Legal documentVersion 2 · in force since May 28, 2025

Personal Data Processing Policy

In compliance with Ley 1581 de 2012 (Colombia’s personal data protection law) and its implementing decrees, this policy explains which personal data we process, for what purpose and how you can exercise your rights as a data subject.

This is a courtesy translation. The binding version of this document is the Spanish one: read it in Spanish.

01Identification of the data controller

Legal name

MTechnology S.A.S.

Tax ID (NIT)

901.777.774-5

Principal address

Carrera 11B # 99-25, Chapinero, Bogotá D.C., Colombia

[email protected]

Phone

+57 601 846 0845

02Legal framework

This policy is issued in compliance with Ley 1581 de 2012 (Law 1581 of 2012, the general personal data protection law), Decreto 1377 de 2013 (Decree 1377 of 2013, which regulates it), Decreto Único Reglamentario 1074 de 2015 (Single Regulatory Decree 1074 of 2015 of the Commerce, Industry and Tourism sector) and other related rules for the protection of personal data in Colombia.

03Scope

This policy applies to all personal data recorded in the databases of MTechnology S.A.S., which acts as the data controller. It covers all personal data subjects, including but not limited to: visitors to our website, clients, prospective clients, suppliers, employees and job candidates.

04Key definitions

Authorization (autorización)

Prior, express and informed consent of the data subject to carry out the processing of personal data.

Database (base de datos)

Organized set of personal data that is subject to processing.

Personal data (dato personal)

Any information linked or that may be associated with one or more identified or identifiable natural persons.

Data processor (encargado del tratamiento)

Natural or legal person who processes personal data on behalf of the controller.

Data controller (responsable del tratamiento)

MTechnology S.A.S., which decides on the database and on the processing of the data.

Data subject (titular)

Natural person whose personal data is subject to processing.

Processing (tratamiento)

Any operation on personal data, such as collection, storage, use, circulation or deletion.

05Principles for the processing of personal data

MTechnology S.A.S. applies the principles defined in Ley 1581 de 2012:

Principle of legality
Principle of purpose
Principle of freedom
Principle of accuracy or quality
Principle of transparency
Principle of restricted access and circulation
Principle of security
Principle of confidentiality

06Purposes of processing

MTechnology S.A.S. will use the personal data collected for the following purposes:

Clients

Performance of contracts, provision of services, invoicing, communication, technical support and sending information about new services, subject to prior authorization.

Website visitors

Responding to inquiries sent through the contact forms; statistical analysis of browsing to improve our services and the user experience, through cookies and with your consent; measuring the effectiveness of our digital marketing campaigns and carrying out remarketing, through cookies and with your consent; and sending newsletters, subject to prior authorization.

Suppliers and freelancers

Management of the contractual relationship, payments and evaluation of services.

Employees and candidates

Selection processes, management of the employment relationship and compliance with legal obligations.

General

Compliance with legal and regulatory obligations, security management and internal statistical analysis. The use of third-party tools such as Google, Facebook or Microsoft may involve an international transfer of data.

07Rights of data subjects

As a personal data subject, you have the right to:

Know, update and rectify your personal data.
Request proof of the authorization granted.
Be informed about how your data has been used.
File complaints with the Superintendencia de Industria y Comercio (SIC, Colombia’s Superintendence of Industry and Commerce and data protection authority) for violations of the law.
Revoke the authorization or request the deletion of the data when the principles, rights and guarantees are not respected, or when there is no legal or contractual duty for it to remain in the database.
Access, free of charge, your personal data that is subject to processing.

08Procedure to exercise your rights

Send your request to [email protected] or to Carrera 11B # 99-25, Chapinero, Bogotá D.C.

The request must include your name, a contact detail, a description of what you are requesting, a copy of your identity document and any documents that help locate your data.

09Duties of MTechnology S.A.S. as data controller

Guarantee the data subject the exercise of their rights.
Request and keep a copy of the authorization.
Properly inform the data subject about the purpose and their rights.
Keep the information under secure conditions.
Handle inquiries and claims.
Inform the data protection authority when security breaches occur.
Comply with the instructions of the Superintendencia de Industria y Comercio.

10Effective date

This policy is effective as of May 28, 2025. The personal data provided will be kept for as long as the purpose for which it was collected remains, or for the periods established by current regulations.

MTechnology S.A.S. reserves the right to modify this policy, informing data subjects in a timely manner through our website or other means.

11Contact information

[email protected]

Website

mtechnology.co

Physical address

Carrera 11B # 99-25, Chapinero, Bogotá D.C., Colombia