Personal data processing policy

• COMPANY NAME: AMERICA DE CALI, UNDER REORGANIZATION
• NIT. 890.305.773-4
• ADDRESS: Pan-American Highway Kilometer 7, Road to Jamundí – Cascajal Alley
• EMAIL: basesdedatos@americadecali.com.co

With the implementation of this policy, the aim is to guarantee the confidentiality of information and the security of its processing for all shareholders, clients, suppliers, employees and third parties from whom AMÉRICA DE CALI SA EN REORGANIZACIÓN has legally obtained information and personal data in accordance with the guidelines established by law.

This PERSONAL DATA PROTECTION POLICY is mandatory.

• AUTHORIZATION: prior, express and informed consent of the owner to carry out the processing of personal data.
• PRIVACY NOTICE: Verbal or written communication generated by the responsible party, addressed to the data subject 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, how to access them and the purposes of the processing that is intended to be given to the personal data.
• DATABASE: an organized set of personal data that is subject to processing.
• SUCCESSOR: person who has succeeded another due to the latter's death (heir) .
• PERSONAL DATA: any piece of information linked to one or more specific or identifiable persons or that can be associated with a natural or legal person.
• PUBLIC DATA: This refers to data that is not semi-private, private, or sensitive. Public data includes, among other things, information relating to a person's marital status, profession or occupation, and their status as a merchant or public servant. By their nature, public data may be contained in, among other sources, public registries, public documents, official gazettes and bulletins, and duly executed court judgments that are not subject to confidentiality.
• SENSITIVE DATA: Sensitive data is understood to be data that affects the privacy of the data subject or whose misuse may generate discrimination, such as data that reveals racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in trade unions, social or human rights organizations or organizations that promote 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.
• OPTIONAL DATA : These are data that AMÉRICA DE CALI SA IN REORGANIZATION
• DATA PROCESSOR : natural or legal person, public or private, who, alone or in association with others, carries out the processing of personal data on behalf of the Data Controller.
• DATA PROTECTION LAW : is Law 1581 of 2012 and its regulatory Decrees or the rules that modify, complement or replace them.
• HABEAS DATA : the right of any person to know, update and rectify the information that has been collected about them in the database and in the files of public and private entities.
• DATA PROTECTION OFFICER: Responsible for monitoring, controlling and promoting the application of the Personal Data Protection Policy within AMÉRICA DE CALI SA EN REORGANIZACIÓN.
• DATA CONTROLLER : natural or legal person, public or private, who alone or jointly with others, decides on the database and/or processing of the data.
• DATA SUBJECT: natural person whose personal data is subject to Processing.
• PROCESSING: any operation or set of operations performed on personal data, such as collection, storage, use, circulation or deletion.
• TRANSFER: Data transfer occurs when the controller and/or processor of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is responsible for the processing and is located inside or outside the country.
• TRANSMISSION: processing of personal data that involves the communication of the same within or outside the territory of the Republic of Colombia when its purpose is the processing by the processor on behalf of the controller.

Under this PERSONAL DATA PROTECTION AND PROCESSING POLICY, the following regulatory references and the procedures and guidelines issued by AMÉRICA DE CALI SA EN REORGANIZACIÓN for the processing of personal data apply.

• Political Constitution, article 15.
• Law 1266 of 2008
• Law 1581 of 2012
• Regulatory Decrees 1727 of 2009 and 2952 of 2010,
• Partial Regulatory Decree 1377 of 2013
• Jurisprudence
• Circulars from the Superintendency of Industry and Commerce.

In the development, interpretation and application of Law 1581 of 2012, which establishes general provisions for the protection of personal data, and the regulations that complement, modify or add to it, the following guiding principles will be applied harmoniously and comprehensively:

