Personal Data Management Policy Lean Staffing Solutions

This policy reflects the type of information that LEAN STAFFING SOLUTIONS INC. (hereinafter the "Company"), collects, stores, uses, transmits, treats, and transfers, as well as the purposes of its treatment, and the general guidelines that will be applied to guarantee the adequate treatment of any personal information.

PARTY RESPONSIBLE FOR THE PROCESSING OF ANY PERSONAL DATA

COMPILED DATA

As a Private User, we collect your personal data in order to provide you with a better service. To create an account, you must provide us with information such as your first name, middle initial, last name and surname, email address, telephone number, as well as a password.

In the same way, you can also include your academic data, work experience and skills, your location, a photograph and additionally, you can upload your resume in word or PDF format in Spanish or English in your profile. We store information associated with the results of your psychometric tests, audio recordings, tracking records of use of our web portal and the duration of your activity on our portal.

As a Business User, in order to create an account on our Web Portal and use our services, you must provide us, with the identification data of the company, and the contact data of the person who will act on behalf of the company. These data are a name and surname, an email address, and a password.

As an Employee, in order to be linked as an employee of LEAN STAFFING SOLUTIONS INC, it is necessary that you provide us with your identification data, such as full name, type and number of identifying document; contact data, such as a cellphone number and / or landline number, an address, or residence address, an email address, a contact person, a relative or person in a relationship with the contact person, gender, date of birth, age, level of education, as well as all information related to academic levels, work experience, marital status, place of birth, nationality, number of children if any, information related to your

military record, healthcare provider (EPS), pension fund (AFP), benefits compensation fund, ARL, blood type, name of bank, and bank account number and type of account, apparel and footwear sizes, and in general any additional information important to the employment relationship. In the event that the information to be collected is of a sensitive nature, we will let you know in advance, announcing that it will not be mandatory to provide said, requested information.

As a Contractor/Supplier/Client/Lessor/ whether a natural or legal person, we collect contact information, such as landline and/or mobile phone numbers, a business or legal notification address, physical address, email address, type and number of identity, bank certification and in general all the data related to the respective certificate of existence and legal representation, commercial registration certificate and/or RUT and additionally any information related to the purpose of the contract.

DATA TREATMENT AND PURPOSE POLICY

LEAN STAFFING SOLUTIONS INC, will inform the owners of the information regarding the treatment that will be given to said information, and about the purposes thereof, in the respective Privacy Notices through which it disseminates the existence of these Personal Data Treatment Policies.

In general, LEAN STAFFING SOLUTIONS INC, will treat the collected information in the following manner:

  • Private User and Business User Information: (i) will be used to carry out the development of the company's corporate purpose; (ii) develop commercial and promotional campaigns; (iii) conduct satisfaction surveys; (iv) store such information in a database and keep a measurement for statistical purposes of those accessing the company's website and applying to job offers; (v) store a database and carry out analytics for statistical purposes of those entering the company's website seeking the provision or supply of services offered by LEAN STAFFING SOLUTIONS INC; (vi) such information will be used for contact purposes in order to celebrate eventual commercial or carry out labor relations, depending on the user; (vii) the other uses will involve those reserved for LEAN STAFFING SOLUTIONS INC, under its privacy policy.
  • Employee Information: (i) will be used to issue, publish, transmit, disseminate, and promote the welfare activities developed by LEAN STAFFING SOLUTIONS INC, to the labor community of the company, and through the different social networks that LEAN STAFFING SOLUTIONS INC, uses for advertising guidelines, as well as for radio or television commercials; (ii) to keep the contact information updated; (iii) to verify owner data; (iv) information will be used to build and update work history; (v) to verify and manage leaves of absence, and information related to disabilities andhealth conditions by the insurance entities of the social security system in health and pension fund entities.‍
  • Contractor/Supplier/Lessor Information: (i) will be used for the execution of the respective contracts or purchase orders; (ii) used in order to carry out the fulfillment of its tax and accounting obligations; (iii) to execute the due diligence requested by the Superintendency of Companies (Superintendencia de Sociedades en el capítulo X de su Circular Externa); (iv) it will be used for commercial, promotional and informative purposes; (v) to treat and respond to requests, complaints, claims, reports, suggestions and/or extend congratulatory messages.‍
  • Shareholder Information: We collect the data of the shareholders of the company in order to have sufficient information to carry out calls for ordinary or extraordinary meetings of the General Assembly of Shareholders, for the report of exogenous information addressed to the tax and national customs entities (DIAN), and to carry out the due diligence requested by the Superintendency of Companies (Superintendencia de Sociedades en el capítulo X de su Circular Externa).

LIMIT ON RETENTION OF PERSONAL INFORMATION

LEAN STAFFING SOLUTIONS INC, will keep the personal data for the duration of the contractual or commercial relationship with the respective person, or with the person they represent or with whom they are related, as well as for the time necessary to comply with the legal obligations of the Company. In general terms, the personal data collected by the Company will be kept for the term legally applicable to the type of personal data collected, and according to the database to which it belongs, namely:

  • Labor/Work Related Data (Employees): kept during the term of the contractual relationship, plus twenty (20) additional years.
  • Commercial and Accounting Data (Business Users/Private Users/ Lessors/Shareholders/Contractors/Suppliers): kept during the term of the civil or commercial relationship, and for ten (10) more years.

TRANSFER OF INFORMATION

The Company will transfer its Employees and Private Users to Business Users information in order to comply with the contractual obligations of LEAN STAFFING SOLUTIONS INC, which will be expressly accepted by the owners of the information in the respective Notices of Privacy. The Company will cause the holders of the information to be informed regarding the treatment policies that the respective Business Users will apply to the transferred data.

