posting updates and changes on our website. It is your responsibility to check our website periodically for changes. Your continued use of our website or the Service or your access to any of these on an ongoing basis following the posting of any changes to these Terms of Service constitutes your acceptance of those changes.

SECTION 20: CONTACT INFORMATION

Questions about the Terms of Service should be sent to meridiancompanygroupsas@gmail.com.

PERSONAL DATA PROTECTION POLICY

MERIDIAN COMPANY GROUP, S.A.S with Nit 901273972-3, operator of OurSecretCol, has decided to establish the rules for the collection, use, management, transmission and other activities involving information or personal data. The above is mandatory for all employees of the company, its contractors, suppliers, third party allies and other persons acting as Agents, in order to fully comply with the provisions of the Political Constitution of Colombia and Law 1581 of 2012, as well as other rules that regulate and complement the treatment for the Protection of Personal Data in Colombia.
Definitions Privacy Notice: Verbal or written communication generated by the responsible party, addressed to the data processor for the processing of personal data, by means of which the existence of policies, the access channels of such policies and the purposes of the processing of personal data are informed. Authorization: Prior, express and informed consent of the Mandatee to carry out the Processing of his personal data. Database: Organized set of personal data that is subject to Processing. Personal Data: Any information linked or that may be associated to one or several determined or determinable persons (personal data may be public, semi-private or private). Private Data: Data which, due to its intimate or reserved nature, is only relevant to the Data Controller. Public Data: It is the data so qualified by the law or the National Constitution and is neither Semi-Private nor Private. Semi-private data: Semi-private data is data that is not of an intimate, reserved or public nature and whose knowledge or disclosure may be of interest not only to the data subject but also to a certain sector or group of persons or to society in general, such as financial and credit data of commercial or service activities. Sensitive Data: It is that which affects the privacy of the natural person Mandatee whose improper use can generate discrimination. Data Controller: It is the natural or legal person of public or private nature, acting by itself or jointly with others, decides on the database and / or data processing. For the purposes of this document is understood as Data Controller MERIDIAN COMPANY GROUP. Data Processor: Natural or legal person, public or private, which by itself or in association with others, performs the processing of personal data on behalf of the controller. Data Processor: Natural person whose personal data is the object of processing. Processing: Any operation or set of operations on personal data such as the collection, storage, use, circulation or deletion thereof.
Transmission: Processing of personal data that involves the communication of such data within and outside the Republic of Colombia and whose purpose is the performance of a processing by the processor on behalf of the Controller. 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, which in turn is responsible for the processing and is located inside or outside the country. Data Protection Officer: It is the person within MERIDIAN COMPANY GROUP, whose function is to monitor and control the implementation of the Personal Data Protection Policy. PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA In activities such as collection, handling, use, processing, storage and exchange carried out by MERIDIAN COMPANY GROUP, shall apply harmoniously the principles established by law for the effect: truthfulness or quality of data records, principle of purpose, principle of restricted circulation, principle of temporality of information, principle of comprehensive interpretation of constitutional rights, principle of security, principle of confidentiality, principle of freedom and principle of transparency: Access and Restricted Circulation: The Processing of the information is subject to the limits derived from the nature of the Personal Data, the provisions of the law and the Constitution. In this sense, the Treatment may only be made by persons authorized by the Trustee and / or by the persons provided by law. MERIDIAN COMPANY GROUP guarantees that the Personal Data, except for public information, will 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 Trustee or third parties authorized by law. Confidentiality: In accordance with the above definition, the confidentiality of the data is guaranteed depending on the nature of the same. Therefore, the information will be kept confidential during and after the activities that justify the processing of personal data. Principle of legality: The treatment of the information contained in the databases held by MERIDIAN COMPANY GROUP, will be applicable as appropriate, the provisions of Law 1581 of 2012 and other provisions that develop, modify and / or complement it. Principle of purpose: The processing of information contained in the databases held by MERIDIAN COMPANY GROUP obeys a legitimate purpose in accordance with the Constitution and the Law which is due and previously informed to the Trustee. Principle of freedom: The processing of information contained in the databases held by