1. PRINCIPLE OF LEGALITY: Data processing is a regulated activity that must comply with the provisions of the law and other regulations that develop it.
2. PRINCIPLE OF PURPOSE: the processing must be for a legitimate purpose in accordance with the Constitution and the Law, which must be communicated to the data subject. Regarding the collection of personal data, it will be limited to data that is relevant and adequate for the purpose for which it was collected or required; the data processor must inform the data subject of the reason why the information is requested and the specific use that will be given to it.
3. PRINCIPLE OF FREEDOM: Processing may only be carried out with the prior, express, and informed consent of the data subject. Personal data may not be obtained or disclosed without prior authorization, or in the absence of a legal or judicial mandate that waives the requirement for consent.
4. PRINCIPLE OF TRUTHFULNESS OR QUALITY: The information subject to processing must be truthful, complete, accurate, up-to-date, verifiable, and understandable. The processing of partial, incomplete, fragmented, or misleading data is prohibited.
5. PRINCIPLE OF TRANSPARENCY: in the processing, the right of the data subject to obtain from the controller or the processor, at any time and without restrictions, information about the existence of data concerning him or her must be guaranteed.
6. PRINCIPLE OF RESTRICTED ACCESS AND CIRCULATION: The processing of personal data is subject to the limitations arising from the nature of the data, the provisions of the law, and the Constitution. In this regard, processing may only be carried out by persons authorized by the data subject and/or by persons authorized by law. Personal data, except for public information, may not be available on the internet or other means of mass dissemination or communication, unless access is technically controllable to ensure restricted access only to data subjects or third parties authorized by law.
7. SECURITY PRINCIPLE: Information subject to processing by AMÉRICA DE CALI SA EN REORGANIZACIÓN must be handled with the technical, human and administrative measures necessary to ensure the security of the records, preventing their alteration, loss, consultation, use or unauthorized or fraudulent access. 
8. PRINCIPLE OF CONFIDENTIALITY: AMÉRICA DE CALI SA IN REORGANIZATION is obliged to guarantee the confidentiality of the information, even after the end of its relationship with any of the tasks that comprise the processing, and may only supply or communicate personal data when it corresponds to the development of the activities authorized by law.

The data subject shall have the following rights:

• You have the right to update, access, and correct your personal data held by AMÉRICA DE CALI SA EN REORGANIZACIÓN, in its capacity as data controller. This right may be exercised, among other things, with respect to data that is partial, inaccurate, incomplete, fragmented, misleading, or whose processing is expressly prohibited or has not been authorized.
• Request proof of the authorization granted to AMÉRICA DE CALI SA EN REORGANIZACIÓN except when expressly exempted as a requirement for the treatment (cases in which authorization is not necessary).
• To be informed by AMÉRICA DE CALI SA EN REORGANIZACIÓN upon request, regarding the use that has been made of your personal data.
• To file complaints with the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, add to or complement it.
• Revoke authorization and/or request the deletion of data when the Processing does not respect the constitutional and legal principles, rights and guarantees.

Access your personal data that has been processed, free of charge.

A) DUTIES OF AMERICA DE CALI SA IN REORGANIZATION

Under this policy for the processing and protection of personal data, the following are the duties of AMÉRICA DE CALI SA EN REORGANIZACIÓN , without prejudice to the provisions provided for by law.

• Request and keep a copy of the respective authorization granted by the holder.
• Properly inform the data subject about the purpose of the collection and the rights they have under the authorization granted.
• Keep the information under the necessary security conditions to prevent its alteration, loss, consultation, use or unauthorized or fraudulent access.
• Ensure that the information is truthful, complete, accurate, up-to-date, verifiable, and understandable.
• Update the information, taking into account all changes regarding the data subject's information. Additionally, all necessary measures must be implemented to ensure the information remains up-to-date.
• Correct the information when it is incorrect and communicate what is relevant.
• Respect the security and privacy conditions of the data subject's information.
• Process inquiries and complaints submitted in accordance with the terms established by law.
• Identify when certain information is under discussion by the owner.
• Inform the data subject, upon request, about the use given to their data.
• Inform the data protection authority when security code violations occur and there are risks in the management of data subjects' information.
• Comply with the requirements and instructions issued by the Superintendency of Industry and Commerce on the matter in particular.
• Use only data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012.
• AMÉRICA DE CALI SA EN REORGANIZACIÓN will use the personal data of the owner only for those purposes for which it is duly authorized and respecting in all cases the current regulations on the protection of personal data.
• To guarantee the holder, at all times, the full and effective exercise of the right of habeas data.

B) THE NATIONAL REGISTER OF DATABASES

The National Database Registry (RNBD) is the public directory of databases subject to processing that operate in the country and will be administered by the Superintendency of Industry and Commerce and will be freely accessible to citizens.

AMÉRICA DE CALI SA EN REORGANIZACIÓN will provide the Superintendency of Industry and Commerce with the databases subject to processing within the indicated time and their respective changes in the terms defined by law.

