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For the interpretation of this personal data treatment policy, the expressions used here with an initial capital letter must be understood with the meaning indicated below. Defined terms are used in the singular and plural as required by the context in which they are used.

(i) Authorization.Prior, express and informed consent of the Owner to carry out the Processing of Personal Data;

(ii) Privacy Notice.Verbal or written communication generated by the Responsible, addressed to the Owner for the Processing of their personal data, through which they are informed about the existence of the information Processing policies that will be applicable to them, the way to access them and the purposes of the Treatment that is intended to be given to personal data.

(iii) Personal Database.Organized set of Personal Data that are subject to Treatment by CUBE VENTURES SAS (hereinafter “CUBE”) or whoever it designates, in its capacity as Responsible and/or Manager;

(iv) Personal Data.Any information linked or that can be associated to one or several determined or determinable natural persons;

(v) Public Data.It is the data classified as such according to the mandates of the Law or the Political Constitution. The data relating to the marital status of people, their profession or trade, their quality as a merchant or public servant and those that can be obtained without any reservation are public, among others. Due to its nature, Public Data may be contained, among others, in public registries, public documents, gazettes and official bulletins, duly executed judicial sentences that are not subject to reservation;

(vi) Data on children and adolescents.They are those Personal Data whose Holders are minors, in which case their Treatment must ensure the prevalence of their fundamental rights.

(vii) Sensitive Data.They are those that affect the privacy of the Holder or whose improper use can generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership of unions, social organizations, human rights or that promotes the interests of any political party or that guarantees the rights and guarantees of opposition political parties as well as data related to health, sexual life and biometric data.

(viii) Processor or Manager.Natural or legal person, public or private, that by itself or in association with others, performs the Processing of Personal Data on behalf of the Data Controller;

(ix) Responsible for Treatment or Responsible.Natural or legal person, public or private, that by itself or in association with others, decides on the Database and/or the Treatment of the data;

(x) Holder.Natural person whose personal data is subject to Treatment;


(xi) Transfer. The Transfer of Personal Data is understood to be the one carried out by the person in charge and/or in charge of the processing of personal data, located in Colombia, when it sends the information or Personal Data to a recipient, who in turn is Responsible for the Treatment and is within or out of the country.

(xii) Transmission.Treatment of Personal Data that implies a communication of the same inside or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the Manager on behalf of the Responsible.

(xiii) Treatment.Any operation or set of operations on Personal Data, such as collection, storage, use, circulation or deletion.


Establish the criteria for the collection, storage, use, circulation and deletion of personal data processed by CUBE.


This policy will be applicable to the databases that are under the administration of CUBE and whose data have been obtained or are likely to be known by it, by virtue of the relationships developed with third parties. In this case, CUBE will act as Responsible and in other cases it could have the quality of Manager or Responsible, depending on whether it receives them from a third party for the fulfillment of a specific purpose or if it obtains them itself. This same policy will be applicable when the data processing is carried out in Colombian territory and when the person in charge or in charge of the treatment does not reside in Colombia, but by virtue of international regulations or treaties, Colombian legislation is applicable.


This policy is mandatory and strict compliance for CUBE, or whoever acts as Responsible or In Charge of Treatment.


CUBE VENTURES SAS, a legally constituted commercial company, identified with NIT 901.395.842-8, with main address at Calle 74 #11-91 in the city of Bogotá, Republic of Colombia. Page: Email: Telephone: +57 3017229481.


The treatment that CUBE will carry out with the personal information will be the following:

For the processing of personal data with applicants, employees or contractors:


  • Manage and operate, directly or through third parties, the processes of selection and hiring of personnel.

  • Evaluation and qualification of the participants and the verification of work and personal references, and the performance of safety studies when applicable.


  • Make the necessary payments derived from the execution of the work contract, contract for the provision of services and/or its termination, and the other social benefits that may apply in accordance with the applicable law.

For the processing of personal data with entrepreneurs:


  • Provide the services and/or products offered to the entrepreneur.


