Code: AP-TIC-PO-01 | Version: 01 | Approved: December 5, 2025
I. Object
TRIAXIAL CREATIVE SOLUTIONS SAS., identified with NIT 900.207.715-2, in compliance with the Political Constitution of Colombia, the Law 1581 of 2012, he Decree 1377 of 2013 and other applicable provisions regarding the protection of personal data, adopts this Personal Data Processing Policy.
Its purpose is to establish the guidelines, principles and procedures that govern the processing of personal data collected, stored, used, circulated or deleted in the development of its activities, guaranteeing full respect for the rights of the data subjects, preserving the confidentiality, security, integrity and proper management of the information.
TRIAXIAL SOLUCIONES CREATIVAS SAS is a company dedicated, among other activities, to the organization of conventions and commercial events; to the design, production, assembly and rental of elements for fairs, stands and special events; to the manufacture and marketing of furniture for commercial spaces; to graphic, industrial and decorative design; and to the provision of comprehensive logistics services for events and fairs.
II. Purpose of the treatment
TRIAXIAL SOLUCIONES CREATIVAS SAS will process the personal data collected for the following purposes:
- Manage, execute and document activities related to the organization of events, fairs, conventions and commercial setups; design, production and rental of stands; furniture manufacturing; and provision of logistics services.
- Manage relationships with clients and suppliers: quotes, orders, production orders, invoicing, product delivery, project tracking, handling complaints, and technical or commercial support.
- Carry out marketing activities, advertising, market research, satisfaction surveys and commercial campaigns.
- Sharing data with business partners, suppliers and logistics operators for design, production, transportation, assembly, statistical analysis and other necessary operations.
- Update, verify, and authenticate the information of people who are related to the company.
- Verify compliance with contractual, commercial, labor and legal obligations.
- Manage labor processes: personnel selection, affiliations, payroll, social security, audits and certifications.
- Evaluate, select, and monitor suppliers, contractors, logistics operators, and creative partners.
- Request and provide commercial and financial references.
- Implement due diligence measures, fraud prevention, and verification against restricted lists.
- Comply with accounting, tax, labor, commercial and personal data protection obligations.
III. Definitions
- Privacy notice: Communication addressed to the data subject informing them about the processing of their personal data, the purposes thereof and how to access the applicable policy.
- Authorization: Prior, express and informed consent of the data subject for the processing of their personal data.
- Database: Organized set of personal data subject to processing.
- Personal data: Any information linked or associated with one or more specific or identifiable natural persons.
- Sensitive data: Data that affects the privacy of the data subject or whose misuse may generate discrimination (ethnic origin, political orientation, religious beliefs, union membership, health data, sexual life, biometric data, among others).
- Person in charge of treatment: Natural or legal person who processes data on behalf of the controller.
- Data controller: Natural or legal person who decides on the database and the processing of the data.
- Holder: Natural person whose personal data is being processed.
- Treatment: Any operation involving personal data: collection, storage, use, circulation or deletion.
- Data Protection Officer: Person responsible for monitoring and controlling the application of this policy within the company.
IV. Classification of databases
- Employee databases: Data of individuals with an employment relationship. This includes private, public, and sensitive information. Processing for purposes other than the employment relationship requires prior authorization from the data subject.
- Databases of contractors and suppliers: Data of individuals with a contractual or commercial relationship. Processing aimed at fulfilling the stipulated contractual provisions.
- Customer databases: Information from affiliated or non-affiliated, national or international, occasional or permanent customers who require products or services from the company.
- Third-party databases: Information provided by external clients. It is presumed that the processing has been authorized to the client by the data subject.
- Inactive file databases: Historical information is stored for as long as necessary to fulfill the purpose of collection or current legal obligations. Once this period has expired, the data will be securely deleted or anonymized.
V. Duty of secrecy and confidentiality
TRIAXIAL SOLUCIONES CREATIVAS SAS guarantees and requires all individuals involved in the processing of private and sensitive data to maintain professional secrecy and the duty to safeguard such data. These obligations remain in effect even after the termination of the contractual relationship with the company. Failure to comply will be sanctioned in accordance with the company's internal work regulations and applicable legislation.