C) AUTHORIZATIONS AND CONSENT OF THE HOLDER

Without prejudice to the exceptions provided for in the Law, the processing of personal data of the holder requires the prior and informed authorization of the holder, which must be obtained by any means that can be subsequently consulted.

D) AUTHORIZATIONS AND CONSENT OF THE OWNER

AMÉRICA DE CALI SA EN REORGANIZACIÓN, in accordance with the terms of the Law, generated a notice informing data subjects that they can exercise their right to the processing of personal data through the following channels:

 EMAIL: basesdedatos@americadecali.com.co .

TELEPHONE: (02) 3160260

E) EVENTS IN WHICH THE AUTHORIZATION OF THE PERSONAL DATA SUBJECT IS NOT NECESSARY

The authorization of the data subject will not be necessary in the following cases:

1. Data of a public nature.
2. Cases of medical or health emergencies.
3. Processing of information authorized by law for historical, statistical, or scientific purposes. Data related to the Civil Registry of persons.
4. Information required by a public or administrative entity in the exercise of its legal functions or by court order.

F) LEGITIMACY FOR THE EXERCISE OF THE RIGHT OF THE HOLDER

The rights of the holders established in the Law may be exercised by the following persons:

1. By the holder, who must sufficiently prove their identity through the various means made available by AMÉRICA DE CALI SA EN REORGANIZACIÓN
2. By the successors of the holder, who must prove such status.
3. By the representative and/or attorney of the holder, after accreditation of the representation or power of attorney.
4. By stipulation in favor of or for another. The rights of children and adolescents shall be exercised by the persons authorized to represent them. (Applies to Minors).

G) PROCESSING TO WHICH THE DATA WILL BE SUBJECTED AND ITS PURPOSE

The processing of personal data of clients, collaborators, suppliers and contractors, among others, will be framed within the legal order and by virtue of the condition of AMÉRICA DE CALI SA IN REORGANIZATION.

The policies and procedures contained in this document apply to the databases and files that AMÉRICA DE CALI SA EN REORGANIZACIÓN collects, stores, uses, and manages throughout its administrative and sports organizational structure.

Likewise, it applies to personal data from Facebook users, Twitter followers, and followers, contacts, users of any social media account and internet pages of AMÉRICA DE CALI SA EN REORGANIZACIÓN

As a consequence of the development of the corporate purpose of AMÉRICA DE CALI SA EN REORGANIZACIÓN for the promotion, sponsorship and practice of football, with athletes under remuneration, in accordance with the rules of the respective federation and the national sports system, it will be possible to contact and collect data from natural persons interested in linking themselves with the corporate purpose developed by AMÉRICA DE CALI SA EN REORGANIZACIÓN , data to which this policy will also apply.

In the case of sensitive personal data, it may be used and processed when:

1. The Data Subject has given explicit authorization for said Processing, except in cases where the granting of such authorization is not required by law;
2. The processing is necessary to safeguard the vital interests of the data subject and the data subject is physically or legally incapable of giving consent. In these cases, the legal representative must give their authorization;
3. The processing is carried out in the course of legitimate activities and with appropriate safeguards by a foundation, NGO, association, or any other non-profit organization whose purpose is political, philosophical, religious, or trade union-related, provided that it relates exclusively to its members or to persons who maintain regular contact with it in connection with its purpose. In these cases, the data may not be disclosed to third parties without the data subject's consent.
4. The Processing refers to data that is necessary for the recognition, exercise or defense of a right in a judicial process;
5. The processing has a historical, statistical, or scientific purpose. In this case, measures must be taken to anonymize the data subjects.

H) PERSONS TO WHOM THE INFORMATION MAY BE PROVIDED

Information that meets the conditions established by law may be provided to the following persons:

1. To the holders, their successors (when they are absent) or their legal representatives.
2. To public or administrative entities in the exercise of their legal functions or by court order.
3. To third parties authorized by the owner or by law.

I) PERSON OR AREA RESPONSIBLE FOR HANDLING REQUESTS, INQUIRIES AND COMPLAINTS

AMÉRICA DE CALI SA EN REORGANIZACIÓN has appointed the PERSONAL DATA PROTECTION OFFICER responsible for ensuring compliance with this policy within the company.

He will be attentive to resolve requests, queries and claims from the owners and to carry out any update, rectification and deletion of personal data, through the email: basesdedatos@americadecali.com.co.