  • Carry out profiling and segmentation campaigns for entrepreneurs.


  • Inform about new products and/or services and about changes in them.

  • Evaluate the quality of the service.

  • Conduct investigative studies.

  • Send to physical mail, email, cell phone or mobile device, via text messages (SMS and/or MMS) or through any other analogous and/or digital means of communication created or to be created, commercial or advertising information about the products and/or or services offered, in order to inform and, in general, carry out campaigns, of a commercial or advertising nature, carried out by CUBE or its allies.


  • Update and supply the contact information of natural persons for the products, services and/or activities of the corporate purpose of CUBE.


  • Attention to requests, complaints and claims.


For the treatment of personal data with suppliers:


  • For the attention of requests or requirements regarding the contractual relationship that exists or existed with the suppliers.


  • Compliance with rules and policies regarding the knowledge of third parties associated for the prevention and control of money laundering and terrorist financing.


  • Create and feed databases for the aforementioned purposes and in general for the development of the corporate purpose of CUBE and its allies or related companies.


For the processing of personal data with investors:


  • For the attention of requests or requirements, the sending of communications regarding the investment and those derived from the contractual relationship that exists or existed with the investors.


  • For the payment of profits or business related to the investment.


  • Compliance with regulations and policies regarding investor knowledge for the prevention and control of money laundering and terrorist financing.


  • Create and feed databases for the aforementioned purposes and in general for the development of the corporate purpose of CUBE and its allies or related companies.



Neither CUBE nor whoever it designates as Responsible or In Charge of the Processing of Personal Data will collect or process Sensitive Data, unless expressly authorized by the Holder.



As the Holder of your personal data, you have the right to:


(i) Free access to the data provided that have been processed.


(ii) Know, update and rectify your information against partial, inaccurate, incomplete, divided, misleading data, or those whose Treatment is prohibited or has not been authorized.


(iii) Request proof of the Authorization granted.


(iv) Submit complaints to the Superintendence of Industry and Commerce (SIC) for violations of the provisions of current regulations.


(v) Revoke the Authorization and/or request the deletion of the data, provided that there is no legal or contractual duty that prevents its deletion.


(vi) Refrain from answering the questions about Sensitive Data. The answers that deal with sensitive data or data on children and adolescents will be optional.



The Holder can exercise the rights described in this document through the email or at the address calle 74 #11-91 in the city of Bogotá DC




In compliance with the regulations on personal data protection, CUBE presents the procedure and minimum requirements for the exercise of your rights:


For the filing and attention of your request, we ask you to provide the following information:


  • Full name and surname

  • Contact information (Physical and/or electronic address and contact telephone numbers),

  • Means to receive a response to your request,

  • Reason(s)/fact(s) that give rise to the claim with a brief description of the right you wish to exercise (know, update, rectify, request proof of the authorization granted, revoke it, delete, access the information)

  • Signature (if applicable) and identification number.

The maximum term provided by law to resolve your claim is fifteen (15) business days, counted from the day following the date of receipt. When it is not possible to address the claim within said term, CUBE will inform the interested party of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first term.

Once the terms indicated by Law 1581 of 2012 and the other norms that regulate or complement it have been fulfilled, the Owner who is denied, totally or partially, the exercise of the rights of access, update, rectification, deletion and revocation, may bring your case to the attention of the Superintendence of Industry and Commerce – Delegation for the Protection of Personal Data.




This Policy for the Treatment of Personal Data is effective as of December 16, 2020.


The databases in which the personal data will be registered will have a validity equal to the time in which the information is maintained and used for the purposes described in this policy. Once these purposes are met and provided there is no legal or contractual duty to retain your information, your data will be deleted from our databases.


Notwithstanding the foregoing, the policies established by CUBE regarding the Processing of Personal Data may be modified at any time. Any modification will be made in accordance with current legal regulations, and they will enter into force and take effect from their publication on the CUBE website so that the holders are aware of the PERSONAL DATA PROCESSING POLICY and the changes that occur in the same.

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