Legal

Personal Data Processing Policy

CIRKULAR AGRO FINTECH S.A.S. (CIRKULAR ORIGIN) · Version 2.0 · In force from January 1, 2026 · Courtesy translation: the Spanish version prevails

CIRKULAR AGRO FINTECH S.A.S. (hereinafter, CIRKULAR ORIGIN) has undertaken to carry out its activity in compliance with Ley 1581 de 2012 (Law 1581 of 2012, the Colombian data protection law), Decreto Reglamentario 1377 de 2013 (Regulatory Decree 1377 of 2013), Decreto 886 de 2014 (Decree 886 of 2014), the other rules that make up the Colombian Personal Data Protection Regime, compiled in the Decreto Único Reglamentario 1074 de 2015 (Single Regulatory Decree 1074 of 2015), and the highest standards applicable in this field. CIRKULAR ORIGIN is committed to the security of the personal data of the producers it works with, its clients, contractors, suppliers, and employees, and of the general public.

17 sections

1. SCOPE

This Policy is publicly accessible, which is why anyone who wishes to know the standards and procedures established by CIRKULAR ORIGIN in relation to the Processing of Personal Data and the protection of the information contained in its Databases may access it and consult it at any time at cirkularorigin.com.

In order to guarantee the rights of the Data Subjects of the information, this Policy must be complied with by all workers linked to CIRKULAR ORIGIN. Likewise, it will apply to all employees, directors, agents, representatives, advisers, contractors, suppliers, and persons acting in the name and on behalf of this company who carry out any type of processing of personal data.

2. DEFINITIONS

Authorisation: The prior, express, and informed consent of the Data Subject to carry out the Processing of Personal Data, in accordance with the purposes and on the terms of this Privacy and Personal Data Protection Policy.

Privacy notice: The verbal or written communication that informs the Data Subject that this Policy exists, how to access it, and the purposes of the Processing of their data.

Database: The organised set of Personal Data, in digital, electronic, or physical media, that is subject to Processing.

Personal Data: Information that identifies a person, or linked information that can be associated with one or more specific or identifiable natural persons. It includes, among others, the image, the voice, and the location of a person or of their property when they make it possible to identify that person.

Private Personal Data: Information that concerns only the Data Subject and is confidential in nature.

Sensitive Personal Data: Personal data that affect the privacy of the Data Subject and whose improper use may lead to their discrimination, such as data that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of trade unions, social organisations, or human rights organisations, or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data relating to health and sex life, and biometric data, such as the fingerprint or the face when they make it possible to identify the person.

Public Data: Data that are not private, semi-private, or sensitive. Public data include, among others, data relating to the marital status of persons, to their profession or trade, and to their status as a merchant or public servant. By their nature, public data may be contained, among others, in public registers, public documents, gazettes, official bulletins, and final court judgments that are not subject to confidentiality.

Data Processor: The natural or legal person who, by itself or jointly with others, carries out the Processing of Personal Data on behalf of CIRKULAR ORIGIN.

CIRKULAR ORIGIN Personnel: All persons linked to CIRKULAR ORIGIN who are in charge of processing personal data, and who must comply with this Personal Data Protection Policy.

Data Controller: CIRKULAR ORIGIN when, by itself or jointly with others, it decides on the purposes and the processing of the Personal Data contained in its Databases.

Data Subject: The natural person whose Personal Data are subject to Processing.

Transfer: The sending of Personal Data by a Data Controller and/or Data Processor of Personal Data located in Colombia to a Data Controller located within or outside the country.

Transmission: The Processing of Personal Data that involves communicating them, within or outside the territory of Colombia, carried out by the Data Processor on behalf of the Data Controller.

Processing: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation, or deletion.

3. PRINCIPLES OF THE PROCESSING OF PERSONAL DATA

For the Processing of Personal Data, CIRKULAR ORIGIN will take into account the following principles:

Principle of Legality in Data Processing: the Processing of Personal Data will be subject to the provisions of the laws applicable in this field in Colombia and of the other provisions that implement those laws.