J) PROCEDURE FOR HANDLING INQUIRIES, COMPLAINTS AND REQUESTS

1. Inquiries:

The Holders or their successors may consult the Holder's personal information held by AMÉRICA DE CALI SA EN REORGANIZACIÓN, who will provide all the information contained in the individual record or that is linked to the Holder's identification.

The inquiry will be made via email to basesdedatos@americadecali.com.co.

The inquiry will be addressed within a maximum of ten (10) business days from the date of receipt. If it is not possible to address the inquiry within this timeframe, the interested party will be informed, stating the reasons for the delay and indicating the date.

in which your inquiry will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.

2. Complaints:

At any time and free of charge, the owner or their representative may make claims related to corrections, updates or deletion of personal data that is processed by the Company, after proving their identity.

When the claim is made by a person other than the holder, the legal capacity or mandate to act must be duly accredited.

The Data Subject or their successors who consider that the information contained in a database should be corrected, updated or deleted, or when they notice the alleged breach of any of the duties contained in the law, may file a claim with AMÉRICA DE CALI SA EN REORGANIZACIÓN which will be processed under the following rules:

The Data Subject's claim must be submitted in writing to AMÉRICA DE CALI SA EN REORGANIZACIÓN via email to basesdedatos@americadecali.com.co . The request must include the Data Subject's identification, a description of the events giving rise to the claim, the address, and any supporting documents, following this procedure:

1. Holder: Identification document
2. Successor: Civil registry and identification document.
3. Legal representative in the case of minors: – Parents: Birth certificate and identity document. – Guardians: Court order granting legal representation
4. Legal representative authorized by the owner with the authenticated power of representation.
5. A clear and precise description of the type of claim made by the data subject (correction, update or deletion).
6. A clear and precise description of the personal data regarding which the holder seeks to exercise the right of complaint, as well as the facts that give rise to it.
7. Provide supporting documentation for your request if it is appropriate given the nature of the data.

If the claim is incomplete, the interested party will be required to correct the deficiencies within five (5) days of receiving the claim. If the applicant fails to submit the required information within two (2) months of the date of the request, it will be understood that they have withdrawn the claim.

If the person receiving the complaint is not competent to resolve it, they will forward it to the appropriate person within a maximum of two (2) business days and inform the interested party of the situation.

Once the email is received at basesdedatos@americadecali.com.co, with the complete claim, it will be categorized with the label "claim in process" and the reason for the claim will be indicated within a period of no more than two (2) business days. This label will remain until the claim is resolved.

The maximum time to address the claim will be fifteen (15) business days, starting from the day after the date of receipt. If it is not possible to address the claim within this period, 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 initial period.

3. Request for updating, rectification and deletion of data.

AMÉRICA DE CALI SA EN REORGANIZACIÓN will rectify and update, at the request of the data subject, any information that is incomplete or inaccurate, in accordance with the procedure and terms indicated above, for which the data subject will send the request to the email address basesdedatos@americadecali.com.co indicating the update, rectification and deletion of the data and will provide the documentation that supports his request. 

4. Revocation of authorization and/or deletion of data

At any time and free of charge, the owner or their representative may make claims related to corrections, updates or deletion of personal data that are processed by AMÉRICA DE CALI SA EN REORGANIZACIÓN , after accreditation of their identity, when the claim is made by a person other than the owner, the authorization or power to act must be duly accredited.

Data subjects may revoke their consent to the processing of their personal data at any time, provided that it is not prevented by a legal or contractual provision. For this purpose , AMÉRICA DE CALI SA EN REORGANIZACIÓN will make the email address basesdedatos@americadecali.com.co available to the Data Subject.

If, after the respective legal term has expired, AMÉRICA DE CALI SA EN REORGANIZACIÓN , as the case may be, has not deleted the personal data, the Data Subject shall have the right to request the Superintendency of Industry and Commerce to order the revocation of the authorization and/or the deletion of the personal data. For these purposes, the procedure described in Article 22 of Law 1581 of 2012 shall apply.

By accepting this policy, the Data Subject expressly authorizes the transfer and transmission of Personal Information. This information will be transferred and transmitted for all relationships that may be established with AMÉRICA DE CALI SA EN REORGANIZACIÓN.

