1. PRESENTATION

As part of our commitment to fulfill the requirements set forth by law in relation to the protection of personal data we have set up the following privacy policy. In this Policy you will find the guidelines that govern our handling of your information, your rights and internal and external procedures which we must follow.

This pertains to the acquisition, use and transfer of personal data that CASA DEL COLISEO, henceforth CASA DEL COLISEO or THE COMPANY collects with your prior authorization. Personal data means any information collected and logged in a format that allows you to be identified personally, either directly by name or indirectly.

2. SCOPE

This Privacy Protection Policy will be applied to our complete database and/or files that contain personal data used by CASA DEL COLISEO SAS who is charged with the handling of said information.

3. IDENTIFICATION OF THE ACCOUNTABLE AUTHORITY

In all instances the responsible party for the usage of the information shall be CASA DELCOLISEO SAS, identified by NIT. 900656886-9, residing in the city of Cartagena, specifically atCentro Calle del Porvenir 35-23 P 2 AP 1. Telephone: 6600566 and email: management@hotelcasadelcoliseocartagena.com

4. TYPE OF INFORMATION COLLECTED

CASA DEL COLISEO SAS acknowledges that its employees, vendors, clients and shareholders have the right to expect a reasonable degree of privacy keeping in mind its responsibilities, rights and obligations. At various times we will need and store the following:

FROM PROSPECTIVE EMPLOYEES:
a. Name, identification, address, telephone, date of birth, education/degrees, hobbies and sports.
b. Resumé, degrees, work experience, ties with organizations and or businesses.

FROM GUESTS AND CLIENTS:
a. Name of guest or company, identification number or NIT with security code, place of residence, telephone, fax and email.
b. Name of General Manager or legal representative and address, telephones, fax and email.
c. Name of person in charge of payments, email.
d. Number of employees and length of time the company has been in business.
e. Tax information
f. Bank information including name of the signatory on the account, account number and name or code of Bank.

FROM VENDORS:
a. Name of provider or company, identification number or NIT with security code, place of residence, address, telephones,fax and email.
b. Name of the General Manager or Legal Representative, address, telephones, fax and email.
c. Name of the Sales Representative, address, telephones, fax and email.
d. Bank information including name of the signatory on the account, account number and name or code of Bank.

FROM EMPLOYEES AND CONTRACTORS:
a. Employee/ contractor and Family Group: Name, identification, address, telephone, Spouse’s and children’s names, identification of spouse and children, medical history,
social security registration, medical insurance policy, age, date of birth, medical authorizations, hobbies and leisure activities.
b. Resume, education, work experience, affiliations.
c. Salary and other income.
d. Balance of any debts outstanding with CASA DEL COLISEO SAS.
e. Payroll deductions.
f. Pension fund contributions
g. Incorporation and voluntary contributions to pension funds, food vouchers, etc.
h. Judicial proceedings, liens.
i. Outstanding debts with credit unions.
j. Approvals of deductions.
k. Information regarding membership of employee unions, businesses.
l. Benefits during your entire working life.
m. Employment contract.
n. Changes to employment contract.
o. Employee’s work resume.
p. Payments of assistance and benefits.
q. EPS affiliations, pension funds, ARL, Caja de Compensacion.
r. Trainings received.
s. Psychological evaluation reports.
t. Employee’s medical record history.
u. Job accidents.
v. Photographic record.

If within the information collected there is sensitive information CASA DEL COLISEO SAS will inform you of the nature of such data and the reason for collection and they will only be used with prior authorization by you. Please keep in mind that because of the sensitive nature of the information you are under no obligation to authorize such use.

5. USE AND PURPOSE OF COLLECTION

Personal data are used for the following purposes:
a. Execution of contract with the Company.
b. Payment of contractual obligations.
c. Information provided to government or judicial entities on their request.
d. Support in external or internal audits.
e. Sending and/or receipt of messages with commercial and promotional ends and/or to provide service to clients.
f. Providing details of our applicants, clients, employees and providers for the database of the Company.
g. Interaction with applicants, clients, employees or providers for the transmission of
information related to contractual, commercial and obligatory processes.
h. Collection of data with the purpose of fulfilling our obligation as Custodian of the
information and personal data that is our duty.
i. For security purposes and fraud prevention.
j. To provide optimal service to our clients.
k. Any other purpose resulting from a contract implementation or interaction between you and the Company.

If you provide us with your Personal Information, we will utilize this information solely for the purposes described above and we shall not sell, license, transmit or divulge this information to third parties unless (i) you expressly authorize us to do so, (ii) if deemed necessary to allow our providers or agents to provide the services we hired them to do, (iii) to provide you with our products or services, (iv) for marketing or promotional services, (v) as needed in case of a joint venture, sale or any other restructuring process, or (vi) as required or permitted by law. In order to carry out the above-mentioned tasks, your personal data may be shared with the Human Resources department, consultants, advisors and other persons or authorities as required.