Principle of Purpose: the Processing will serve a legitimate purpose in accordance with the Constitution and the law of Colombia, which will be disclosed to the Data Subject of the Personal Data.

Principle of Freedom: the Processing may only be carried out with the prior, express, and informed consent of the Data Subject. Personal Data will not be obtained or disclosed without prior authorisation, or in the absence of a legal or judicial mandate that dispenses with consent.

Principle of Truthfulness or Quality: the information subject to Processing will be truthful, complete, accurate, up to date, verifiable, and understandable.

Principle of Transparency: the right of the Data Subject to obtain information about their Personal Data at any time and without restrictions, from CIRKULAR ORIGIN or from the Data Processor, will be guaranteed.

Principle of Restricted Access and Circulation: the Processing will be subject to the limits that derive from the nature of the Personal Data, from the provisions of the laws applicable in this field and, in particular, from this Policy. That is, Personal Data, except public information, will not be available on the internet or other means of mass disclosure or communication, unless access is technically controllable so as to provide knowledge restricted only to the Data Subjects or authorised third parties.

Principle of Security: the Personal Data subject to Processing by CIRKULAR ORIGIN or by its Data Processor(s) will be protected by the technical, human, and administrative measures necessary to provide security to the Personal Data, preventing their alteration, loss, consultation, use, or unauthorised or fraudulent access.

Principle of Confidentiality: all CIRKULAR ORIGIN Personnel who take part in the Processing of Personal Data will be obliged to guarantee their confidentiality, even after their relationship with any of the tasks that the Processing comprises has ended, and may only supply or communicate Personal Data when this corresponds to the performance of the activities authorised by law.

4. PROCESSING OF PERSONAL DATA

Collection of the Personal Data and the Processing to which they will be subject. CIRKULAR ORIGIN guarantees that it only processes the Personal Data of persons who have previously and expressly authorised that Processing. CIRKULAR ORIGIN will keep a copy of the authorisation so that the Data Subject of the Personal Data, whenever they wish and provided that it is appropriate, may revoke their authorisation and request the deletion of their information.

In the request for authorisation, CIRKULAR ORIGIN will provide all the information related to the Processing to which each Data Subject's Personal Data will be subject, including, where applicable, information related to the transmission or transfer of the Personal Data to third parties.

When the Personal Data are obtained as a result of entering into a contract, the particular terms and conditions of their Processing will be documented in the contracts signed with the Data Subjects. Therefore, when a producer, supplier, worker, or client signs the corresponding contract, they will be understood to be giving their express and informed consent for CIRKULAR ORIGIN to process their information in relation to the performance of that contract. Uses that are not necessary to perform the contract, such as the use of a person's image, voice, and testimonials, are authorised separately, one by one, and silence is not understood as authorisation.

Likewise, when the Data Subjects of the Personal Data provide their information to CIRKULAR ORIGIN voluntarily and unilaterally, such as when writing through the website, they will be understood to have given their express authorisation for the Processing of those data for the purposes disclosed at that time. The data that producers provide in the Cirkular App are processed under the authorisation they give in their contract and in the authorisation for the processing of personal data.

Whoever refers another person in the Cirkular App declares that that person allowed them to share their contact details. CIRKULAR ORIGIN asks the referred person for their authorisation at the first contact and, if they do not give it, deletes their data.

CIRKULAR ORIGIN will not be obliged to request the authorisation of the Data Subject of the Personal Data in the following cases: i) for information required by a public or administrative entity in the exercise of its legal functions or by court order; ii) when the data are public in nature; iii) in cases of medical or health emergency; iv) when the Processing is authorised by law for historical, statistical, or scientific purposes; and, v) when the data relate to the Registro Civil de las Personas (the Colombian civil registry).

5. ACCESS TO PERSONAL DATA

The information stored in CIRKULAR ORIGIN's Databases may be shared internally with the workers in charge of the Processing of Personal Data in accordance with the purposes mentioned in this Policy and/or in the request for authorisation for the Processing granted by the Data Subject.