5. Policy modifications

The Company reserves the right to modify this policy at any time. To this end, it will publish a notice on its website five (5) business days prior to its implementation and for the duration of the policy. If you do not agree with the new policies for handling personal information, the data subjects may...

information or their representatives may exercise their rights as data subjects under the terms previously described.

6. Use of the AMERICA DE CALI brand

Users, clients, employees, suppliers, or any third party with a direct or indirect relationship with AMÉRICA DE CALI SA EN REORGANIZACIÓN must refrain from carrying out, without prior written authorization, any initiative or activity that involves the use of its name, trademark, corporate name, symbol, logo, brand, or any other distinctive sign that implies the processing of personal information. Any activity or initiative undertaken without complying with this requirement will be the sole responsibility of its author and/or promoter and will not generate any effects, commitments, or liability whatsoever for AMÉRICA DE CALI SA EN REORGANIZACIÓN.

Depending on the nature of the information, the main scenarios that give rise to the processing of personal data and their corresponding purposes are described below:

1. Suppliers / purchases / customers / users and acquisitions:

• Verify commercial background, reputation and potential risks of relationships associated with Money Laundering and Terrorist Financing in accordance with the policies of the System for the Prevention and Control of Money Laundering and Terrorist Financing (SIPLAFT).
• To legally and commercially link the national and international supplier, client, user with AMÉRICA DE CALI SA EN REORGANIZACIÓN , allowing their registration in the management systems of AMÉRICA DE CALI SA EN REORGANIZACIÓN for the development of the accounting, logistics and financial procedures of the operation.
• Formalize the contractual relationship with the supplier, monitoring the full execution of the obligations assumed.
• Evaluate the supplier's performance and results with a view to strengthening procurement or supply procedures.
• Develop marketing and market intelligence activities, seeking to strengthen commercial management
• Manage communication and customer loyalty activities, as well as the timely handling of requests, complaints, claims and applications.
• Evaluate the job profile of applicants with a view to selection and formalization of the employment relationship.
• Verify academic, work, personal, family, business and other significant socioeconomic background of the job applicant, according to the requirements of the position.
• Manage before the administrative authorities the linking, affiliation or reporting of changes associated with the general social security system, as well as other welfare and benefits obligations of a labor nature.
• Register the worker in the Organization's computer management systems, allowing the development of accounting, administrative and financial activities inherent to the employment relationship.
• Manage new employment-related matters that affect payroll processing and payment. – Promote the development of activities that foster the well-being and comprehensive development of the employee and their work and family environment.
• Manage training and development programs in accordance with job requirements and corporate guidelines.
• Manage the occupational health and safety management system, promoting risk mitigation, as well as the proper handling of incidents or events of Work Accidents or Occupational Disease.
• Evaluate the performance and analyze the functional competencies of the workers with a view to determining the career plan and comprehensive development.
• Manage the procedures for termination of employment or retirement, as well as compliance with the corresponding financial obligations.
• To guarantee the right of collective association and to manage the economic, administrative, social and organizational aspects derived from its exercise.
• Manage the development and fulfillment of the operational and functional tasks associated with the job profile.
• Formalize the registration and linking of minors to the training programs of soccer schools.
• To evaluate and analyze the child's overall performance with a view to strengthening their sports skills, through the manual or systematized recording of the different variables and performance criteria.
• Manage registration and participation in sporting events, as well as the logistical aspects associated with their development, such as equipment supply, transportation and general medical care.
• To promote and advertise the AMERICA DE CALI brand and its associated training activity, the soccer schools.

The collection, storage, use, circulation or deletion of personal data during the development of the activities described in this policy, requires the free, prior, express and informed consent of the data subject.

1. Means and manifestations for granting authorization

Authorization for the processing of personal information required in the various processing scenarios described in this policy is obtained through the privacy requests and notices made available to the data subject at each of the physical, verbal, or digital information collection channels or points associated with the Organization's operations. These requests and notices are provided through forms, notices, or statements that inform the data subject about the collection and subsequent processing of their personal data, its purposes, their rights, the channels for exercising their rights, and, where applicable, how to access this policy. The data subject's authorization for data processing must be expressly granted and may be given in any of the ways established by law, taking into account the nature of each information collection channel. This authorization may be given in writing, verbally, or through the data subject's unambiguous actions or conduct.

