I. PRIVACY

A. COOKIE POLICY

1. Definition of "cookie(s)" A cookie is a small piece of information that a website places on your PC, phone, or any other device, with information about your browsing on that site. Cookies are necessary to facilitate navigation, make it more user-friendly, and for the Website that sent it to remember you.

2. Use of cookies on the Website The main objective of the cookies we use is to understand how you interact with the Website and to improve your browsing experience. For example, by remembering your preferences (language, country, etc.) during browsing and on future visits. The information collected in the cookies also allows us to improve the website, through estimates of numbers and usage patterns, adapting the website to the individual interests of users, speeding up searches, etc. Occasionally, if we have obtained your prior informed consent, we may use cookies, tags or other similar devices to obtain information that allows us to show you advertising based on the analysis of your browsing habits from our website, third-party websites, or any other medium.

The information stored in the Website's cookies is used exclusively by us, with the exception of those identified below as "third-party cookies," which are used and managed by external entities to provide us with services requested by us to improve our services and the user's experience when browsing our website. The main services for which these "third-party cookies" are used are to obtain access statistics and to guarantee payment operations.

3. Preventing or disabling the use of Cookies on the Website If you wish to prevent the use of cookies on the Website, taking into account the above explanation, you must: (i) disable the use of cookies in your browser; and, (ii) delete the cookies saved in your browser associated with the Website. This option to prevent the use of cookies can be carried out by you at any time.

If you wish to restrict, block the use of or delete cookies from the Website, you can do so, at any time, by modifying your browser settings. Although each browser is different, generally to configure cookies, you must select the "Settings", "Preferences", or "Tools" menu. For more details on configuring cookies in your browser, consult its "Help" menu.

4. Cookies used on the Website. The cookies used by the Website are the following:

1. Session identification. Identifies the user's http session. It is common in all web applications to identify requests from a user in a session.

2. Acceptance of cookie use. Identifies whether the user has accepted the use of cookies on the website.

3. Google Analytics (third-party cookie). Allows website tracking through the Google Analytics tool, which is a service provided by Google to obtain information on user access to websites. Some of the data saved for later analysis are: number of times a user visits the website, dates of the first and last visit of the user, duration of visits, from which page the user accessed the website, which search engine the user used to reach the website or which link they clicked, from where in the world the user accessed, etc. The configuration of these cookies is predetermined by the service offered by Google, so we suggest you consult the Google Analytics privacy page, http://www.google.com/intl/es/analytics/privacyoverview.html, for more information on the cookies it uses and how to disable them (on the understanding that we are not responsible for the content or the veracity of third-party websites).

B. PRIVACY NOTICE

MOTTA INTERNACIONAL, S.A. is committed to the legal, lawful, legitimate, and secure processing of personal data contained in its information systems. As the controller of such processing, it communicates that the personal data of clients, contractors, suppliers, employees, and third parties is processed in accordance with the Personal Data Processing Policy, the content of which is available on the Website. Therefore, the information provided is processed for the purposes and scope set forth in said policy, which indicates your rights as the data subject to know, update or rectify your data and other rights provided in current regulations, which can be exercised through the email address contactenos@attenza.net.

 

C. AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA

I have been informed by MOTTA INTERNACIONAL, S.A. (Data Controller) of the following:

i. The data provided to the Data Controller will be processed for the following purposes: To send or use the information for contractual, customer service, marketing (such as consumption analysis, brand traceability, among others), commercial (such as benefits, promotions, discounts, current campaigns, promotional events, written materials, images, data messages, allied brands and programs of own brands or allies, among others), updating data and providing relevant information; for consultation to answer questions about products and services offered, conducting studies for statistical purposes, customer knowledge; for information, to inform data subjects about news, products, services and special offers, for the development of activities related to telephone services, collections or others of a similar nature. The Data Controller may transfer or transmit all or part of the data or information to its subsidiaries, businesses, and/or affiliated entities and strategic or commercial allies that operate or not in another jurisdiction for the purposes mentioned in this point.

ii. It is optional to answer questions about sensitive data or data of minors;

iii. As the data subject and/or representative of the minor, I have the rights to access, rectify, cancel or oppose the use of my information; and/or revoke the authorization granted;

iv. In case my request is not resolved directly, and subsidiarily, I have the right to file complaints with the competent authority;

v. I can exercise my rights and obligations by strictly observing ATTENZA's Privacy, Information and Personal Data Processing Policy, available at www.attenza.net and by contacting contactenos@attenza.net. Consult the Privacy, Information and Personal Data Processing Policy.

I declare that I have provided third-party data with their unequivocal and express authorization.

D. PRIVACY, INFORMATION PROCESSING AND PERSONAL DATA POLICY

1. GENERAL

MOTTA INTERNACIONAL, S.A., domiciled in Panama, with email contactenos@attenza.net, informs the Holders of Personal Data processed by the company of this Processing Policy in compliance with: (i) Law 1266 of 2008, Law 1581 of 2012 and Decree 1377 of 2013, in Colombia; (ii) Law No. 81 of March 26, 2019, in Panama; and (iii) Law No. 787 of March 29, 2012 in Nicaragua, collectively, the “Applicable Legislation”).