CIRKULAR ORIGIN will not share or deliver Personal Data stored in its Databases to third parties not related to this company. However, and when the purpose so requires, the Personal Data may be legitimately transmitted or transferred to commercial partners or service providers of CIRKULAR ORIGIN, in order to fulfil specific contractual or commercial objectives. If CIRKULAR ORIGIN considers that it is necessary to make a transfer of Personal Data, it will only be made in strict compliance with the legal requirements.

Because of the nature of its carbon projects, CIRKULAR ORIGIN shares producers' data with the following recipients, only for the purposes in section 6: the project's certification standards and their registries (France and Switzerland); the independent verification body; the laboratories that analyse the samples; the auditors; the rating agencies that assess the quality of the credits (United Kingdom and other countries); the entities that fund or invest in the project; the buyers and prospective buyers of carbon credits; its parent company, Cirkular Agro Fintech LLC (United States); and the group company that receives by assignment a contract with the Data Subject.

What each one receives depends on the use:

  • Standards, registries, and verifier: the producer's name and the coordinates of their farm and of each application, because they require them to issue the credits.
  • Audits and due diligence reviews by auditors, rating agencies, funders, investors, and buyers or prospective buyers: data bearing the producer's name, such as their contract, their payment records, the monitoring photographs, and the location of their farm. Only what the review needs is provided, the cédula (national identity card) number only when the review requires it, and whoever receives them undertakes in writing to keep them confidential and not to use them for any other purpose.
  • Dashboards, reports, impact reports, and commercial material: aggregated data or data without the names or cédulas of the Data Subjects. Photographs in which a person can be recognised, only with their authorisation.

In any of these events, CIRKULAR ORIGIN undertakes to take all relevant measures to guarantee that the Processing of the information by its Data Processors and/or by its commercial partners or service providers is carried out in strict compliance with this Policy.

6. PURPOSES OF THE PROCESSING

Without prejudice to what is stated in the corresponding request for authorisation or contract, the Processing of Personal Data carried out by CIRKULAR ORIGIN has, in general, any of the following purposes:

