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Spectrum Technology S.A.S

Personal Data Processing Policy

Effective date: July 2026

Spectrum is committed to protecting the personal data of the individuals and legal entities that interact with its website and commercial channels. This Personal Data Processing Policy (hereinafter, the "Policy") clearly and transparently describes how we collect, use, store and protect the information provided by users, in compliance with Colombian Law 1581 of 2012, Decree 1377 of 2013, and any other rules that amend or supplement them, and observing, to the extent applicable, the principles and standards of the European Union’s General Data Protection Regulation (GDPR).

1. Purpose and scope

Data controller: Spectrum Technology S.A.S. (hereinafter "Spectrum"), identified with Tax ID [Tax Identification Number], is the entity responsible for processing the personal data collected through its website and commercial contact form.

This Policy applies to all personal and corporate information that Spectrum collects through its website, specifically through the commercial contact form provided for inquiries about cybersecurity, technology infrastructure, connectivity, IT services and artificial intelligence. By filling out that form, the user accepts the terms described here and authorizes the processing of their data in accordance with the purposes set out below.

Data controller contact details

  • Legal name: Spectrum Technology S.A.S.
  • Tax ID: [Tax Identification Number]
  • Privacy contact email: [privacy email, e.g. privacidad@spectrumt.co]
  • Physical address: [To be defined]
  • Main channel for rights requests: email / contact form available on the website

2. Data collected

Through the commercial contact form (Cybersecurity) available on the website, Spectrum exclusively collects the following data:

  • Full name
  • Corporate email
  • Company
  • Role
  • Phone number
  • Service of interest
  • Message

Spectrum does not collect sensitive data (such as ethnic origin, religious beliefs, health or biometric data) through this form. The information requested corresponds to corporate contact data, necessary only to manage the business relationship initiated by the user.

3. Purpose of processing

The data collected will be used exclusively for the following purposes:

Purpose A — Commercial management (mandatory)

To manage requests for information about Spectrum’s cybersecurity and technology infrastructure services, prepare and send quotes, respond to inquiries raised, and establish the commercial contact requested by the user. This purpose is essential to handle the request and is therefore a necessary condition for submitting the form.

Purpose B — Value-added communications (optional)

To send newsletters, cybersecurity industry news, and Spectrum promotions and offers. This purpose will only be carried out if the user expressly and voluntarily checked the optional box provided for that purpose in the form. The user may unsubscribe or revoke this authorization at any time, without affecting the handling of their commercial request (Purpose A).

4. User rights (Colombian ARCO rights)

As the data subject, any user who has provided their information to Spectrum has the right to:

  • Know, update and correct their personal data held by Spectrum as the data controller.
  • Request proof of the authorization granted, except where expressly exempted as a requirement for processing.
  • Be informed, upon request, of how their personal data has been used.
  • File complaints with the competent authority (in Colombia, the Superintendence of Industry and Commerce) for violations of applicable regulations.
  • Revoke the authorization and/or request deletion of their data, when there is no legal or contractual duty preventing its removal.
  • Access, free of charge, the personal data that has been processed.

Procedure for exercising your rights

To know, update, correct or delete your data, or to revoke the consent granted (including opting out of newsletters and commercial communications under Purpose B), the user must send a request to [privacy email, e.g. privacidad@spectrumt.co], stating their full name, the company they represent, and a clear description of their request. Spectrum will respond within the terms established by Colombian Law 1581 of 2012 (a maximum of ten (10) business days for inquiries and fifteen (15) business days for complaints, extendable when the complexity of the case requires it, with due notice to the data subject).

5. Data retention and security

Spectrum implements reasonable technical, human and administrative measures to protect personal data against loss, misuse, unauthorized access, alteration or disclosure. These measures include the use of SSL encryption on the website to protect the transmission of information submitted through the contact form.

Personal data will be retained only for as long as necessary to fulfill the commercial purpose for which it was collected, or for the period required by applicable legal, contractual or accounting obligations. Once that purpose has been fulfilled and the legal retention periods have expired, the data will be securely deleted or anonymized.

6. Data transfer and transmission

Spectrum does not sell, rent or share the corporate data collected with third parties unrelated to its business operations. The information provided by users is used exclusively for the purposes described in this Policy.

Data may be accessed by Spectrum’s internal staff or by technology vendors that provide website support services (for example, hosting or email tools), who act as data processors under contractual confidentiality and security obligations, and only to the extent necessary to provide those services. Under no circumstances are these third parties authorized to use the information for purposes other than those established here.

7. Validity and changes

This Policy is effective as of July 2026. Spectrum reserves the right to modify or update this Policy at any time, in order to reflect regulatory, operational or technological changes. Any changes will be published promptly on Spectrum’s website, indicating the date of the last update, so users are advised to review this Policy periodically.

Last updated: July 2026

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