RoundCode

PRIVACY POLICY

June 2026

RoundCode, its collaborators, and associates are committed to complying with Article 15 of the Political Constitution of Colombia, which protects the fundamental right of individuals to privacy and good name, as well as the rights to know, update, and rectify information that has been collected about them in databases and files of public and private entities, together with the regulations that develop this constitutional principle.

In furtherance of this commitment, RoundCode has adopted this binding policy to establish mechanisms that guarantee the security and confidentiality of the personal data of its clients, collaborators, suppliers, associates, and third parties with whom it maintains a commercial or administrative relationship. RoundCode collects information and keeps it updated for the purpose of carrying out its corporate purpose, complying with accounting, administrative, and legal obligations, conducting commercial activities, promoting its services, and, in general, performing any activity aimed at fulfilling its corporate purpose.

Personnel responsible for collecting personal data undertake to maintain the confidentiality of all personal data collected by and for RoundCode. Failure to comply with this duty shall give rise to the corresponding administrative investigations and sanctions, as applicable.

RoundCode has designated personnel responsible for handling complaints and claims. Therefore, any third party who considers that their right to the confidentiality of their personal data has been affected may submit the corresponding complaint to the following email address: hola@roundcode.co.

RoundCode informs that the provision of personal data is voluntary and therefore requires prior authorization from the individual providing the information. Such data shall be used solely for the purposes described in this policy, in accordance with the constitutional principles that protect personal data privacy. Consequently, personal data shall be collected, processed, stored, and used in compliance with the constitutional principles of privacy, non-discrimination, legality, rectification, and correction. RoundCode shall keep a copy of the authorization, and the data subject may obtain a copy thereof.

The information collected by RoundCode shall at all times be accurate, complete, truthful, up to date, verifiable, and understandable. RoundCode shall take the necessary measures to prevent any risk of error, alteration, or falsification of the information.

The data subject may, at any time, request that RoundCode update their personal data and inform them of the personal information collected, as well as the processing carried out on such information.

RoundCode only allows access to personal information to:

  • The data subject;
  • Persons authorized by the data subject;
  • Judicial or supervisory authorities of the Republic of Colombia that duly demonstrate the need for access to such information;
  • Personnel designated by RoundCode for the collection, storage, and processing of personal data.

Data subjects have the right to:

  • Know, update, and rectify their personal data free of charge;
  • Provide prior authorization for the collection of their personal data and obtain a copy thereof;
  • Revoke such authorization.

Data subjects may request information related to their personal data by sending an email to hola@roundcode.co, including their full name, identification number, contact information for response (email address, physical address, telephone number), and a detailed description of their request.

If the data subject acts through a representative, an original power of attorney with personal presentation before a notary public must be submitted to the following address: Carrera 10 # 93 – 51, Bogotá, Colombia.

RoundCode shall process the request within ten (10) days from the date of receipt and shall provide a response no later than the tenth (10th) day following receipt of the request. Corrective measures, if applicable, shall be implemented within five (5) days following the response or earlier if possible. If additional information is required to process the request, RoundCode shall contact the data subject or their representative immediately. If the requested information is not provided within two (2) months, the request shall be deemed concluded.

RoundCode shall keep a sequential record of all requests submitted by data subjects or their representatives, including full name, date of request, reason for the request, dates of requests for additional information, date of response, and any other relevant information.

RoundCode declares that it does not collect or store personal data of minors.