POLICY ON PROTECTION, PRIVACY, AND PROCESSING OF PERSONAL DATA

The personal data that LICENCIAS ONLINE processes may include, but is not limited to, the following: - Potential customers, business partners, suppliers, and third parties with commercial interests: first and last names, date of birth, gender, email address, position, home and work address, landline and mobile phone number, financial data, commercial references, tax information, and all information necessary for the execution of all types of contracts or registration in digital administration and commerce applications. - Job candidates, employees, related professionals, and administrators: first and last names, gender, email address, home address, landline and mobile phone number, date of birth or age range, profession, information about family dependents, information about family members with conflicts of interest, date of birth of family dependents, photographs, fingerprints and fingerprint code, marriage certificate, health condition and examinations, medical records, medical certificates, as well as all information necessary to fulfill labor and welfare obligations for personnel working for LICENCIAS ONLINE. - Partners or shareholders: identification and contact data, address data, commercial references, and tax information. - Communication channel users: Information may be collected from users who access communication channels enabled by LICENCIAS ONLINE, for example, through social networks, email, digital platforms, instant messaging services, and website.

Personal data is obtained by LICENCIAS ONLINE from: - Directly from the Data Subject - Publicly accessible sources - Public Records, public administrations, lists for fraud prevention, money laundering, and terrorism financing. - From third parties that have lawful legitimate bases and consents granted by the Personal Data Subject. - From third parties who have collected personal data with prior consent of the Data Subject to fulfill the provision of products and services. - Derived from the use of systems, platforms, websites, applications, chats, bots, or social networks to create behavioral profiles. LICENCIAS ONLINE will process personal data based on the purposes for which they are obtained

LICENCIAS ONLINE, in the development of its commercial activities and relationships with third parties, processes the personal data of its administrators, customers, suppliers, employees and their families, for the following purposes:

- Offer products and services from LICENCIAS ONLINE's portfolio. - Carry out billing, collection, and payment processes. - To conduct relevant marketing activities such as sending personalized offers, promotions, contests, sweepstakes, event invitations, and in general digital advertising of LICENCIAS ONLINE's activities or its products and services, through emails, SMS, MMS, social networks, instant messaging services, WhatsApp, applications, and phone calls. - Attend to and respond to requests, claims, and petitions made through LICENCIAS ONLINE's different service channels. - Fulfill contractual obligations arising from the acquisition of services offered by LICENCIAS ONLINE. - Design or implement commercial strategies. - Update and notify changes in contracting conditions for products and services offered by LICENCIAS ONLINE. - Consult consumption habits and hobbies for offers, promotions, product and service quality, among others. - Validate commercial and credit references. - Conduct market studies and satisfaction surveys. Manage requests, complaints, and claims. - Manage and attend to the provision of LICENCIAS ONLINE's products and services - Establish communication channels through email, phone calls, SMS, WhatsApp, instant messaging tools, or any known or future communication channel. - Consult financial information and credit history, as well as consult unfulfilled obligations in various public portals. - To interact through LICENCIAS ONLINE's website or through an official social media account. - Control physical access to LICENCIAS ONLINE offices - Store in physical or digital databases. - Transfer to third parties with commercial interests, such as manufacturers or business partners. - Transfer to third parties who have the status of processors or sub-processors for the fulfillment of specific purposes, within and outside national territory, as well as to entities linked to LICENCIAS ONLINE. Data Subjects may request LICENCIAS ONLINE to suspend totally or partially some or several specific processing of their personal data. Notwithstanding the request, LICENCIAS ONLINE may process data that is strictly necessary for the fulfillment of its commercial activities, contract execution, pre-contractual measures, legal obligations, or legitimate interest. In the event that Data Subjects refuse to provide the data requested by LICENCIAS ONLINE, the purposes for which they were collected cannot be fulfilled.

- Conduct hiring processes and verification of information included in resumes submitted to LICENCIAS ONLINE - Guarantee the duties and rights derived from the candidate's condition as information holder; collect, register, and update the candidate's personal data for the purpose of conducting interviews and possible hiring, inform about the entity's activities. - In general, when a candidate participates in a selection process to fill a vacancy, contact them for interviews, apply knowledge tests, home visits, conduct respective medical and other evaluations, even contrast the work and personal references they have provided. - Verification of judicial and criminal records. - Store the Resume in physical or digital files. - Process any obligation that must be fulfilled before administrative, labor, social security authorities, or any other government agency. The aforementioned information is required for any application within personnel selection and recruitment processes.

