1. Introduction

Information security is a fundamental priority for Go-Delegate International LLC, a companycommitted to excellence in providing outsourcing services to businesses located in the UnitedStates. We recognize the importance of protecting the confidentiality, integrity, and availabilityof the data we handle, both for our clients and for our own operation. Therefore, this policyestablishes the principles and measures we adopt to ensure security in data processing.

2. Scope

This policy applies to all employees, contractors, suppliers, and business partners of Go-Delegate International LLC, as well as to any third parties who may have access to data on our behalf.

3. Legal Compliance

We are committed to complying with all applicable data protection laws and regulations, both in Colombia and the United States. This includes, among others, the General Data Protection Regulation (GDPR) of the European Union and the Personal Data Protection Law in Colombia.4.

4. Responsibility and Organization

Information security is the responsibility of everyone at Go-Delegate International LLC. Management is committed to allocating adequate resources and providing ongoing training to ensure the effective implementation of security measures.

5. Risk Management

We continuously identify, assess, and mitigate risks related to data processing. This includes conducting data protection impact assessments and implementing appropriate security controls.

6. Data Protection

We are committed to protecting our clients’ data through the use of appropriate technical, organizational, and administrative measures. This includes data encryption, firewall implementation, access control, staff training, and security patch management.

7. International Data Transfer

When we transfer data to countries outside of Colombia, we ensure that appropriate security measures are applied and that legal requirements for international data transfer are met.

8. Confidentiality

We guarantee the confidentiality of the data we process and commit not to disclose it to unauthorized third parties, except where necessary for the provision of services or permitted by law.

9. Security Incidents

We implement a security incident management procedure to detect, report, and respond appropriately to any security breach that may affect the data we process.

10. Review and Continuous Improvement

We commit to regularly reviewing this policy, as well as our security practices and controls, to ensure their effectiveness and adapt them to changes in the operational and legal environment.

11. Compliance

Non-compliance with this policy may result in disciplinary action, including termination of employment or termination of the contractual relationship, as appropriate.

12. Contact

For any questions or concerns related to this policy, please contact the data protection officer of Go-Delegate International LLC at jvelez@go-delegate.com.