PRIVACY POLICY

The purpose of this policy is to inform clients, suppliers and workers about the processing of personal data that CONSORCIO NOBIS S.A.S, HONEY FRUIT EXPORTADORA HONEYFRUITS S.A.S., GRANRIO SOCIEDAD ANÓNIMA CIVIL, CENTRO DE NEGOCIOS EJECUTIVOS ICONCLUB S.A., BEAUPORT S.A., VINDELCORP S.A., NOBIS FRUIT COMPANY NOBISFRUIT S.A.S., HACIENDA SAN RAFAEL S.A. (H.S.R.), NOBIS FOUNDATION (hereinafter, “NOBIS HOLDINGS”) carries out in accordance with the Organic Law on Personal Data Protection (LOPDP), the Regulations and other applicable regulations.

Definition

For the purposes of this document, in accordance with the provisions of the applicable regulations, personal data will be considered to be any data that identifies or makes a natural person identifiable.

Scope

This Policy applies only to the NOBIS HOLDINGS companies mentioned. Those companies that are not listed have their own Privacy Policy.

Content

This document refers to the following:

1. Identification of the person responsible;
2. Type of personal information we collect;
3. Purposes of treatment;
4. The legal basis for the processing of data;
5. Time for which the information is kept;
6. Information storage mechanisms;
7. Rights of the owners and means through which they can be exercised;
8. People with whom the information is shared;
9. Modifications to the Privacy Policy.

1. Identification data: name, surname, age, date of birth, identification number, contact information such as email and cell phone number.
2. Health data: medical history, clinical and surgical history, physical and mental illnesses, results of medical examinations, results of tests for alcohol and psychotropic substances
3. Data of people with disabilities: Data related to the disability, or of people for whom they are substitutes
4. Personal characteristics: marital status, family data, date of birth, place of birth, age, sex, nationality, mother tongue, physical or anthropometric characteristics.
5. Data on social circumstances: Family situation (family responsibilities)
6. Economic, financial and credit data: Data related to your remuneration (income and economic payroll data), bank account number, type of bank account, bank entity, credit bureau information
7. Academic and professional data: Educational and professional training, professional experience

1. Responsible for the treatment

NOBIS HOLDINGS, with address in the Executive Center Building, on Av. Joaquin Orrantia and Av. Juan Tanca Marengo, in the city of Guayaquil, with contact email [email protected], and telephone number (593-4) 3751 000 as Responsible for processing the personal data of its clients, suppliers, collaborators and applicants.

As indicated by law, NOBIS HOLDINGS, in its capacity as Data Controller, guarantees that it has applied the necessary technical, legal, organizational and administrative measures to protect personal data.

The processing activities carried out by NOBIS HOLDINGS are currently not based on automated decisions. If the above changes, the Owner will be informed accordingly.

2. Type of personal information we collect

NOBIS HOLDINGS collects personal information in order to always offer a better service.

On each of our platforms we handle information in accordance with the provisions of this Privacy Policy.

The personal data subject to processing are all those that you have provided and are contained in the documents that you provide us at the beginning of the commercial, employment, civil relationship or any other information considered personal data that has been made available and/or brought to the attention of the NOBIS HOLDINGS companies, as well as data collected from publicly accessible sources and third parties.

Among the personal data that NOBIS HOLDINGS collects is the following:

1. Biometric data: Fingerprints, facial recognition
2. Other information from public or publicly verifiable sources

3. Purposes of treatment

By virtue of our company’s line of business, we will process personal data in accordance with the following purposes:

Customers

• Contact with potential clients;
• Updating customer data;
• Respond to requests for information about the products and services offered by NOBIS HOLDINGS;
• Conclusion of contracts;
• Subscription of agreements, policies and protocols;
• Management of the commercial relationship and activities related to the execution of projects linked to community development;
• Carry out due diligence and review processes for the Financial and Economic Analysis Unit and verify information in publicly accessible sources.
• Data transfer between related companies, subsidiaries and/or affiliates
• Analysis of capacity and/or credit history for acquiring the products offered by NOBIS HOLDINGS
• Manage complaints from Clients.
• Contact the client to carry out satisfaction surveys for the products and services offered by NOBIS HOLDINGS.
• Send you commercial communications about products that may be of interest to the Client, in which you can always choose to stop receiving these automatic notifications through simple procedures to unsubscribe.

Suppliers

• Supplier selection and qualification management;
• Conclusion of contracts;
• Management of the commercial relationship with NOBIS HOLDINGS;
• Conclusion of agreements, policies and protocols;
• Execution of audits by NOBIS HOLDINGS and/or third parties;
• Carry out due diligence and review processes for the Financial and Economic Analysis
• Unit and verify information in publicly accessible sources.
• Data transfer between related companies

Applicants

• Recruitment and/or selection processes of new collaborators;
• Hiring of personnel;
• Storage of information for future selection processes;
• Carry out due diligence processes and verification of information in publicly accessible sources;
• Medical examinations for medical work aptitude;
• Reliability tests and psychometric evaluations.

Collaborators

• Subscription of employment contracts;
• Access to employee social benefits;
• Comply with the legal and contractual obligations arising from the employment relationship;
• Registration of entry and exit from the workplace through biometric recognition systems (fingerprints and/or facial recognition)
• Conclusion of agreements, policies and protocols;
• Updating personal data;
• Reliability tests and psychometric evaluations;
• Management of obligations derived from the employment relationship;
• Conduct annual occupational examinations;
• Carry out due diligence processes and verification of information in publicly accessible sources.