VI. Authorization for treatment
TRIAXIAL SOLUCIONES CREATIVAS SAS will request prior authorization from the data subject for the processing of their personal data, always informing them:
- The processing to which your data will be subjected and the specific purpose thereof.
- The rights you have as the owner.
- The communication channels —email, telephone, physical address— for inquiries and complaints.
VII. Types of data collected
- Employee information: Data obtained during selection, hiring, affiliations, social security, performance, welfare and termination of the employment relationship.
- Information on suppliers, contractors, and business partners: Data for evaluation, linking, contract execution, monitoring and payments.
- Customer information: Data for quotes, orders, invoicing, product delivery, portfolio management and commercial communications.
- Photographic and audiovisual records: Obtained exclusively within the framework of corporate, commercial, or internal promotional activities. Dissemination for advertising purposes requires prior, express, and informed authorization from the owner.
VIII. Cases in which authorization is not required
Authorization from the holder will not be required when it comes to:
- Information required by a public or administrative entity in the exercise of its legal functions or by court order.
- Data of a public nature.
- Cases of medical or health emergencies.
- Processing of information authorized by law for historical, statistical or scientific purposes.
- Data related to the Civil Registry of Persons.
IX. Rights of the holders
Data subjects have the following rights against TRIAXIAL SOLUCIONES CREATIVAS SAS:
- Right of access: To know, free of charge, the personal data processed, after verification of identity.
- Right to consultation: Request information about your data in any of the company's databases. Response time: 15 business days, extendable by an additional 5 business days.
- Right of rectification and updating: Request the correction of incomplete or inaccurate data.
- Right to erasure: You have the right to request the deletion of your data when it is no longer necessary, is not being processed in accordance with the law, or the processing period has expired. This right may be denied when there is a legal or contractual obligation to retain the data in the database.
- Right of withdrawal: To revoke the processing authorization at any time, in whole or in part, except where there is a legal or contractual impediment.
- Right to complain: File complaints with the company or, if the procedure has been exhausted, with the Superintendency of Industry and Commerce – Delegation for the Protection of Personal Data.
X. Procedure for exercising rights
To exercise any of the above rights, the holder must send a written communication to TRIAXIAL SOLUCIONES CREATIVAS SAS through one of the following channels:
- Email: anacarvajal@triaxial.com.co
- Physical address: Calle 44A No. 60-31, Medellín, Antioquia
- Phone: (604) 358 65 77
The request must include: date, photocopy of the holder's identity document, and physical or electronic contact address. The maximum response time is fifteen (15) business days. If it is not possible to respond within that period, the interested party will be informed before its expiration, indicating the reasons for the delay and the new response date, which may not exceed five (5) business days later.
XI. Data protection in contracts
Employment contracts include clauses authorizing the processing of employee data related to the performance of the employment relationship. In service contracts, third parties requiring personal data will act as data processors, with obligations of confidentiality, security, and integrity in accordance with Law 1581 of 2012 and Decree 1377 of 2013.
XII. International Data Transfer
In accordance with Article 26 of Law 1581 of 2012, the transfer of data to countries that do not provide an adequate level of protection is prohibited, except in the following cases: express and unequivocal authorization of the data subject; medical exchanges for reasons of public health; bank or stock market transfers; international treaties in force for Colombia; execution of contracts with the authorization of the data subject; or legal requirements of public interest.
XIII. Contact Information
For inquiries, complaints or to exercise rights related to this policy:
- Phone: (604) 358 65 77
- Email: anacarvajal@triaxial.com.co
- Address: Calle 44A No. 60-31, Barrio Triste, Medellín, Antioquia
XIV. Applicable regulations
- Political Constitution of Colombia, 1991
- Law 1266 of 2008
- Law 1581 of 2012
- Decree 1377 of 2013
- Decree 1074 of 2015
- Law 2080 of 2021
- Decree 255 of 2022
XV. Validity and updates
This policy is effective from December 11, 2025, under the signature of the Legal Representative, Gustavo Alberto Osorio Patiño. TRIAXIAL SOLUCIONES CREATIVAS SAS may modify its terms to comply with regulatory changes or changes in its operations, notifying its employees and collaborators in a timely manner.