  1. To carry out all the activities necessary for the pursuit of CIRKULAR ORIGIN's corporate purpose.
  2. Creation of the account for access to the services of the Cirkular App.
  3. To complete the profile information for access to the Cirkular App or to CIRKULAR ORIGIN's platform or back office, including the information needed to make payments to the Data Subject.
  4. Receipt of the information that the Data Subject provides in the Cirkular App, such as answers to surveys, documents, and information about their activities, and the information about their activities that CIRKULAR ORIGIN receives from its partners. To properly provide the contracted services, and to keep the Data Subjects informed about the progress, status, and other matters related to the contracted activity.
  5. To enrol producers in CIRKULAR ORIGIN's carbon removal programmes, such as the biochar programme made from coffee zoca (the woody stems cut back when coffee plantations are renewed), and to perform the contracts with them: recording production and application to the soil in the monitoring application, its own or a third party's, with dated and geolocated photographs, payments, and technical support.
  6. To meet the requirements of the carbon certification standards, of their registries, and of the independent verification, which includes providing them with the producer's name and the coordinates of their farm and of each application as proof that the biochar remained in the soil.
  7. To respond to the audits and due diligence reviews of auditors, rating agencies, funders, investors, and buyers or prospective buyers of carbon credits, to demonstrate that the projects comply and where the credits come from, on the terms of section 5.
  8. To carry out all the activities necessary to properly perform the existing contracts with producers, suppliers, clients, and other commercial contacts.
  9. To maintain efficient communication of the information that is useful for the performance and fulfilment of the existing contracts with producers, workers, suppliers, clients, and other commercial contacts.
  10. To carry out the administrative tasks associated with the pursuit of CIRKULAR ORIGIN's corporate purpose.
  11. To send commercial information about the activities that CIRKULAR ORIGIN carries out and about the launch of new products or services, including its newsletter, to those who have authorised it.
  12. To send communications by post, email, mobile device, text message, or any other analogue and/or digital means of communication with commercial, advertising, or promotional information about the services, events, promotions, campaigns, and/or contests of a commercial or advertising nature carried out by CIRKULAR ORIGIN, to those who have authorised it. Each mailing includes the way to unsubscribe.
  13. To respond to requests that arrive through the website and to manage, in CIRKULAR ORIGIN's contact manager, the relationships with clients, prospective buyers, partners, investors, and funders.
  14. To contact the Data Subjects in the event of complaints, claims, or suggestions about the activities of CIRKULAR ORIGIN, including complaints from producers.
  15. To carry out satisfaction campaigns, monitor the provision of its services, and assess the quality of the services provided by the workers and of the support given to the producers.
  16. To use the image, voice, name, and testimonials of producers and of other persons in CIRKULAR ORIGIN's communications and to share them with partners, buyers of credits, members of the CIRKULAR ORIGIN biochar programme, and companies in the coffee supply chain for their reports and communications, only in the uses that each person authorises one by one.
  17. To fulfil the obligations undertaken with CIRKULAR ORIGIN's workers in relation to the payment of salaries, social benefits, and other obligations arising from the employment relationship.
  18. To contact and engage suppliers of products or services that CIRKULAR ORIGIN requires for the performance of its activities and the ordinary furnishing of its premises or offices; to check them against national and international restrictive lists to prevent money laundering and terrorist financing; and to make the requests necessary to report the tax information related to them.
  19. To submit information to control and supervisory authorities and to support internal or external audit processes, including the audits and verifications of the certification standards.
  20. To offer educational content in the Cirkular App and to collect the services that the Data Subjects use and the way in which they use them.
  21. To receive the contact details of the persons that a Data Subject refers in the Cirkular App and to contact them to present CIRKULAR ORIGIN's programmes to them, on the terms of section 4.
  22. Analysis of personal information by CIRKULAR ORIGIN, its shareholders, its parent company Cirkular Agro Fintech LLC and other related companies, and third parties engaged for the development and promotion of the sale of CIRKULAR ORIGIN's services and carbon credits and for raising capital.
  23. To analyse the producers' information, such as their production, their practices, their answers to surveys, their use of the Cirkular App, and their payments, to improve the programmes and measure their impact, and to prepare dashboards, reports, impact reports, and commercial material for CIRKULAR ORIGIN, its partners, investors, funders, and buyers of credits, with aggregated data or without the names or cédulas of the Data Subjects.
  24. To record and transcribe virtual meetings to keep a record of what was agreed, with prior notice to the attendees.
  25. Invoicing and other tax purposes, in which case the information will be shared with the competent authority of each country responsible for carrying out that task.
  26. To carry out statistical studies or accounting processes.

The location of the farms. In the public registry of the standard, only the location of the group of producers is published, not the producer's name or the exact location of their farm. The exact location is provided to the standards and the verifier, and in the audits and due diligence reviews of section 5, under confidentiality. Producers are not checked against restrictive lists, and CIRKULAR ORIGIN does not consult or report any Data Subject to credit bureaus (centrales de información financiera).

7. PRIVACY AND SECURITY COMMITMENT

CIRKULAR ORIGIN is committed to the confidentiality and privacy of the Personal Data stored in its Databases, under access and availability restrictions, preventing their consultation by unauthorised third parties.

On that basis, CIRKULAR ORIGIN guarantees to the Data Subjects of the Personal Data that they will be kept under standard security conditions typical of the industry, which prevent their alteration, loss, theft, public consultation, use, or unauthorised or fraudulent access, as well as the implementation of internal practices that contribute to a secure information environment. If an incident occurs that compromises Personal Data, CIRKULAR ORIGIN reports it to the Superintendencia de Industria y Comercio (SIC, the Colombian data protection authority) and notifies the affected Data Subjects. CIRKULAR ORIGIN also applies this Policy to the technology and artificial intelligence tools it uses, and a person reviews every response on the exercise of the Data Subjects' rights.

7.1. Processing of the Personal Data of children and adolescents

CIRKULAR ORIGIN only processes Personal Data of children and adolescents when the processing serves their best interests and respects their fundamental rights, with the authorisation of their legal representative and after hearing the minor's opinion according to their maturity.