The information collected through our video surveillance systems will be used to preserve the security of establishments, personal property and infrastructure through formal control of physical access to NOBIS HOLDINGS facilities for suppliers, customers, workers and other visitors.

4. Basis of legitimacy for the processing of personal data

The bases of legitimacy for the processing of the information obtained by the companies that make up NOBIS HOLDINGS are:

1. Express consent of the OWNER, provided voluntarily in accordance with the Law in applicable cases;
2. Legal mandate, based on the regulations that regulate the business of NOBIS
3. HOLDINGS, or any legal rule that requires the respective treatment to be carried out;
4. Compliance with the contractual obligations contracted with the OWNER;
5. Legitimate interest of the OWNER, NOBIS HOLDINGS or a third party.
6. Data obtained from publicly accessible sources
7. In cases where applicable, Vital interest of the interested party.

Consent will not be required when it comes to information that comes from public sources; whether information required by a public or administrative entity in the exercise of its legal functions or by court order; in cases of medical or health emergency, or when the treatment is required by law.

In accordance with the Organic Law on Data Protection, the owner’s financial and credit data will be processed only for the purpose of analysis with prior authorization from the owner, and will not be communicated or disseminated to unauthorized third parties, nor may they have any secondary purpose.

Personal information allows NOBIS HOLDINGS to carry out the necessary processes to provide the service offered.

Conservation time

The data will be collected for the time strictly necessary to fulfill the corresponding purpose, as well as for the period established in the Law or regulations applicable to NOBIS HOLDINGS. After that time, this information may be kept duly anonymized or pseudonymized, for statistical and internal analysis purposes.

Information storage

The data collected by NOBIS HOLDINGS will be kept in any of the banks or databases, which have the physical, administrative, technological, legal and organizational measures required by law.

Owners’ rights

The Owners have the rights that assist them according to the Organic Law on Protection of Personal Data, its Regulations and other applicable regulations, which are defined below:

• Access The Owner may request NOBIS HOLDINGS to access all personal data and information on its treatment without justification, and as long as this request is reasonable and does not constitute an abuse of rights.

• Rectification and update

The owner has the right to obtain from NOBIS HOLDINGS the rectification and updating of his or her inaccurate or incomplete personal data.

It is the Owner’s obligation that the information provided is true and accurate. NOBIS HOLDINGS can carry out reviews and comparisons of the information provided with public information or information available on pages of state authorities and publicly accessible.

• Elimination

The Owner has the right to have NOBIS HOLDINGS delete his/her personal data when there is no longer a reason for its processing, when the commercial relationship has ended or in the event that its conservation is no longer necessary with respect to the purpose for which it was processed. initially collected.

As a limitation to the above, the LOPDP establishes that NOBIS HOLDINGS may retain the Owner’s information in the event that an authority requires it in the context of investigations, public interest or if there is a legal obligation to maintain it for longer than the period established above.

• Opposition

The Owner has the right to oppose or refuse the use of their personal data if they verify that they are being processed for purposes other than those for which they were collected or if they are not necessary to maintain the commercial relationship.

• Portability

The Owner has the right to receive their personal data in a compatible, updated, structured, common, inter-operable and machine-readable format by the company.

The owner, through the right of portability, can request that his or her data be transmitted to other controllers (other companies).

• Treatment suspension
• The Owner disputes the accuracy of his or her personal data;
• The treatment that NOBIS HOLDINGS carries out is illicit;
• If NOBIS HOLDINGS no longer needs to process the personal data for the purposes of the processing, but the Owner needs it for the formulation, exercise or defense of claims; and
• If the Owner objects to the processing of their health-related data, while NOBIS HOLDINGS verifies whether the legitimate reasons for the processing prevail over those of the owner.

The Owner has the right to obtain from NOBIS HOLDINGS the suspension of data processing when:

Regarding the exercise of rights or claims

To exercise your rights set forth in this policy in accordance with the provisions of the LOPDP, you can send a request to exercise or claim about the processing of your personal data by email:

NOBIS HOLDINGS company to which the request is addressed

Consorcio Nobis S.A.S
Granrio Sociedad Anónima Civil
Centro De Negocios Ejecutivos Iconclub S.A.
Beauport S.A.
Vindelcorp S.A.
Email: [email protected]

Honey Fruit Exportadora Honeyfruits S.A.S.
Nobis Fruit Company Nobisfruit S.A.S.
Hacienda San Rafael S.A.
Fundación Nobis
Email: [email protected]

Transfer of Personal Data

NOBIS HOLDINGS may share personal data with certain data processors, who act as suppliers to the Controller.

NOBIS HOLDINGS undertakes to verify that those in charge of the treatment comply with the legal, technological and administrative measures necessary to carry out the entrusted treatment, as well as to sign the confidentiality, assignment and other necessary documents, to adequately protect the information.

If required, NOBIS HOLDINGS may request the owner’s consent to transfer their data. Said request will contain the specific purposes for which it is required to share personal information.

The companies that make up NOBIS HOLDINGS may also share information nationally and internationally to subsidiaries, affiliates, affiliates, controlled or controlling companies to fulfill solely the purposes described.

It will be guaranteed that the international transfer of personal data is supported by a legal instrument that contemplates the standards determined above, as well as those established by the Personal Data Protection Authority.

Changes to the Data Protection Policy

Updates to this document will be notified through the NOBIS HOLDINGS website or through the digital channels of said company. Through these, the holders of the personal data under the responsibility of NOBIS HOLDINGS will be informed of any eventuality that may affect the processing of personal data, without implying a detriment to their rights.

Last update: July 4, 2024