Personal Data Protection Policy

www.enerbridgecapital.com

POLICY ON THE PROCESSING AND PROTECTION OF PERSONAL DATA

In compliance with Laws of the Republic of Colombia (Colombian Constitution; Decree 1377 of 2013, Decree 1727 of 2009, Decree 2952 of 2010, Law 1581 of 2012, Law 1266 of 2008 and other applicable regulations), Enerbridge Capital S.A.S. adopts this Policy on the Processing and Protection of Personal Data. This policy will be communicated to all individuals whose personal data is collected or processed in the course of our commercial and corporate activities.

Enerbridge Capital S.A.S. guarantees the right to privacy, intimacy, and good reputation in the processing of personal data, respecting the principles of legality, purpose, freedom, accuracy, transparency, restricted access and circulation, security, and confidentiality. Any person who provides personal information to Enerbridge Capital S.A.S. may know, update, and rectify their data at any time.

IDENTIFICATION OF THE DATA CONTROLLER

  • Corporate Name: Enerbridge Capital S.A.S.

  • Email: management@enerbridgecapital.com

  • Phone: (+57) 305-3246138

SCOPE OF APPLICATION

This policy applies to the processing of personal data stored in databases managed by Enerbridge Capital S.A.S., whose owner is a natural person.

DEFINITIONS

  • Authorization: Prior, express, and informed consent of the data subject for data processing.

  • Database: Organized set of personal data subject to processing.

  • Personal data: Any information linked or associable to a natural person.

  • Sensitive data: Information that affects the privacy of the data subject or may lead to discrimination (health, religious beliefs, biometric data, etc.).

  • Data controller: Natural or legal person who decides on the processing of data.

  • Data processor: Person who processes data on behalf of the data controller.

GOVERNING PRINCIPLES

Enerbridge Capital S.A.S. will apply the following principles in the processing of personal data:

  • Legality: Compliance with applicable regulations.

  • Purpose: Data will be collected for a legitimate and informed purpose.

  • Freedom: Processing will be carried out with the consent of the data subject, except in legal exceptions.

  • Accuracy: Information will be complete, accurate, and updated.

  • Security: Protection measures will be implemented against unauthorized access.

  • Confidentiality: Data will only be disclosed in cases permitted by law.

RIGHTS OF DATA SUBJECTS

Data subjects have the following rights:

  1. To know, update, and rectify their personal data.

  2. To request proof of the authorization granted for data processing.

  3. To be informed about the use of their personal data.

  4. To file complaints before the Superintendence of Industry and Commerce for non-compliance.

  5. To revoke authorization and request the deletion of their data when legal principles are not respected.

  6. To access their personal data free of charge.

DUTIES OF ENERBRIDGE CAPITAL S.A.S.

Enerbridge Capital S.A.S. commits to:

  • Guaranteeing the right to habeas data.

  • Requesting and keeping evidence of authorization for data processing.

  • Implementing security measures for the protection of personal data.

  • Updating, rectifying, and deleting data when necessary.

  • Addressing queries and complaints from data subjects.

  • Using data exclusively for authorized purposes.

  • Informing the competent authority about security incidents.

AUTHORIZATION AND CONSENT

Enerbridge Capital S.A.S. requires the free, prior, express, and informed consent of the data subject to process their personal data, except in legal exceptions:

  • Requests from public or judicial entities.

  • Data of a public nature.

  • Situations of medical or health emergencies.

  • Historical, statistical, or scientific research with anonymization measures.

Authorization may be obtained through physical, electronic, or verbal means, as appropriate.

REVOCATION OF AUTHORIZATION

The data subject may revoke their authorization at any time by submitting a written request to management@enerbridgecapital.com.

INFORMATION SECURITY

Enerbridge Capital S.A.S. will implement technical, human, and administrative measures to protect personal data against unauthorized access, loss, alteration, or fraudulent use.

UPDATES AND MODIFICATIONS

Enerbridge Capital S.A.S. reserves the right to modify this policy at any time. Updates will be published at www.enerbridgecapital.com.

CONTACT INFORMATION

For queries, complaints, or requests related to personal data processing, data subjects may contact us through:

  • Email: management@enerbridgecapital.com

  • Phone: (+57) 305-3246138

This policy takes effect from its publication on December 29 of 2024.