MERIDIAN COMPANY GROUP is only exercised when it has the free, prior, express and informed consent of the Trustee. Principle of truthfulness or quality: The information subject to processing by MERIDIAN COMPANY GROUP will be truthful, complete, accurate, current, verifiable and understandable. No partial, incomplete, fractioned or misleading data will be processed. Principle of transparency: MERIDIAN COMPANY GROUP guarantees the right of the Trustee to obtain at any time and without restriction, information about the existence of data concerning him. Security Principle: The information will be handled with the technical, human and administrative measures that are necessary to provide security to the information avoiding its adulteration, loss, consultation, use or unauthorized or fraudulent access. Principle of Temporality: The period of conservation of the Personal Data will be the necessary to achieve the purpose for which it has been collected and/or while the Agent has pending obligations, direct or indirect responsibility, for the additional time required by special rules or by the statute of limitations. Data Processing Purposes The Personal Data developed under Law 1581 of 2012 and other rules that modify or add to it will be used for the following purposes: Clients and Users: a) Promote, market or offer, individually or jointly, products
and/or services of its own or offered in commercial alliance, through any means or channel, or to complement, optimize or deepen the portfolio of products and/or services currently offered. This authorization for the Processing of Personal Data is extended to the subordinate entities of MERIDIAN COMPANY GROUP, its parent company and the subordinate or related entities of its parent company or to any company in which they have direct or indirect shareholding (hereinafter “THE AUTHORIZED ENTITIES”).
b) As an element of analysis in pre-contractual, contractual and post-contractual stages to establish and/or maintain any contractual relationship, including as part of it, the following purposes: i. Update databases and process the opening and/or linking of products and/or services in MERIDIAN COMPANY GROUP or in any of THE AUTHORIZED ENTITIES, ii. Evaluate risks derived from the potential contractual relationship, in force or concluded, iii. Perform, validate, authorize or verify transactions including, when required, the consultation and reproduction of sensitive data such as fingerprint, image or voice, iv. Obtain knowledge of the commercial or transactional profile of the agent, the birth, modification, conclusion and/or extinction of
direct, contingent or indirect obligations, the breach of the obligations acquired with MERIDIAN COMPANY GROUP or any third party, as well as any developments in relation to such obligations and payment habits MERIDIAN COMPANY GROUP and / or third parties. v. To know the status of current active or passive operations or of any nature or those that in the future MERIDIAN COMPANY GROUP may enter into with other commercial companies, with any information operator or database administrator or any other similar entity that may be established in the future and whose purpose is any of the above activities, vi. To know
information about the management of current accounts, savings, deposits, credit cards, commercial behavior, labor and other products or services and, in general, about the compliance and management of credits and obligations, whatever their nature may be. This authorization includes information regarding the management, status, compliance of relationships, contracts and services, payment habits, including contributions to the social security system, obligations and current debts, overdue without cancellation, processes, or improper use of financial services. vii. Prevent money laundering, financing of terrorism, as well as detect fraud and other illegal activities, viii. To comply with its legal and contractual obligations, ix. Exercise its rights, including those related to judicial and extrajudicial collection activities and related actions to obtain payment of the obligations owed by the agent or its employer, if applicable, x. Implementation of software and technological services. c) Perform cross-selling of products and/or services offered by MERIDIAN COMPANY GROUP or by any of THE AUTHORIZED ENTITIES or their commercial allies, including the execution of co-branding agreements. d) Elaborate and report statistical information, satisfaction surveys, studies and market analysis, including the possibility of establishing contact for such purposes. e) Send messages, notifications or alerts through any means to send statements, disclose legal information, security, promotions, commercial, advertising, marketing, institutional or financial education campaigns, sweepstakes, events or other benefits and inform the principal about innovations made in its products and/or services, inform about improvements or changes in its service channels, as well as inform about other services and/or products offered by MERIDIAN COMPANY GROUP; THE AUTHORIZED ENTITIES or their
