PRIVACY NOTICE

PRIVACY NOTICE

Valencia Holding Group

Last updated: 1-1-2026

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1. Introduction and Purpose: This Privacy Notice (“Notice”) describes how Valencia Holding Group and its authorized subsidiaries, affiliates, controlled entities, brands, and business units (collectively, the “VHG Group,” “VHG,” “we,” “us,” or “our”) collect, use, store, disclose, protect, and otherwise process personal data obtained through our websites, digital platforms, applications, communication channels, and online services (collectively, the “Digital Platforms”).

This Notice is issued in accordance with applicable data protection and privacy laws in the jurisdictions in which VHG operates, including the United States, Colombia, and Panama, and reflects internationally recognized best practices for lawful, fair, and transparent data processing.

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2. Scope of Applicability: 

2.1 Covered Entities: This Privacy Notice applies to all Digital Platforms operated by or on behalf of VHG, whether directly or indirectly, including those operated by:

• Parent and holding entities

• Subsidiaries and affiliated companies

• Authorized brands and business units

• Controlled or managed platforms acting under VHG’s governance framework

Entity-specific privacy supplements may apply where required by local law, provided they remain consistent with this master Notice.

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2.2 Covered Individuals: This Notice applies to all individuals whose personal data is processed by VHG, including:

• Website visitors and users

• Clients and prospective clients

• Investors and potential investors

• Business partners and counterparties

• Contractors, suppliers, and service providers

• Any individual interacting digitally with VHG

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3. Governing Privacy Principles: VHG processes personal data in accordance with the following principles, which reflect GDPR-aligned international standards and are embedded across VHG’s governance framework:

• Lawfulness and fairness

• Purpose limitation

• Data minimization

• Accuracy and data quality

• Storage limitation

• Security and confidentiality

• Accountability and transparency

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4. Categories of Personal Data Collected: Depending on the nature of the interaction, VHG may collect and process the following categories of personal data:

4.1 Identification and Contact Data

• Full name

• Identification number or document type (where legally required)

• Email address

• Telephone number

• Country of residence or business location

4.2 Professional and Business Information

• Company name and role

• Business contact details

• Professional background relevant to services or inquiries

4.3 Digital and Technical Data

• IP address

• Browser type and device identifiers

• Usage logs and interaction metadata

• Cookie and tracking data (see Cookie Notice)

4.4 Communication Data

• Messages, inquiries, and correspondence submitted through Digital Platforms

• Records of communications with VHG representatives

VHG does not intentionally collect sensitive personal data unless strictly necessary and legally permitted.

5. Purposes of Data Processing: Personal data is processed for legitimate and defined purposes, including:

• Operating and managing Digital Platforms

• Responding to inquiries and communications

• Managing client, investor, and partner relationships

• Evaluating business opportunities and service requests

• Compliance with legal, regulatory, and contractual obligations

• Risk management, security, and fraud prevention

• Corporate governance, reporting, and internal controls

• Improving Digital Platform performance and user experience

Data will not be processed for purposes incompatible with those described above.
 

6. Legal Bases for Processing: Depending on jurisdiction and context, VHG relies on one or more of the following legal bases:

• Consent of the data subject

• Performance of a contract or pre-contractual steps

• Compliance with legal obligations

• Legitimate interests of VHG, provided such interests do not override fundamental rights and freedoms

Where consent is required, it may be withdrawn at any time in accordance with applicable law.

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7. Data Sharing and International Transfers

7.1 Data Sharing: Personal data may be shared with:

• Authorized VHG entities within the corporate group

• Professional advisors (legal, financial, compliance)

• Technology, hosting, and service providers

• Regulatory or governmental authorities where legally required

All third parties are subject to confidentiality and data protection obligations.

7.2 Cross-Border Transfers

Given VHG’s international operations, personal data may be transferred across borders, including to the United States, Colombia, Panama, and other jurisdictions. VHG implements appropriate safeguards to ensure equivalent levels of data protection, consistent with applicable law and international best practices.

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8. Data Retention

Personal data is retained only for as long as necessary to:

• Fulfill the purposes for which it was collected

• Comply with legal, regulatory, or contractual obligations

• Resolve disputes or enforce agreements

Retention periods are defined in accordance with internal data governance policies.

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9. Data Subject Rights: Subject to applicable law, individuals may exercise the following rights:

• Access to their personal data

• Rectification of inaccurate or incomplete data

• Deletion or erasure, where legally permissible

• Restriction or objection to processing

• Data portability, where applicable

• Withdrawal of consent

Requests may be submitted through VHG’s official contact channels and will be addressed within legally mandated timeframes.
 

10. Information Security Measures: VHG implements administrative, technical, and organizational safeguards designed to protect personal data against:

• Unauthorized access

• Loss or destruction

• Alteration or disclosure

• Misuse or unlawful processing

Security controls are aligned with enterprise-level risk management and governance standards.

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11. Third-Party Platforms and Links: Digital Platforms may contain links to third-party websites or services. VHG is not responsible for third-party privacy practices and encourages users to review external privacy policies independently.

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12. Updates to This Privacy Notice: VHG reserves the right to amend this Privacy Notice at any time. Updates will be published on the applicable Digital Platforms and become effective upon publication. Continued use constitutes acknowledgment of the updated Notice.

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13. Contact and Data Protection Inquiries: For privacy-related inquiries, requests, or concerns, individuals may contact VHG through the official channels provided on the Digital Platforms. Where required by law, designated data protection contacts or representatives will be identified.