Purpose:  There must be a legitimate, specific and explicit purpose for using the data. Since the holder

must be informed about how the data will be used. As an operator, Wolkee will strictly follow the

directing the Client Company on the processing and use of data through contract

services and will only store personal information in accordance with the contracted services.

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Data quality:  The data subject has the right to review the data whose processing has been consented to to ensure accuracy, clarity and up-to-dateness. This responsibility remains with the Client Company, which, in turn, has to ensure that its direct clients can access and update their data. The Client Company's direct customers do not have access to data stored at Wolkee. After any update to the Customer Companies' databases, this data is automatically replicated to the Wolkee databases for reporting and other services.

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Suitability:  Data must be treated in a manner compatible with the purpose informed and approved by the owner. As operator, Wolkee will treat the data in accordance with the service contract signed with the Client Company which is responsible for ensuring the adequacy and purpose.

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Free Access:  The holder has the guaranteed right at any time to consult how their data is being used by the Company. This responsibility remains with the Client Company, which, in turn, has to ensure that its direct clients can access and verify how their data is used. The Client Company's direct customers do not have access to data stored at Wolkee.

Necessity:  Data should only be processed when necessary, not exceeding the use communicated and authorized by the owner. As an operator, Wolkee will strictly follow the Client Company's guidelines on the treatment and use of data from its direct customers through the service contract signed.

Prevention:  The company must adopt general security measures and internal training of its employees to avoid the occurrence of damages due to the processing of personal data. Customer Companies' direct customer data is stored in the Microsoft Azure cloud and follows the strictest information security concepts, using the most modern encryption methods from our partner Microsoft.

 

Transparency: Clear information about the processing of personal data, avoiding doubts for the holder. This responsibility remains with the Client Company, which, in turn, has to guarantee clarity to its direct clients about the type of data processing. Wolkee will strictly follow the Client Company's guidance on the treatment and use of data through the service contract

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Safety:  Connected to the principle of Prevention, technical and administrative measures are necessary to protect personal data against incidents.

• Techniques: Client Companies' direct customer data is stored in the Microsoft Azure cloud and follows the strictest Information security concepts that are approved by other programs such as GDPR.

• Administrative: All Wolkee employees, third parties and partners annually sign the Wolkee Code of Ethics and Conduct, where this documentation clearly expresses the data protection responsibility of its Client Companies and its direct customers, as well as the Wolkee principles and values. Our contracts with partners and customers contain an NDA session without exception.

• Access: Access to data stored in Wolkee is authorized by the Client Company, preventing any type of unauthorized access. Accesses are monitored and recorded for further evaluation. Wolkee on its own initiative performs a semi-annual review of access of all its customers, partners and employees, ensuring that only authorized people see the data .

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Non-Discrimination:  No data will be used for discriminatory or abusive purposes, whether of racial or ethnic origin, political opinion, religion or beliefs, geolocation, union membership, genetic or health status or sexual orientation.

Wolkee will strictly follow the rules written and signed in the service contract and will not allow any type of discrimination, which guides one of its main values: Respect.

Accountability and Accountability:  The company is required to demonstrate the adoption of measures capable of

comply with personal data protection regulations. Wolkee goes through a Due Diligence process for

each Client Company before signing a service contract, in order to ensure capacity

to protect the data of direct customers of the Client Companies, even if you have a company

integrator, contractually interacting with the Client Company.