CIRKULAR ORIGIN may use photographs and videos in which a child or adolescent appears with their family, taken within its programmes, on its website, its social media, its reports and its communication and commercial material, only if all of these conditions are met:

1) their mother, father or legal representative authorises it in writing, use by use, on the minor's image authorisation form, after hearing the minor's opinion; if the minor does not want to appear, their image is not used;

2) the minor appears with their family, never alone or as the main subject of a piece;

3) the piece does not carry their name, their identity document, their school, the rural district, the farm or any other data that would allow them to be identified or located, and location data is removed from the file before publication;

4) the minor does not appear operating a kiln or in any production or work activity, nor in situations that affect their dignity or privacy;

5) the authorisation may be revoked at any time; CIRKULAR ORIGIN stops using the image in new pieces and removes it from its digital media within a maximum of fifteen (15) business days; and

6) whoever receives the image from CIRKULAR ORIGIN undertakes to meet the same conditions.

In this case, CIRKULAR ORIGIN will make its best efforts to verify that whoever acts as the legal representative of the child or adolescent actually holds that status. However, CIRKULAR ORIGIN will rely on the good faith of whoever grants the authorisation for the processing of the personal data of the child or adolescent and states that they hold the status of legal representative.

8. PROCESSING OF SENSITIVE DATA

CIRKULAR ORIGIN undertakes to avoid the Processing of Sensitive Data. However, when they are absolutely necessary, it will take charge of the Processing of Sensitive Data (according to the purposes listed above) and undertakes to:

1) Inform the Data Subject explicitly and in advance, in addition to the general requirements of the authorisation for the collection of all Personal Data, that the data to be Processed are sensitive and of the specific purpose of the Processing of those Sensitive Personal Data.

2) Inform the Data Subject that, because they are Sensitive Personal Data, they are not obliged to authorise their Processing.

In particular: the fingerprint is only requested when a producer cannot sign and another person signs at their request before two witnesses, because article 826 of the Código de Comercio (the Colombian Commercial Code) requires it, and it is used only as proof of that signature; photographs and videos in which a person can be recognised are only used with their authorisation; and answers to survey questions about sensitive data, such as health or ethnic origin, are voluntary.

Without prejudice to the above, CIRKULAR ORIGIN appreciates the prudence and discretion of the Data Subjects in disclosing Sensitive Data and requests that under no circumstances they be disclosed to CIRKULAR ORIGIN without having granted their prior, free, and informed consent. If you have doubts about the need to provide Sensitive Data, please contact us before providing them.

9. TRANSMISSION AND TRANSFER OF PERSONAL DATA

If CIRKULAR ORIGIN does not have the technical capacity to carry out certain activities that involve the Processing of Personal Data, it may transmit the Personal Data or the Personal Databases it considers relevant to third-party Data Processors, such as the providers of the Cirkular App, the monitoring application, cloud storage, website hosting, the accounting system, payments, email, the contact manager, and artificial intelligence tools. Several of them are outside Colombia.

In these cases, CIRKULAR ORIGIN will guarantee that the Data Processor complies with the terms established in this Privacy and Personal Data Processing Policy and that it meets the same standards of protection, information security, and guarantees for the Data Subjects.

CIRKULAR ORIGIN only transfers Personal Data outside Colombia in one of these cases: (a) the country appears on the Superintendencia de Industria y Comercio's list of countries with an adequate level of protection; (b) the Data Subject authorised it expressly and unequivocally, as the producer does in their contract; or (c) another case of article 26 of Ley 1581 de 2012 applies. If none of those cases applies, CIRKULAR ORIGIN does not transfer the data without a declaración de conformidad (declaration of conformity) from the Superintendencia. CIRKULAR ORIGIN does not sell or rent databases.