2. SCOPE OF APPLICATION

The policies and procedures contained in this document will be applicable at all times and during the performance of all activities involving the collection, storage, use, circulation, and transfer of information or personal data, registered in any database that makes them susceptible to processing by MOTTA INTERNACIONAL, S.A.

This document is of mandatory and strict compliance for MOTTA INTERNACIONAL, S.A., as the data controller, and can be consulted physically or electronically by any of the Data Subjects.

Both the controller and those in charge must safeguard the security of the databases containing personal data and maintain confidentiality regarding them.

3. DEFINITIONS

In accordance with current regulations and for the purpose of facilitating the understanding of this document, the following definitions will apply:

1. Authorization: Prior, express, and informed consent of the Data Subject to carry out the processing of personal data.

2. Privacy Notice: Electronic document or in any other format, generated by the Controller that is made available to the Data Subject for the processing of their personal data.

3. Database: Set of personal data that is subject to processing by the Controller;

4. Personal Data: Any information linked to one or more determined or determinable persons.

5. Public Data: Data related to the civil status of individuals, their profession and trade, and their status as a merchant or public servant. Due to their nature, Public Data may be contained, among others, in public records, public documents, official gazettes and bulletins, and duly executed judicial sentences that are not subject to reservation.

6. Sensitive Data: All information that may affect the privacy of the Data Subject or whose use may generate discrimination, such as those that reveal racial or ethnic origin, political orientation, religious or philosophical convictions, membership in trade unions, social organizations of human rights or that promote interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life, and biometric data.

7. Data Processor: Natural or legal person who, alone or in association with others, performs the processing of personal data on behalf of the Data Controller.

8. Data Controller: Natural or legal person, public or private, who, alone or in association with others, decides on the database and/or the data processing, that is, MOTTA INTERNACIONAL, S.A.

9. Data Subject: Natural or legal person, public or private, who is the owner of the information or personal data contained in the Controller's Database;

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

11. Transfer: Data Transfer occurs when the Data Controller and/or Processor of Personal Data sends the information or Personal Data to a recipient, who in turn is the Data Controller and is located inside or outside the country.

12. Transmission: Processing of Personal Data that involves communicating them inside or outside the territory, when its purpose is for the Processor to carry out processing on behalf of the Controller.

4. RIGHTS OF PERSONAL DATA SUBJECTS

In accordance with the Applicable Legislation, Data Subjects have the following rights:

1. To know, update, and rectify their Personal Data before MOTTA INTERNACIONAL, S.A., in its capacity as Data Controller. This right may be exercised with respect to partial, inaccurate, incomplete, fragmented, misleading data, or those whose processing is expressly prohibited or has not been authorized.

2. To request proof of the authorization granted to MOTTA INTERNACIONAL, S.A. or the local affiliated company, in its capacity as Data Controller, except when expressly exempted as a requirement for processing, in accordance with the Applicable Legislation.

3. To be informed by MOTTA INTERNACIONAL, S.A., regarding the use made of their personal data if expressly requested.

4. To revoke the authorization and/or request the suppression of the data when the processing does not respect constitutional and legal principles, rights, and guarantees. Revocation and/or suppression will proceed when the competent authority has determined that the Data Controller or Processor has engaged in conduct contrary to the Applicable Legislation during processing.

5. To access their personal data in the databases of MOTTA INTERNACIONAL, S.A. free of charge.

6. To be informed of substantial changes made to this Information Processing Policy, such as, but not limited to: changes in the identification of the Data Controller and in the purpose of processing the personal data of customers, suppliers, and employees of MOTTA INTERNACIONAL, S.A.

7. To receive a new authorization request for Information Processing when MOTTA INTERNACIONAL, S.A. makes changes to the Privacy Policy that modify the purpose of Information Processing.

Attention to requests to the Privacy Officer (updates, rectifications, deletion of Information, and revocation of authorization), inquiries, and complaints regarding Information Processing.

5. PURPOSE OF PROCESSING

1. To achieve efficient communication related to our products, services, offers, promotions, alliances, contests, content, and other activities, thus facilitating general access to information about them.

2. To evaluate the quality of our products and services through satisfaction surveys and conduct studies on consumption habits, preferences, purchase interest, product testing, concept, service evaluation, satisfaction, and others related to our services.

3. To carry out marketing, promotion, advertising, billing, collection, revenue collection, service improvements, inquiries, verifications, control, payment method enablement, fraud prevention, as well as any other activity related to our current and future services and offers for the fulfillment of contractual obligations and our corporate purpose, through any direct means.

4. To control and prevent fraud in all its forms.

5. To perform basic administrative management tasks.

Subject to obtaining your consent, we may contact you by email, text message (SMS, MMS), direct mail, or telephone.

If you prefer not to receive communications through any or all of these channels, you can notify contactenos@attenza.net at any time and request to stop receiving such communications.