commercial allies. f) Carry out the relevant steps, including the collection and delivery of information before public or private, national or foreign authorities with jurisdiction over MERIDIAN COMPANY GROUP, THE AUTHORIZED ENTITIES or their activities, products and/or services, when required to comply with their legal or regulatory duties, including within these, those relating to the prevention of tax evasion, money laundering and financing of terrorism or other similar purposes issued by competent authorities. g) Validate information with the different databases of MERIDIAN COMPANY GROUP, of THE AUTHORIZED ENTITIES, of authorities and/or state entities and third parties such as the National Registry of Civil Status and its certified technological allies, information operators and other entities that are part of the Integral Social Security System, companies providing public services and mobile telephony, among others, to develop the activities of its main and related corporate purpose, and/or to comply with legal obligations. h) So that the Personal Data can be used as evidence. The Personal Data provided may be circulated and transferred to all areas of MERIDIAN COMPANY GROUP including service providers, network users, distribution networks and persons promoting its products and services, including callcenters, domiciled in Colombia or abroad, whether natural or legal persons, Colombian or foreign to its commercial force, telemarketing teams and/or data processors working on behalf of MERIDIAN COMPANY GROUP, including but not limited to contractors, delegates, outsourcing, outsourcing, outsourcing, network of offices or allies, in order to develop system hosting services, maintenance, analysis services, messaging services by e-mail or physical mail, delivery services, management of payment transactions, collection, among others. Suppliers: (i) To comply with legal standards of knowledge of the supplier; (ii) establish, maintain and deepen the contractual relationship; (iii) update information; (iv) evaluate risk; (v) deepen products and services; (vi) determine the level of indebtedness on a consolidated basis; (vii) carry out marketing, commercial research or statistics; (viii) for security reasons; (ix) to prevent money laundering, financing of terrorism and (x) to comply with legal and/or contractual regulations, and while having outstanding obligations, direct or indirect responsibilities, for the additional time required by special regulations or by the statute of limitations. Candidates and Employees: Candidate information, including information contained in the resume, is used for the purpose of evaluating candidates to become employees of MERIDIAN COMPANY GROUP. The purpose of the employees’ databases is to develop the working relationship with them and to involve them in the activities planned by MERIDIAN COMPANY GROUP. For Shareholders, the purpose of the data is to develop relations with them in compliance with the rights, obligations and duties established in the regulations in force. MERIDIAN COMPANY GROUP will recognize the following rights in favor of the agent in the legal terms established by Law 1581 of 2012 and its regulatory decrees: To know, update and rectify their personal data. 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. To request proof of the authorization granted, except when expressly exempted as a requirement for the processing, in accordance with the provisions of Law 1581 of 2012. Be informed, upon request, regarding the use that has been made of their personal data. Access free of charge to their personal data that have been subject to processing. File complaints before the Superintendence of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other rules that modify, add or supplement it. To revoke the authorization and/or request
the deletion of the data when the treatment does not respect the principles, rights and constitutional and legal guarantees. Note: The request for deletion or revocation will not proceed when the representative has a legal or contractual duty to remain in the database. For the activities described in this Document, MERIDIAN COMPANY GROUP will obtain the respective authorization of the Agent. This authorization may be contained in a physical document, electronic, data message, Internet, Web sites, provided verbally or by telephone or in any other format to ensure subsequent consultation, or by a suitable technical or
technological mechanism, which allows to express or obtain consent and by which it can be concluded unequivocally, that in the absence of conduct of the agent, the data would never have been captured and stored in the database or electronic repositories. It may also be obtained from clear and unequivocal conducts of the Data Subject that allow to reasonably conclude that he/she gave his/her consent for the Processing of his/her information. The Authorization of the Data Subject shall not be necessary when the law so provides, when it is information requested by a public or administrative entity in exercise of its legal functions or by court order, when it is Data of a public nature, in cases of medical or health emergency, when it is Data related to the Civil Registry of persons and for historical, statistical or scientific purposes when the law so allows it. Duties of the Data Controller MERIDIAN COMPANY GROUP as responsible for the