10. TIME LIMITS ON THE PROCESSING OF PERSONAL DATA

CIRKULAR ORIGIN will keep a record of the information related to producers, workers, suppliers, and/or clients during and after the end of the contractual relationship. These records may include Personal Data, which, after the contract ends, will be kept until the information they contain is no longer needed to comply with legal, administrative, audit, or regulatory requirements, as follows:

  • The records of the carbon projects (production, application, coordinates, and monitoring photographs): five (5) years after the project's last monitoring period, or longer if a law or the standard requires it.
  • The signed contracts and the accounting and tax supporting documents, including payments: ten (10) years.
  • The image, voice, and testimonials of the producers: while their contract is in force and five (5) years afterwards, unless the Data Subject withdraws their authorisation earlier.
  • The image of children and adolescents: while their representative's authorisation is in force, for a maximum of five (5) years, and not after they turn eighteen (18), unless they authorise it themselves.
  • The data of the account in the Cirkular App: while it is active and up to two (2) years after it is closed, except those that must be kept for the periods above.
  • The data of those who write through the website or subscribe to the newsletter: until they request their deletion or unsubscribe, and in any case no more than two (2) years without interaction.

Likewise, after its contractual relationship has ended, CIRKULAR ORIGIN will keep contact information of Data Subjects for sending news, updating information, and invitations to events held or sponsored by CIRKULAR ORIGIN. The above applies unless a request is made to revoke the authorisation for the Processing of Personal Data, in which case the information will be deleted for the purposes mentioned.

Finally, CIRKULAR ORIGIN will store and Process the Personal Data that are necessary to comply with its legal obligations. Once the periods have ended, it deletes or anonymises the data.

11. PROHIBITION OR REVOCATION OF AUTHORISATION FOR THE PROCESSING OF PERSONAL DATA

Data Subjects are free to prohibit or not authorise the Processing of their Personal Data by CIRKULAR ORIGIN, except on occasions when, due to legal or contractual requirements, it is necessary to keep these data. However, if some producers, clients, suppliers, or current or former workers do not authorise the use of their Personal Data or request the revocation of the authorisation for the Processing of their Personal Data, CIRKULAR ORIGIN may not be able to continue the commercial relationship or continue providing services because it does not have the information necessary for these purposes.

Revocation may be total or for a single purpose only, such as the use of the image or the sending of the newsletter, and revoking an authorisation that is not necessary for the contract does not affect that contract or the payments.

12. RIGHTS OF THE DATA SUBJECTS

The Data Subjects of Personal Data stored in CIRKULAR ORIGIN's Databases have the following rights:

To know, update, and rectify their Personal Data: Data Subjects may exercise this right in relation to data that are partial, inaccurate, incomplete, fragmented, or misleading. In compliance with the principles that must govern the Processing of Personal Data, CIRKULAR ORIGIN undertakes to make its best efforts to ensure that the information contained in its Databases is accurate, complete, and up to date. To this end, CIRKULAR ORIGIN may ask its producers, clients, suppliers, and workers to keep them permanently up to date.

Right to request proof of the authorisation: Data Subjects may request proof of the authorisation granted for the Processing of their data, except in the cases indicated in this Policy.

Right to be informed of the use that has been made of their Personal Data: Data Subjects have the right to know at any time the use that has been made of their Personal Data, upon a request addressed to CIRKULAR ORIGIN or to its Data Processor.

Right to revoke the authorisation and/or to request the deletion of the personal data: Data Subjects may at any time revoke the authorisation granted to CIRKULAR ORIGIN for the Processing of their Personal Data and/or request their deletion, except when they have a legal or contractual duty to remain in the Database.

Right to access their Personal Data: Data Subjects whose Personal Data are subject to Processing may access them free of charge at least once every calendar month and each time this Policy changes substantially.

Right to file complaints: Data Subjects may file complaints with the Superintendencia de Industria y Comercio for breaches of the provisions of the regulations in force, once they have exhausted the enquiry or complaint procedure with CIRKULAR ORIGIN.

Right to refrain from answering questions about sensitive data: Data Subjects whose Personal Data are subject to Processing may refrain from answering questions about sensitive data. Answers concerning sensitive data or data of children and adolescents will be optional.

