By means of this document, LANDING PARTNERS S.A.S., in compliance with the provisions of Law 1581 of 2012 and Decree 1377 of 2013, establishes its Personal Data Processing Policy (hereinafter the “Policy”), which defines the criteria for the collection, storage, use, circulation, and deletion of personal data. This is intended to guarantee the constitutional right of individuals to know, update, and correct any personal information that LANDING PARTNERS S.A.S. has collected about them or received in the ordinary course of its corporate activities. For the purposes of this Personal Data Processing Policy, LANDING PARTNERS S.A.S. will be the Data Controller, responsible for its implementation.

1. IDENTIFICATION OF THE DATA CONTROLLER .

1.1 Data Controller Information
The entity responsible for the processing of personal data contained in its databases is LANDING PARTNERS S.A.S., identified with Tax ID No. 901551891, with its main office located in Envigado, Colombia. The contact details of the data controller are:

Website: www.landingpartners.co
Email: andres.rincon@landingpartners.co

1.2 Scope
LANDING PARTNERS ensures that all its employees and affiliates are aware of and comply with this policy. It will also carry out training, updates, and dissemination activities as necessary for its employees to comply with the policy.

2. PROCESSING AND PURPOSE OF PERSONAL DATA
2.1 Data Collection

LANDING PARTNERS collects users’ personal data during interactions on its website www.landingpartners.co or during various events or activities it conducts. This information may be collected through electronic or physical means, such as forms or surveys, and may include, but is not limited to: names, phone numbers, identification numbers, emails, city of residence, interests, and other relevant contact data necessary for the website’s functioning.

2.2 Processing

The information contained in the LANDING PARTNERS databases will be subject to various forms of processing, including collection, sharing, updating, processing, reproduction, compilation, storage, use, systematization, and organization, in whole or in part.

LANDING will always process data in strict compliance with the purposes authorized by the Data Subject. In the event that Sensitive Data is collected, it will be processed strictly for the purposes authorized by the Data Subject, who will have the right to decide whether or not to provide the information considered sensitive. Furthermore, the collection of Sensitive Data will be carried out in compliance with the relevant provisions of Law 1581 of 2012 and Decree 1377 of 2013.

2.3 Purpose

LANDING PARTNERS will collect personal data to store, use, and circulate it for the following purposes:

1. Store the information in its database.
2. Perform administrative tasks and manage requests (inquiries, complaints, claims).
3. Invite users to events and offer new products and services.
4. Conduct data analysis for the sale of subscriptions and premium content targeted to users.
5. Create audience and website traffic profiles, including information on website browsing hours, sites visited, time spent on the website, and other relevant information to improve the service.
6. Producing opinion, market, or consumer analyses based on collected data
7. Conducting satisfaction surveys regarding content offered by LANDING PARTNERS
8. Sharing contact information with the sales force or distribution network, marketing by any means, market research, and any third parties with contractual relationships for such activities
9. Contacting the Data Subject via electronic means (SMS, chat, email) to send general content, loyalty campaigns, or service enhancements
10. Utilizing information for commercial purposes including—but not limited to—advertising, marketing campaigns, and presenting relevant products or services
11. Contacting the Data Subject through electronic media (identical to item 9) for general content and loyalty campaigns
12. Transmitting personal data abroad to third parties with whom LANDING PARTNERS has a data processing agreement, when necessary to fulfill contractual objectives
13. Licensing LANDING PARTNERS’ databases

3. PRINCIPLES

3.1 Principles of Personal Data Handling.

LANDING PARTNERS will process personal data in strict adherence to the laws of the Republic of Colombia, especially Law 1581 of 2012, Decree 1377 of 2013, and any amendments or additions thereto. The processing will be governed by the following principles:

14. Purpose: Data processing will serve a legitimate legal purpose, which will be promptly communicated to the Data Subject
15. Freedom: Processing requires the Data Subject’s prior, informed, and explicit consent; no personal data may be collected or disclosed without authorization or legal mandate
16. Truthfulness: Information must be accurate, complete, up-to-date, verifiable, and understandable as provided by the Data Subject
17. Transparency: The Data Subject has the right to know, at any time and freely, whether their data is being processed and how
18. Restricted Access and Circulation: Data processing will comply with legal limits; personal data will not be publicly accessible unless access is technologically restricted to Data Subjects or authorized third parties
19. Security: Data must be managed with necessary technical, human, and administrative measures to ensure protection against unauthorized access, loss, alteration, or fraud
20. Confidentiality: All individuals participating in data processing must maintain confidentiality even after termination of their involvement

4. AUTHORIZATION FOR PERSONAL DATA PROCESSING
4.1 Authorization

Without prejudice to the exceptions established in Law 1581 of 2012, LANDING PARTNERS will always require the Data Subject's prior and informed authorization for the processing of their Personal Data in accordance with the purposes established in this Policy. Data Subject authorization may be obtained or granted by any means and may always be subsequently consulted by the Data Subject. Data Subject authorization will not be required in the following cases:

21. Information is requested by public or administrative entities within their legal mandate or by court order
22. Data is publicly available
23. There is a medical or health emergency
24. Data is processed for historical, statistical, or scientific purposes authorized by law
25. Data relates to the Civil Registry of Persons

4.2 Proof of Authorization

LANDING PARTNERS will implement technological or mechanical means to record authorizations from Data Subjects, including the date and manner in which authorization was obtained.

4.3 Revocation of Authorization

Data Subjects may request deletion of their personal data or revoke their authorization at any time through a formal complaint, as outlined in this Policy. Deletion or revocation will not be permitted if the Data Subject has a legal or contractual obligation to remain in LANDING PARTNERS’ databases.