2. Proof of authorization

Authorization for the processing of data collected during the activities described in this policy depends on the nature of the channel or point of information collection. The means of proof to demonstrate effective authorization for processing depends on the type of mechanism used to obtain authorization, such as a signed form, a registration of acceptance or access to the website, or a recording of the conversation. In cases of acceptance through unambiguous conduct, the following elements shall be considered sufficient proof of acceptance by the data subject:

• The authorization request form made available to the data subject at the time of data capture.
• The express indication in the authorization request form of the unequivocal conduct of the holder that constitutes authorization of the processing.
• Evidence of the unequivocal conduct by the holder, being feasible to prove the information provided by the holder or other type of evidence of express acceptance according to the nature of the channel.

• Regarding the use of cookies:
  Cookies are text files that are installed on the user's device when they visit a website or application. The use of these cookies allows, for example, the website to indicate whether the user has visited the site before or if it is their first time, as well as to identify which site features are most interesting to them. In this context, cookies may be used by AMÉRICA DE CALI SA EN REORGANIZACIÓN to improve the user's online experience by saving their preferences when they visit AMÉRICA DE CALI SA EN REORGANIZACIÓN 's applications. In carrying out its activities, particularly regarding the management of digital media, AMÉRICA DE CALI SA EN REORGANIZACIÓN may use its own or third-party cookies on its own platforms or those managed on its behalf, for the purpose of determining, for example, how many users visited the accessed applications. Eventually, the use of cookies by AMÉRICA DE CALI SA EN REORGANIZACIÓN will focus on the use of "personalization cookies," which are used to identify returning visitors to the websites, as well as "analytical cookies," which monitor how visitors use the websites and applications, helping to better understand which content users and visitors spend the most time reading. Therefore, the main cookies to be used by AMÉRICA DE CALI SA EN REORGANIZACIÓN are the following: These cookies help improve the websites over time, providing information on how the different sections of the websites are used and how users interact with them. The information collected is anonymous and statistical in nature.
  b) Authentication: These cookies are used to individually identify website visitors. When a user logs into the website, these cookies allow the website to remember who they are in order to grant them access to their preferences or personal settings. These cookies help maintain website security.
  c) Session: These cookies are designed to ensure that your visit to the Applications is as pleasant as possible. Their main functions are as follows: • To identify a device when accessing the Application, so that the user is not considered a new visitor each time they access another section of the application. • To ensure that each of the servers used to host the application serves the same number of users, allowing for more efficient browsing. • To record your browser settings. Similarly, cookies are used to remember user preferences for the applications, which means: • If the application user deletes all their cookies, they will have to update their preferences again. • If the user uses a different device, computer profile, or browser, they will have to re-enter their preferences. All information obtained through cookies is encrypted, and no personal data such as credit card numbers or other financial or credit information is collected. Most browsers provide instructions on how to reject new cookies, how to receive notifications of new cookies, and how to disable existing cookies. However, it is important to note that without cookies, users will not be able to take full advantage of the features of the Company's Applications. Any other additional or complementary use of cookies by the applications of AMÉRICA DE CALI SA EN REORGANIZACIÓN will be communicated to the user or owner in the respective web browsing terms and conditions.
• Regarding the use of IP addresses:
  An IP address is a unique identifier that some electronic devices use to detect and communicate with each other over the internet. When visiting, using, or accessing an application of AMÉRICA DE CALI SA EN REORGANIZACIÓN , whether managed directly or through a third party, the IP address of the device used by the user or data subject to connect to the internet may be displayed. This information may be used to determine the general physical location of the device and to identify the geographic regions from which visitors or users of the applications originate, in order to facilitate or enable the provision of a service. For example, it may be used to geolocate the user or data subject to facilitate the distribution or delivery of products. Whenever AMÉRICA DE CALI SA EN REORGANIZACIÓN uses this type of tool, the data subject will be informed in the respective terms and conditions of the application.
• Regarding the use of Web beacons
  PERSONAL DATA PROTECTION POLICY AMÉRICA DE CALI SA EN REORGANIZACIÓN may occasionally use “web beacons” (also known as “internet tags,” “pixel tags,” or “clear GIFs”) in its applications. These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page containing the beacon, the URL of the page containing the beacon, the time the page containing the beacon was viewed, the type of browser used to view the page, and information from cookies set by said third party. Whenever AMÉRICA DE CALI SA EN REORGANIZACIÓN uses these tools, the data subject will be informed in the respective terms and conditions of the corresponding application.