Privacy Policy.

1. Scope and applicable framework

This Privacy Policy applies to personal information collected through haspglobal.com and its forms. HASP Global S.A.S. processes personal data in accordance with Colombia’s Law 1581 of 2012, the applicable provisions compiled in Decree 1074 of 2015, and other applicable data protection rules.

2. Information we collect

Depending on how you use the website, we may collect:

• Identification and contact information, including name and email address.
• Professional information, including company, fund, role, country and investor type.
• The contents of messages, partnership inquiries and Data Room access requests.
• Technical information generated when the website is accessed, such as IP address, browser type, device information, timestamps, referring pages and server logs.
• Cookie and analytics information when those technologies are enabled and permitted.

We do not intentionally request sensitive personal data through the website. Please do not include confidential, sensitive or unnecessary personal information in free-text fields.

3. Purposes of processing

We may process personal information to:

• Respond to commercial, partnership, media, career and general inquiries.
• Assess and manage requests for access to investor materials or the Data Room.
• Communicate with prospective operators, investors, suppliers and strategic partners.
• Operate, secure, maintain and improve the website and its forms.
• Detect abuse, fraud, malicious activity and technical failures.
• Maintain records necessary to demonstrate consent, manage requests and comply with legal obligations.
• Send business communications when permitted by law or when the data subject has authorized them. Recipients may withdraw that authorization at any time.

4. Authorization and consent

When required, HASP Global S.A.S. obtains prior, express and informed authorization before processing personal data. The acceptance box displayed in our forms records the user’s authorization for the purposes stated next to the form and in this policy. Refusing optional processing does not prevent access to public areas of the website, although information required to answer a request must be provided.

5. Service providers and international processing

HASP Global S.A.S. may engage hosting, website administration, cybersecurity, email delivery, form protection, analytics and professional service providers. These providers may process information only to deliver their services and under appropriate confidentiality and security obligations.

Some providers may operate infrastructure outside Colombia. Where personal information is transmitted or transferred internationally, HASP Global S.A.S. will apply the requirements and safeguards established by applicable Colombian law.

6. Cookies and technical technologies

The website may use essential cookies required for security, session management, form operation and basic functionality. Analytics or third-party cookies will only be used when enabled and subject to the applicable consent requirements. Browser settings may be used to block or delete cookies, although doing so may affect certain website functions.

7. Retention

Personal information is retained only for as long as reasonably necessary to respond to the request, maintain the relevant business relationship, protect the website, demonstrate authorization, resolve disputes and comply with legal or contractual obligations. Information will then be deleted, anonymized or securely archived as applicable.

8. Security

HASP Global S.A.S. applies reasonable administrative, technical and organizational safeguards intended to protect personal information against unauthorized access, loss, alteration, disclosure or misuse. No internet transmission or storage system can be guaranteed to be completely secure.

9. Rights of data subjects

Subject to applicable law, data subjects may:

• Know, access, update and rectify their personal information.
• Request information about the use made of their personal data.
• Request proof of the authorization granted, when applicable.
• Revoke authorization or request deletion when legally appropriate.
• Submit complaints to Colombia’s Superintendence of Industry and Commerce after completing the direct consultation or complaint procedure with HASP Global S.A.S.

10. Requests, consultations and complaints

Requests concerning personal data must be sent to sergio@haspglobal.com with the subject line Personal Data Request. The request should identify the data subject, describe the request clearly, provide contact information and include any document needed to verify identity or representation.

HASP Global S.A.S. will process consultations and complaints within the periods and under the procedures established by applicable Colombian law. If additional information is required to process a request, we will contact the requester through the information provided.

11. Children and adolescents

This website is intended for business and professional audiences and is not directed to children. HASP Global S.A.S. does not knowingly collect personal information from children through these forms. If such information is identified, it will be handled in accordance with the heightened protections required by law.

12. Third-party websites

The website may link to external publications, social networks and third-party websites. HASP Global S.A.S. does not control their privacy practices. Users should review the policies of those services before providing personal information.

13. Changes to this policy

This policy may be updated to reflect changes in the website, company operations or applicable law. The effective date displayed at the top will be updated when material changes are published.

14. Contact

HASP Global S.A.S.
Email: sergio@haspglobal.com
Website: haspglobal.com