The Company may hire subcontractors for the processing of certain duties or information. When doing so we will underscore the need for them to take the necessary precautions to safeguard such information.They are also notified that they may not use any of this information for their own purposes or share them with others.

The Company may also transfer or transmit your personal data to other companies abroad for security reasons, administrative expediency and better service with the authorization of each of these persons. CASA DEL COLISEO SAS has taken the necessary measures so that these companies may implement appropriate measures as required by the regulations stipulated in this document. In case of transmission of personal data such transmission will take place according to the rules stipulated in Decree 1377/13.

In addition, we inform you that when we do not require the information provided by you, we may eliminate it from the database belonging to CASA DEL COLISEO SAS or securely archived only to be used when needed as applicable by law. This data will not be destroyed or deleted even if solicited by you if it is required to fulfil a requirement or contract.

6. YOUR RIGHTS

Those whose personal data is utilized by CASA DEL COLISEO SAS have the following rights which can be exercised at any given moment:

* Be familiar with the personal data being utilized by CASA DEL COLISEO SAS. The right to solicit updating or correction of incomplete, inaccurate data, data conducive to errors or unauthorized data;

* Demand proof of such authorization given to CASA DEL COLISEO SAS unless as exempted.

• Be informed, if previously requested, regarding the use that CASA DEL COLISEO SAS has given to your data.

• File a complaint before the Superintendence of Industry and Commerce of any breach of the requirements as laid out in the Law of Protection of Personal Data.

• Apply for the suppression of your data and/or revoke your authorization of the handling of your data according to the conditions established in the following point #7.

• You have at no cost to you access to your personal information which has been handled by us.

7. PROCEDURES FOR PROCESSING AND RESPONDING TO PETITIONS, QUERIES, COMPLAINTS AND CLAIMS BY THE OWNERS OF THE PERSONAL INFORMATION.

The owners of personal information managed by CASA DEL COLISEO SAS have the right to access their information and the ways it is utilized, as well as the right to update and/or correct these as well as ask for them to be deleted if found that they have been inappropriately used.

Ways for you to do this:

* By writing to CASA DEL COLISEO SAS, Centro, Calle del Coliseo 35-23 P 2 AP 1. Cartagena, Colombia.

* Send an email to: management@hotelcasadelcoliseocartagena.com

* By calling us at: 6600566.

7.1 PROCEDURES FOR SOLICITING INFORMATION OR PLACING A PETITION

* Petitioner needs to verify identity or representatives’ identity. if the identity of the representative is not verifiable it will be considered null and void.

* At a minimum we require a name and address or contact information where the information.

* that is being solicited can be sent as well as a clear description of the required information.

* We will provide the required information within a period of no more than 10 working days starting on the day the petition is received. If we are not able to provide the information within the required period we will inform the petitioner of the reason for the delay. The information will have to be provided then within a period of no more than 5 working days.

7.2 PROCEDURES FOR FILING A CLAIM OR COMPLAINT

* You, or your legal representative, must clearly indicate which information needs to be corrected, updated or deleted.

• You, or your legal representative, must verify your/their identity. If you cannot do so satisfactorily then your petition will be null and void.

• Your claim must be presented trough the channels described previously in this document and contain at a minimum your name and address, or any other means of reaching you, the documents which verify your identity and given the case, those of your legal representative.

• Once we receive your claim it shall be labeled as “ claim or complaint being processed”, the reason for such and should be handled within 2 working days.

• The deadline for processing these is 15 working days after receipt.

• If for any reason we cannot fulfill your request within the stipulated time period, you will be informed as to the reason of the delay and provide with the information within 8 working days after the first deadline.

8. SPECIAL DISPENSATIONS FOR THE HANDLING OF PERSONAL INFORMATION

8.1 MANAGEMENT OF SENSITIVE PERSONAL INFORMATION

The handling of sensitive personal information is prohibited by law unless we have specific authorization for this by you according to Article 6 of the Law 1581 of 2012.

8.2 MANAGEMENT OF PERSONAL INFORMATION OF MINORS

According to Article 7 of the Law 1581 of 2012 and Article 21 of Decree 1377 of 2013 if required CASA DEL COLISEO SAS will only collect personal information of minors accordingly, always respecting the interest of minors and guaranteeing their fundamental rights.

Authorization for this will be required of their parents or legal custodian.

9. NATIONAL REGISTRY OF PERSONAL INFORMATION

The National Data Registry (RNBD) is the public registry of personal information in the country and is administered by the Superintendency of Industry and Commerce and is open to the public. CASA DEL COLISEO SAS will provide this Registry with the required information in the time period required.

10. MODIFICATION OF POLICY

This Policy may be amended at any given time and will be available to you.

Date of implementation: January 1, 2016. This database shall be valid for the time period required to manage the information.