- Send information by any known or future means (email, physical mail, SMS, phone calls, data messages, WhatsApp, instant messaging tools, among others), about information originating from the employment relationship. - Incorporate and store personal and biometric data of employees, related to their work activity in the company's active and historical files; - Administer personal data in order to comply with legal and contractual obligations that LICENCIAS ONLINE assumes as an employer in labor and social security matters.; - Assign physical and digital permissions within LICENCIAS ONLINE's facilities and systems for security monitoring purposes. - Administer personal data to correctly pay employees' remuneration. - Notify authorized contacts in case of emergencies during work hours or on the occasion of its development; - Have personal data available to assign work tools such as: email, computers, mobile phones, database access, software, etc.; issue certificates and attestations requested as a result of the employment relationship, health examinations, medical permits; process personal data to conduct (when necessary), performance, competency and skills tests, psychosocial evaluations, and all others generated by virtue of their employment relationship. - Verify judicial and criminal records. - Plan business activities. - Store in physical or digital files.

- Send information by any known or future means (email, physical mail, SMS, phone calls, data messages, WhatsApp, instant messaging tools, among others), about information originating from the contractual relationship. - Incorporate and store personal and biometric data of employees, related to their contractual activity in the company's active and historical files; - Administer personal data in order to comply with legal and contractual obligations that LICENCIAS ONLINE assumes. - Inform, communicate, organize, control, attend to, accredit activities in relation to their condition as supplier; manage data to carry out invoice payment processes and other actions that are the responsibility of LICENCIAS ONLINE; - Develop and apply selection processes, evaluation, preparation of responses to a request for information, prepare requests for quotations and proposals, and/or contract awards; - Contrast the commercial references they have provided; - Use, when necessary, the personal data of the supplier's or contractor's personnel in order to establish access controls to logical or physical infrastructure. - Store in physical or digital files.

- Establish communication channels with the Data Subject through email, phone calls, SMS, WhatsApp, instant messaging tools, or any known or future communication channel. - Control the register of shareholders or partners and exercise of their rights. - Control the Shareholders or Partners Register Book. - Provide information about dividend or profit payments. In general, LICENCIAS ONLINE may process personal data of the Data Subject without their consent, only when: i) permitted by law, ii) required by court order, iii) based on the fulfillment of a mission of public interest, iv) for the execution of pre-contractual measures or fulfillment of contractual obligations, v) to protect vital interests of the Data Subject; vi) for a legitimate interest

If LICENCIAS ONLINE requires sensitive data for the proper development of the company's own activities, data subjects must grant their express authorization, having prior knowledge of the optional nature of the response to questions about this type of data. In addition to the described authorization, the company may process this data when: - Processing is necessary to safeguard the vital interest of the data subject, and they are physically or legally incapacitated. In these events, legal representatives must grant their authorization. - Processing refers to data that is necessary for the recognition, exercise, or defense of a right in legal proceedings. - Processing is carried out by order of competent authority. - Processing has a historical, statistical, or scientific purpose. - Data of a public nature - Those described in Applicable Law

In LICENCIAS ONLINE's facilities, video surveillance systems can be found through which personal data such as image and video are captured, by means of cameras, video cameras, analog or digital or IP cameras, closed-circuit television (CCTV) for the purpose of carrying out the following purposes: - Provide security to property and people within a specific physical space - Monitor activities carried out by LICENCIAS ONLINE's employees and customers, mainly in relation to the services that the company provides to customers.

LICENCIAS ONLINE may transfer or communicate the personal data of Data Subjects to companies or organizations when it is carried out for the fulfillment of purposes directly related to the legitimate functions and corporate purpose of LICENCIAS ONLINE and the recipient. The transfer will be made provided that it is configured within one of the legitimacy grounds established in Applicable Law.

LICENCIAS ONLINE, in accordance with Applicable Law, may transfer partially or totally the personal data of Data Subjects, including third parties related to its customers, to third parties abroad such as: i) Manufacturers of offered products or services; ii) Members, related companies, or subsidiaries of LICENCIAS ONLINE; iii) Third-party providers of data processing and storage services.