At RICARDO ESCOBAR ARBELAEZ S.A.S. (hereinafter “INGELAM“), we value transparency and respect for our users’ privacy. Therefore, through this Cookie Policy, we provide clear and accessible information about the use of cookies on our website.

OBJECTIVE AND SCOPE OF THE COOKIE POLICY

INGELAM, on its website and using new information technologies, may use its own or third-party cookies, thereby processing the personal data of those who access its website. For this reason, this policy aims to disclose the information and criteria regarding the processing of personal data collected through the implementation of cookies, either directly or through third parties contracted for this purpose.

DEFINITIONS

• Cookie: A file that is downloaded to the user’s computer when accessing certain websites and allows the website, among other things, to store and retrieve information about the user’s browsing habits or their equipment; and, depending on the information they contain and the information used by the equipment, they can be used to recognize the user.

• Authorization: Prior, express, and informed consent of the Data Subject to carry out the processing of personal data.

• Database: An organized set of personal data that is subject to processing.

• Personal data: Any information linked or that can be associated with one or more determined or determinable natural persons.

• Data Subject: Natural person whose personal data is subject to processing.

• Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.

Data Controller for data collected through cookies.

PROCESSING AND PURPOSES

Given that cookies are small information files that are downloaded to the user’s computer when accessing the INGELAM website to store and retrieve information about the browsing conducted from that equipment, they will be used by the company as follows:

1. So that the website remembers information about the user’s visit, thereby improving and making the user’s browsing experience safer, considering the following:

   • Cookies can remember other types of personal information, such as preferences regarding website settings (language, screen resolution, etc.), so that it is not necessary to configure them again.

   • Cookies are essential for the functioning of the internet, providing advantages in the delivery of interactive services, facilitating navigation and usability of the web.

   • Cookies cannot damage your equipment, and having them activated helps identify and resolve errors.

   • Cookies are not a virus or any other type of malicious program that can harm users’ devices, nor do they delete or read information from their computer or device.

2. Cookies are created or updated on the user’s computer or device automatically when they access the INGELAM website, which allows the latter or the third parties it contracts to track the user’s cookies, and therefore the information they contain or obtain from the user, for the following purposes:

   • Detect preferences, commercial or market needs.

   • Offer the services provided by the Data Controller.

   • Loyalty and management of detected needs or interests.

   • Sending information related to services, promotions, alliances, campaigns, new website content, opening of new services, and other matters related to the company’s corporate purpose that may be of interest, in accordance with the tracking of information collected through cookies; the above, addressed to the contact details provided through our website.

3. Cookies are only read by the website that created them.

4. INGELAM may share information obtained through cookies with external parties or third parties (allies, clients, suppliers, or affiliated companies) to improve user services.

COOKIES USED BY INGELAM

As is common practice on most websites, different types of cookies are used to enhance the experience with content and digital services. These cookies are divided into the following categories:

• Functional Cookies: These cookies make interaction with the website more efficient and personalized. For example, by remembering your language preferences or the region you are in.

• Performance Cookies: These cookies are used to collect aggregated data about the use of the website and applications. This helps to continuously improve services and better understand how users interact with the content.

• Marketing Cookies: These cookies are used to display relevant content based on users’ interests and behavior during browsing.

COOKIE AUTHORIZATION

By clicking the checkbox that appears in the cookie pop-up modal when entering the website, you grant your consent for the use of the categories of cookies employed by the company and declare that you have read and understood the Privacy Policy.

DEACTIVATING COOKIES

All internet browsers allow limiting the behavior of a cookie or deactivating cookies within the browser’s settings or options. The steps to do this are different for each browser, and instructions can be found in your browser’s help menu.

RIGHTS OF DATA SUBJECTS

In accordance with the provisions of Law 1581 of 2012, holders of personal data have the following rights:

• To know, update, and rectify their information regarding partial, inaccurate, incomplete, fragmented, misleading data, or those whose processing is prohibited or has not been authorized.

• To request proof of the granted authorization when required.

• To file complaints with the Superintendency of Industry and Commerce (SIC) for violations of current regulations.

• To revoke authorization and/or request the deletion of data, provided there is no legal or contractual duty that prevents their elimination.

• To be informed about the use that has been made of their personal data, upon request.

• Responses regarding sensitive data or data of children and adolescents will be optional.

• To access, free of charge, the provided data that has been processed.

These rights can be exercised through the following channels:

EFFECTIVE DATE

This Cookie Usage Policy enters into effect as of [_______________].

INGELAM may modify this document at any time to keep it current and updated. Therefore, users are advised to check the creation or update date of this document.