Personal Data Processing Policy

360 Software

1. Purpose

To establish the guidelines governing the collection, storage, use, circulation and deletion of the personal data of candidates, customers, users and other data subjects who interact with 360 Software, in compliance with Ley 1581 de 2012, Decreto 1377 de 2013 and other applicable regulations in Colombia.

2. Data Controller

Legal name: 360 Software

NIT (Tax ID): 901613244-1

Email: mercadeo@360software.com.co

Phone: (+57) 302 3452800

3. Personal Data Processed

Depending on the purpose, 360 Software may collect and process the following types of data:

a) For recruitment processes

  • Identification data (full name, ID number, date of birth, nationality).
  • Contact data (address, phone number, email).
  • Education and work experience.
  • Personal and professional references.
  • Results of interviews and technical or psychometric tests.
  • Information strictly necessary for recruitment processes, with the prior express authorization of the data subject and in accordance with applicable law.

b) For commercial, technical support and marketing purposes

  • Basic data such as first name, last name, email, phone number, job title, company, city and commercial preferences.
  • Information collected through web forms, chat, surveys, events, cookies and the use of applications.
  • Browsing and behavioral information on platforms, gathered through analytics and digital marketing tools.

4. Purposes of Processing

Data will be processed for the following purposes:

a) Recruitment processes

  • Assess the candidate's suitability for a specific position.
  • Verify the information provided in the resume.
  • Conduct tests and interviews related to the process.
  • Contact the candidate and keep their information for future openings, if the data subject so authorizes.
  • Comply with legal and contractual obligations.

b) Commercial, support and marketing activities

  • Manage the relationship and maintain commercial contact.
  • Provide technical support and improve our services.
  • Send promotions, educational content and commercial communications.
  • Personalize the user experience.
  • Carry out statistical analyses and market research.
  • Share information with strategic partners and technology providers under confidentiality agreements.

5. Data Retention

360 Software will retain personal data only for as long as necessary to fulfill the purposes described in this policy, meet legal, contractual or commercial obligations, and while there is an active relationship with the data subject. Once the purpose of the processing has been fulfilled, the data may be securely deleted or anonymized.

6. Authorization of the Data Subject

The collection and processing of personal data will require the prior, free, express and informed authorization of the data subject, which may be granted through physical or electronic means, or through unequivocal conduct that allows it to be verified later.

7. Rights of the Data Subject

The data subject may:

  • Access, update and correct their personal data.
  • Request proof of the authorization granted.
  • Be informed about how their data is used.
  • Submit inquiries or complaints related to the processing of their data.
  • File complaints with the Superintendencia de Industria y Comercio (SIC).
  • Revoke the authorization or request the deletion of their data when no legal or contractual duty prevents it.

8. Security Measures

360 Software implements reasonable technical, human and administrative measures to ensure the confidentiality, integrity and availability of information, including access controls, secure storage and data protection tools managed by authorized technology providers.

9. International Data Transfers

The processing of personal data may involve transferring or storing information on servers located outside Colombia, including countries such as the United States or member states of the European Union, with adequate protection and confidentiality measures in accordance with applicable regulations.

10. Use of Cookies

360 Software uses cookies and similar technologies to improve the user experience, analyze browsing behavior, gather statistics and run digital marketing campaigns. Users may disable cookies in their browser settings.

11. Effective Date

This policy takes effect on May 21, 2026, and may be amended at any time. Updates will be published in a timely manner on the company's official channels.

12. Channels for Exercising Rights

Data subjects may submit requests, inquiries or complaints related to the processing of their personal data through the following channels:

Email: mercadeo@360software.com.co

Phone: (+57) 302 3452800

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