6. RESPONSIBLE FOR EXERCISING DATA SUBJECTS' RIGHTS

For the processing of petitions, complaints, claims, and requests for modifications made by Data Subjects in exercise of the rights established herein, Data Subjects or their representatives may contact the person responsible at MOTTA INTERNACIONAL, S.A., from Monday to Friday from 8:00 a.m. to 5:00 p.m., at the email address contactenos@attenza.net.

7. PROCEDURE FOR EXERCISING THE RIGHTS TO KNOW, UPDATE, RECTIFY, AND DELETE INFORMATION AND TO REVOKE AUTHORIZATION

The Data Subject or any of the authorized persons in accordance with this Policy, who considers that the information contained in the databases of MOTTA INTERNACIONAL, S.A. should be corrected, updated, or deleted, or when they notice an alleged breach of the Applicable Legislation or any rule that complements or modifies it, may file a complaint with MOTTA INTERNACIONAL, S.A., which will be processed in accordance with the following rules:

1. The complaint will be formulated by means of written requests sent to the email address contactenos@attenza.net.

2. If the complaint is incomplete, MOTTA INTERNACIONAL, S.A. will require the interested party within five (5) days following receipt of the complaint to correct the deficiencies. After two (2) months from the date of the request, if the applicant does not submit the required information, it will be understood that they have withdrawn the complaint.

3. The maximum period to address the complaint will be fifteen (15) business days from the day following its receipt. If it is not possible to address the complaint within said period, the interested party will be informed of the reasons for the delay and the date on which their complaint will be addressed, which in no case may exceed eight (8) business days following the expiration of the first period.

8. DATA DELETION

The data subject has the right, at any time, to request MOTTA INTERNACIONAL, S.A. to delete their personal data when:

• They consider that the data is not being processed in accordance with the principles, duties, and obligations set forth in the Applicable Legislation.

• The data is no longer necessary or relevant for the purpose for which it was collected.

• The period necessary for the fulfillment of the purposes for which it was collected has expired.

This deletion implies the total removal of personal information, as requested by the data subject, from the records, files, or databases of MOTTA INTERNACIONAL, S.A.

The right of deletion is not absolute, and the Data Controller may deny its exercise when the Data Subject has a legal or contractual duty to remain in the database of MOTTA INTERNACIONAL, S.A.

9. REVOCATION OF AUTHORIZATION

The data subject can revoke consent to the processing of their personal data at any time, provided that a legal provision does not prevent it.

10. INTERNATIONAL TRANSFER OF PERSONAL DATA

When data is sent or transferred to another country, the authorization of the data subject whose information is being transferred will be required. In this regard, before sending personal data to another country, those obliged to comply with this policy must verify that they have the prior, express, and unequivocal authorization of the data subject to transmit their personal data.

By sharing your personal data with MOTTA INTERNACIONAL, S.A., you authorize it to be sent or transferred to another country when necessary. This transfer of personal data is carried out only to third parties with whom MOTTA INTERNACIONAL, S.A. has a contractual, commercial, and/or legal relationship, so that they can assist us with some of the functions related to product promotion, payment collection, product shipments, or outsourcing of our customer service systems. We may exchange information with third parties for fraud protection and credit risk reduction purposes.

MOTTA INTERNACIONAL, S.A. may also transfer data to other Data Controllers when authorized by law or by an administrative or judicial order.

11. VIDEO SURVEILLANCE

MOTTA INTERNACIONAL, S.A. uses various video surveillance means installed in different internal and external locations of its facilities or offices. Consequently, it informs the general public about the existence of these mechanisms by displaying video surveillance notices in visible places.

The information collected through this mechanism is used for security purposes, improving our service and the experience at MOTTA INTERNACIONAL, S.A.'s facilities, as well as evidence in any type of process before any type of authority or organization.

MOTTA INTERNACIONAL, S.A. does not hand over obtained video recordings to any third party, unless there is a judicial order or from a competent authority or if permitted by law.

12. INFORMATION SECURITY
In developing the principle of security, MOTTA INTERNACIONAL, S.A. has adopted reasonable technical, administrative, and human measures to protect the data subjects' information and prevent alteration, loss, consultation, unauthorized or fraudulent use or access. Access to personal data is restricted to its data subjects, and MOTTA INTERNACIONAL, S.A. will not allow access to this information by third parties under conditions other than those announced, except for an express request from the data subject or persons legitimized in accordance with national regulations.

Notwithstanding the foregoing, MOTTA INTERNACIONAL, S.A. will not be responsible for any action tending to infringe the security measures established for the protection of Personal Data.

13. CHANGES TO THE POLICY

MOTTA INTERNACIONAL, S.A. may modify this Policy at any time and will always publish the updated version in all its commercial establishments.

14. VALIDITY OF THE POLICY

The Policy is effective from the acceptance of its Terms and Conditions. As a general rule, the term of authorizations for the use of personal data is understood for the term of the commercial relationship or the service linkage and during the exercise of the company's corporate purpose.