processing of personal data will use them for the purposes for which it is empowered in compliance with current regulations and meet the following duties provided for the Controllers and Data Processors, without prejudice to the other provisions of the law: Ensure the Trustee, at all times, the full and effective exercise of the right of habeas data. Request and keep a copy of the respective Authorization granted by the Trustee. Duly inform the Beneficiary about the purpose of the collection and the rights he/she is entitled to by virtue of the authorization granted. To keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access. Ensure that the information subject to processing is truthful, complete, accurate, current, verifiable and understandable. Update the information. Rectify the information when it is incorrect. To process the consultations and claims formulated by the Representatives in the terms indicated in the law. To inform, at the request of the Beneficiary, about the use given to its data. Inform the data protection authority when there are violations to the security codes and there are risks in the administration of the information of the Agents. Comply with the instructions and requirements given by the Superintendence of Industry and Commerce. Transmission of Data In accordance with the purposes stated in this document and subject to legal procedures, when MERIDIAN COMPANY GROUP transmits data, in the documents that are signed for the purpose, require the respective confidentiality of the same, compliance with these policies, and specify the purposes for which they are transmitted. MERIDIAN COMPANY GROUP may transfer and exchange Data to national and foreign authorities and agencies such as the IRS (Internal Revenue Service of the United States), information and documentation on products and / or services, income, deductions, source of resources, shareholders and related or related persons, managers and directors, for legal and / or tax purposes such as FATCA (Foreign Account Tax Compliance Act), inspection, supervision, compliance and verification of international governmental agreements. MERIDIAN COMPANY GROUP may also exchange Personal Information with governmental or public authorities such as administrative, tax, investigative and judicial authorities, as well as with entities and persons involved in legal proceedings (such as advisors, legal assistants, lawyers, accountants and in general experts in different fields) when necessary to attend legal proceedings, comply with applicable laws, respond to requests from national and foreign authorities, protect the operations of the Mandatee and MERIDIAN COMPANY GROUP as well as their interests and rights. MERIDIAN COMPANY GROUP will comply with the legal provisions in the international transmission and exchange of data. Activities on Sensitive Data If MERIDIAN COMPANY GROUP requires Sensitive Data and perform any activity on them, it will inform the Mandatee or his legal representative or guardian and obtain prior authorization, as well as the possibility for the Mandatee not to provide them. MERIDIAN COMPANY GROUP will not condition access to its products or services by not providing this authorization, unless such data are necessary for the birth and / or proper maintenance of the relationship or for the fulfillment of the duties of its charge and / or the Data Controller. Sensitive Data of minors will be treated in a way that ensures respect for their prevailing rights. Biometric data will be used for the establishment and maintenance of contractual relationships with MERIDIAN COMPANY GROUP, as well as for the verification of the identity of the Data Controller in financial transactions. Procedure for the Mandataries to exercise their rights In order to meet the request, the agent must prove his identity; in case the query or claim is not submitted by the agent, must attach a document stating the quality of representative, assignee, or attorney in fact. The request must indicate the physical or electronic address where you wish to receive the response. In the case of claims, a description of the facts that give rise to the claim and the documents you wish to attach to support it (optional) must be submitted. When any of the requirements are missing, you will be informed within five (5) days of receipt of your request. It will be understood that the claim has been abandoned if after two (2) months from the date of the request, the required information has not been submitted. In order to receive the requests and claims of the Agents, the Management will be in charge of solving these claims. Deadline: Responses to queries will be given no later than ten (10) business days from the date of receipt, which may be extended for five (5) more business days. In case of claims, a response will be given no later than fifteen (15) business days, which may be extended for eight (8) more business days, in accordance with the provisions of the Law. Validity of the databases MERIDIAN COMPANY GROUP will keep the databases as long as the Trustee does not revoke the authorization, provided that such revocation is appropriate. Responsible for the information MERIDIAN COMPANY GROUP is responsible for the activities carried out on the information on which it performs the activities outlined in this document. MERIDIAN COMPANY GROUP is a commercial company, with NIT 901273972-3, domiciled in Bogota. The address for notifications is carrera 1c este No. 7a-08 sur Int. 2 apt. 202 in Bogotá D.C. Modification of the Policies Modifications to these policies will be informed through the web page https://oursecretcol.com/; those that are substantial will be previously informed to the Agents through the same means before being implemented. Validity These policies are effective as of July 1, 2022.

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