5. RIGHTS AND DUTIES

5.1 Data Subject Rights

The Data Subject has the right to:
26. Access, update, and correct personal data stored by LANDING PARTNERS
27. Request proof of the personal data processing authorization granted
28. Be informed by LANDING PARTNERS or the data processor, upon request, about how their data has been used
29. File complaints with the Superintendence of Industry and Commerce (SIC) for violations of data protection laws
30. Revoke authorization and/or request data deletion when the processing does not respect constitutional and legal principles, rights, and guarantees. Revocation and/or deletion will be appropriate when the Superintendency of Industry and Commerce has determined that, in the processing of data, LANDING PARTNERS has engaged in conduct contrary to this law and the Constitution;
31. Access their processed data free of charge
32. Decline to answer questions about sensitive data or data concerning minors

5.2 LEGITIMATE REPRESENTATION

These rights may be exercised by:

33. The Data Subject, upon proof of identity (e.g., national ID)
34. Their legal successors, with appropriate documentation
35. Their representative or legal agent, with valid power of attorney

5.3 DUTIES OF LANDING PARTNERS

As Data Controller under Article 17 of Law 1581 of 2012, LANDING PARTNERS commits to:
36. Guaranteeing the effective exercise of habeas data rights at all times
37. Storing authorization records in accordance with the law
38.Properly informing Data Subjects about collection purposes and their rights
39. Protecting data with adequate security measures
40. Ensuring that data transferred to processors is accurate and comprehensible
41. Updating data promptly and ensuring processors maintain current information
42. Correcting inaccurate data at the Data Subject’s request
43. Providing processors only with authorized data
44. Ensuring processors comply with data confidentiality and security requirements

45. Handling inquiries and complaints as required by Law 1581 of 2012
46. Informing processors when data is under legal dispute
47. Reporting to processors the authorized use/treatment of data, upon request
48. Inform the data protection authority when security code violations occur and there are risks in the management of the Data Subjects' information.
49. Complying with directives from the Superintendence of Industry and Commerce

5.4 DUTIES OF DATA PROCESSORS

According to Article 18 of Law 1581 of 2012, LANDING PARTNERS or designated processors must:
50. Ensure Data Subjects’ rights of habeas data are protected at all times
51. Maintain data security to prevent unauthorized access or alteration
52. Correct, update, or delete data in accordance with the law
53. Process inquiries and complaints promptly
54. Flag data as “under judicial dispute” when notified by authorities
55. Refrain from disseminating data that is legally contested
56. Allow access to information only to persons who may have access to it in accordance with Law 1581 of 2012.
57. Comply with mandates issued by the Superintendence of Industry and Commerce

6. INQUIRIES, COMPLAINTS, AND CLAIMS
6.1 CHANNELS FOR PETITIONS, INQUIRIES, AND COMPLAINTS

The Holder of Personal Data may exercise the rights established in section 8.1 of this Policy and others contained in the law and the Constitution through the channels or means provided by LANDING PARTNERS for public attention, the email andres.rincon@landingpartners.co, whose information can be consulted www.landingpartners.co, available from Monday to Friday from 8:00 a.m. a.m. to 6:00 p.m., to address requests, queries and complaints related to the processing of Personal Data. You may also use the "Contact Us" section on the www.landingpartners.co website.

6.2 PROCEDURE FOR EXERCISING THE RIGHT TO HABEAS DATA The Owner of Personal Data whose information is stored in the LANDING PARTNERS databases, or their successors in title, may submit petitions, complaints and claims, exercising the rights provided for in section 8.1 of this document, with respect to the data they have provided in the terms established by applicable law. Any request for consultation, correction, update or deletion must be submitted in writing or by email, and must contain the following information:
58. Full name and surname
59. Contact information (physical and/or electronic address, phone)
60. Preferred method for receiving a response
61. Description of the request and right exercised (e.g., access, update, revoke, delete, etc.)
62. Signature (if applicable) and identification number; Inquiries will be answered by LANDING PARTNERS within a period of no more than fifteen (15) business days from the date of receipt of the respective request. When it is not possible to answer the inquiry within this period, the interested party will be informed, stating the reasons for the delay and indicating the date on which their inquiry will be answered, which in no case may exceed eight (8) business days following the expiration of the first term. LANDING PARTNERS may send the response to the inquiry or claim to the Owner of the information via email or certified mail. Once the terms established by Law 1581 of 2012 and other regulations or supplements thereof have been met, the Data Subject who is denied, in whole or in part, the exercise of the rights of access, update, rectification, deletion, and revocation may bring his or her case to the attention of the Office for the Protection of Personal Data of the Superintendency of Industry and Commerce.
The Holder or the persons entitled to exercise their rights must complete the consultation process with LANDING PARTNERS as a prerequisite to filing any complaint with the Superintendence of Industry and Commerce,

7. MISCELLANEOUS PROVISIONS
7.1 PUBLICATION OF THE POLICY

These policies will be available to the public through the following website: www.landingpartners.co

7.2 POLICY MODIFICATIONS

These policies may be modified by LANDING PARTNERS with prior notice to the Personal Information Holders. Such modifications will be published on the aforementioned website. LANDING PARTNERS will notify Holders of any modifications made to this Processing Policy at least five (5) business days prior to the entry into force of the modified policy. In the event that the Holder does not agree with the modifications made to this Processing Policy, he or she will have the right to request the deletion of his or her Personal Data in accordance with the procedure described in section 7.2.

8. EFFECTIVE DATE

This Personal Data Processing Policy becomes effective on August 1, 2025, and remains effective as long as the data is utilized for the purposes outlined above. Once those purposes have been fulfilled—and provided there is no legal or contractual obligation to retain the data—it will be deleted from LANDING PARTNERS’ databases.