13. PROCEDURES FOR HANDLING ENQUIRIES AND REQUESTS

The enquiry or request must be addressed to the email address info@cirkularorigin.com, or in writing to the address in section 16. It is handled by CIRKULAR ORIGIN's General Management. A producer who cannot write may ask their extension worker or a person of their choice to write it for them.

In the email, the Data Subject must fully identify themselves and clearly describe their request or enquiry. If the person is not acting as the Data Subject, please state the capacity in which they are acting and attach the document that empowers them to make the request or enquiry, such as a power of attorney or a registro civil (civil registry record), among others.

CIRKULAR ORIGIN will handle the request or enquiry within a maximum period of ten (10) business days from the date of receipt of the enquiry.

When it is not possible to handle the enquiry within that period, CIRKULAR ORIGIN will inform the interested party, stating the reasons for the delay and indicating the new period for handling their request or enquiry, which will not exceed five (5) business days from the expiry of the period in the previous paragraph.

14. COMPLAINTS

The request for correction, updating, or deletion of Personal Data must be addressed to the email address info@cirkularorigin.com, or in writing to the address in section 16.

In the email, the Data Subject must fully identify themselves. If the person is not acting as the Data Subject, please state the capacity in which they are acting and attach the document that empowers them to make the request or enquiry, such as a power of attorney or a civil registry record, among others.

If the complaint relates to a possible breach of any of CIRKULAR ORIGIN's duties, the reason for the breach must be stated in detail.

If the complaint is incomplete, CIRKULAR ORIGIN will ask the interested party, within the five (5) business days following its receipt, to correct its inaccuracies. If two (2) months pass from the date of that request without the applicant submitting the required information, CIRKULAR ORIGIN will understand that the complaint has been withdrawn.

If CIRKULAR ORIGIN receives a complaint that it is not competent to resolve, it will forward it to whoever is competent within a maximum period of two (2) business days and will inform the interested party of the situation.

Once the complete complaint has been received, CIRKULAR ORIGIN will include in the corresponding Database a legend reading "reclamo en trámite" (complaint in progress) and its reason, within a period not exceeding two (2) business days. That legend will remain until the complaint is decided.

CIRKULAR ORIGIN will handle the complaint within a maximum period of fifteen (15) business days counted from the day following the date of its receipt.

When it is not possible to handle the complaint within that period, CIRKULAR ORIGIN will inform the interested party of the reasons for the delay and the date on which their complaint will be handled, which may in no case exceed eight (8) business days following the expiry of the first period.

15. PERSONS AUTHORISED TO RECEIVE INFORMATION ABOUT THE PERSONAL DATA

For all purposes, CIRKULAR ORIGIN may only provide information contained in its Databases to:

  1. The Data Subjects, their successors in title, or their legal representatives.
  2. Public or administrative entities in the exercise of their legal functions or by court order.
  3. Third parties authorised by the Data Subject or by law.

CIRKULAR ORIGIN reserves the right to request additional documentation in order to verify the standing of the person requesting the information.

16. CONTACT INFORMATION OF CIRKULAR ORIGIN AS DATA CONTROLLER

Company name: CIRKULAR AGRO FINTECH S.A.S. (CIRKULAR ORIGIN)

NIT (Colombian tax identification number): 901.514.369-7

Domicile: Bogotá, Bogotá D.C., Colombia

Address: Calle 98 No. 7A-72

Telephone: 311 482 7167

Email: info@cirkularorigin.com

Website: https://cirkularorigin.com

17. AMENDMENT AND VALIDITY OF THIS POLICY

CIRKULAR ORIGIN reserves the right to amend this Policy at any time by publishing the corresponding amendment on its website. If the change is substantial, such as a new controller, a new purpose, or a new type of recipient, CIRKULAR ORIGIN will communicate it to the Data Subjects before applying it and, if the change concerns a purpose, it will request a new authorisation.

This Policy is in force from January 1, 2026 and replaces any previous version. CIRKULAR ORIGIN's Databases will remain in force for as long as the purposes in section 6 and the periods in section 10 continue to apply. The Policy is published in Spanish and English; if the versions differ, the Spanish version prevails.

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