INFORMATION OWNERSHIP RIGHTS

As the owner of the personal data provided to the Company, you have the following rights:

  1. To know, update and rectify your personal data against that held by the Company. This right may be exercised, among others, against partial, inaccurate, incomplete, fragmented, misleading data, or the treatment of those items which are expressly prohibited or have not been authorized;
  2. To request proof of the authorization granted to the Company, except for data whose treatment does not require authorization, under the terms of the applicable legislation;
  3. To be informed by the Company, upon request, regarding the use that has been given to your personal data;
  4. To Submit complaints to the Superintendency of Industry & Commerce (Superintendencia de Industria y Comercio) for violations of the provisions of these Data Processing Policies or the law;
  5. To revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the treatment. The revocation and/or suppression will proceed when the Superintendence of Industry & Commerce (Superintendencia de Industria y Comercio) has determined that in the treatment the Company has engaged in conduct contrary to the law or the Political Constitution;
  6. To gain free access to your personal data which has been processed, all of which will be supplied through a media source.

INFORMATION RELATING TO MINORS

If you are a minor, we ask you not to provide information or personal data, since LEAN STAFFING SOLUTIONS INC, does not collect or process personal information of minors under eighteen (18) years of age.

SENSITIVE/CONFIDENTIAL INFORMATION

Unless specifically requested or called on you by the Company to provide such information, we ask that you do not submit, and do not disclose, sensitive personal data. In instances where we may request or call on you to provide confidential or sensitive information, we will do so with your express prior consent. The owner has the right to choose not to provide any sensitive information requested by LEAN STAFFING SOLUTIONS INC, related, among others, to data on their racial or ethnic origin, membership in trade unions, social or human rights organization affiliation, political, religious convictions, sexual preferences, biometrics, or health data, unless they are required for the exercise of legal functions or when there is an administrative order or judicial authority in charge.

VIDEO SURVEILLANCE

For security purposes and compliance with its obligations, LEAN STAFFING SOLUTIONS INC, uses various means of video surveillance installed in different internal and external sites of our facilities or offices. At the entrance to our facilities, the corresponding privacy notices will be posted, where the purpose of processing the data collected by said means is established, and the sensitive nature of said information is noted, as well as the voluntary nature of providing it.

INQUIRIES AND CLAIMS

To make queries or requests to know, update, rectify, delete the data provided or revoke the authorization granted thereafter, the owner or his successors in the capacity of his/her title can use any of the following communication channels:

NOTE: All inquiries received through these options outside of the established Service Schedule will be handled on the following workday.

To exercise the owner’s right in relation to their personal data, a written communication must be sent in a physical or electronic medium, which must contain the following:

  1. Full names and surnames of the owner of the data or their representative or proxy;
  2. Type and number of the applicant's identity document;
  3. The electronic or physical address where correspondence will be received and the telephone number where the owner may be reached;
  4. The object of the request and the reasons on which the request is based;
  5. Photocopy of the identification document of the holder and his/her representative or proxy, when applicable;
  6. Authenticated document that accredits the representation of the owner, when applicable;
  7. The signature of the petitioner or attorney, when applicable.

If the query or request is incomplete, LEAN STAFFING SOLUTIONS INC, will require the interested party, within five (5) days of receipt, to correct the mistakes. After two (2) months from the date of the request, without the petitioner submitting the requested and corrected information, it will be understood that he/she has withdrawn the respective query or request.

Once the query or complete request is received, the Company will include, in the respective database, a legend that reads, "Request in process," with a status comment within a term not exceeding two (2) business days from its receipt in a complete form. Said status will remain until the request is reviewed and a decision is reached.

QUERIES

All queries will be answered within a maximum term of ten (10) business days, beginning from the day following the date of receipt. When it is not possible to handle the query within said term, the interested party will be informed, stating the reasons for the delay and indicating the date on which his query will be handled, which in no case may exceed five (5) business days following the expiration of the first 10-day term.

CLAIMS

The holders or their successors in title, who consider that the information contained in a database of LEAN STAFFING SOLUTIONS INC, must be subject to correction, update, or deletion, or that warn of the alleged breach of any of the duties contained in Law 1581 of 2012, may submit a request or claim before LEAN STAFFING SOLUTIONS INC, in accordance with the mechanisms provided in this Data Processing Policy.

The maximum term period to address the claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay, and the date on which his claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first 15-day period.

DELETION OF DATA / REVOCATION OF AUTHORIZATION

As long as the Superintendence of Industry & Commerce (Superintendencia de Industria y Comercio) has determined that in the treatment of personal information, the Company has engaged in conduct contrary to this Policy, the law and/or the Political Constitution; the owner of said personal data, will have the right to request of LEAN STAFFING SOLUTIONS INC, to delete their personal data, or to revoke the authorization for its management and purpose; without overlooking that the right of deletion or revocation is not an absolute right, and that the Company, as the entity responsible for the processing of personal data, may deny or limit its exercise when:

  • The owner of the data has the legal or contractual duty to remain in the respective database;
  • The elimination of data hinders on pending judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions;
  • The data is necessary to protect the legally protected interests of the owner of information; to carry out an action based on the public interest, or to comply with an obligation legally acquired by the owner.

Notwithstanding the foregoing, it will be guaranteed that the data is used exclusively for the purpose requested, and the information is given the corresponding reservations.

VALIDITY AND MODIFICATIONS

This Policy is effective from its issuance. This Policy may be modified at any time, and its modifications will be made in accordance with current regulations. The Company will inform the holders of the information that a modification will be made to this Policy, in the event that said modification implies substantial changes, publishing the projected modification text on the following web page: https://www. leangroup.com/solutions/leanstaffing for a term of ten (10) business days, prior to starting the application process.

Date of Issuance: 09/06/2020

Date of Last Modification: 11/30/2021

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