Colly Privacy Notices

In compliance with Law No. 19,628 on the Protection of Private Life and other applicable regulations, COLEKTIA CHILE SpA (“COLEKTIA”), in its capacity as the data controller, makes this Privacy Notice available to data subjects. This notice applies to the use of the artificial intelligence system known as Colly, designed to perform automated collections activities through various communication channels.

For all matters related to this Privacy Notice, COLEKTIA may be contacted through the following means:

Address: Av. Providencia 1208, Office 2101, Providencia, Chile.
Email: privacidad@colektia.com

This email address may be used to exercise data protection rights and receive notifications related to the processing of personal data.

I. COLLY AS AN ARTIFICIAL INTELLIGENCE SYSTEM

Colly is an artificial intelligence agent developed by COLEKTIA that operates without direct human intervention and communicates with data subjects through telephone calls, emails, WhatsApp messages, SMS, web chatbots, and social media platforms. Its purpose is to facilitate collections management in an automated, efficient manner and in compliance with Chilean regulations.

II. PURPOSES OF PERSONAL DATA PROCESSING

The processing of personal data carried out by Colly has the following primary purposes:

• Contacting individuals to remind, notify, and manage the resolution of outstanding debts.
• Verifying the identity of data subjects during automated interactions.
• Maintaining communication through digital and telephone channels.
• Analyzing interaction data to optimize automated collections processes.
• Ensuring compliance with legal and contractual obligations arising from the relationship between COLEKTIA, its clients, and data subjects.
• Producing statistical reports and predictive models to improve collections strategies.

III. PERSONAL DATA PROCESSED

Colly may process all personal data necessary to properly perform collections activities, including:

• Identification data, such as name and Chilean Tax ID (RUT) or equivalent identification number.
• Contact information, including telephone number, email address, physical address, messaging profiles, and social media accounts.
• Information related to payment obligations, including outstanding balances, payment history, and creditor information.
• Technical data used to record interactions, such as date, time, and IP addresses.

Sensitive personal data will not be processed unless provided incidentally by the data subject. In such cases, enhanced security measures will be applied in accordance with Law No. 19,628.

IV. LEGAL BASIS FOR PROCESSING

The processing of personal data by Colly is based on:

• The fulfillment of contractual obligations between creditors and data subjects.
• Collections activities carried out in the legitimate interest of creditors.
• Compliance with applicable legal and regulatory obligations.
• The explicit consent of the data subject when required by law.

V. OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA

Data subjects may limit the use or disclosure of their personal data by submitting a request to privacidad@colektia.com in order to be included in COLEKTIA’s Exclusion List, ensuring that their data is not used for purposes other than those described in this Privacy Notice.

VI. DATA PROTECTION AND SECURITY MEASURES

COLEKTIA protects personal data processed by Colly in accordance with the principles established under Law No. 19,628 by implementing administrative, technical, and physical safeguards designed to prevent loss, alteration, unauthorized access, or misuse.

These measures include:

• Access controls
• Data encryption
• Database segmentation
• Activity monitoring
• Incident response protocols
• Business continuity procedures
• Security breach notification procedures when required by law

VII. DATA TRANSFERS AND DATA SUBJECT RIGHTS

Personal data may be shared with:

• Clients and creditors that engage COLEKTIA for collections services.
• Technology service providers operating under agreements that ensure confidentiality and regulatory compliance.
• Competent authorities when required by applicable law.

No transfers will be carried out without a legal basis or consent where consent is required.

Data subjects may exercise their rights of access, rectification, cancellation, blocking, or deletion by sending a request to privacidad@colektia.com together with a copy of their official identification. COLEKTIA will respond within a reasonable period in accordance with Law No. 19,628.

VIII. DATA OBTAINED FROM INDIRECT SOURCES

If personal data is obtained from public sources or third parties, such as creditor clients of COLEKTIA, the data subject will be informed of this Privacy Notice during the first contact before the data is used for collections purposes.

IX. CHANGES TO THIS PRIVACY NOTICE

COLEKTIA reserves the right to modify this Privacy Notice at any time to reflect regulatory, technical, or business changes.

Updates will be published through the usual communication channels and on the following website: www.colektia.com/privacy

X. USE OF COOKIES AND SIMILAR TECHNOLOGIES

When Colly interacts through websites, cookies and similar technologies may be used for analytics and service improvement purposes.

Data subjects may configure their browser settings to reject or delete cookies. However, disabling cookies may affect the functionality of certain services.

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In compliance with Law No. 29733, the Personal Data Protection Law, and its implementing regulations, COLEKTIA PERÚ S.A.C. (“COLEKTIA”), in its capacity as the data controller, makes this Privacy Notice available to data subjects. This notice applies to the use of the artificial intelligence system known as Colly, designed to perform automated collections activities through various communication channels.

For all matters related to this Privacy Notice, COLEKTIA may be contacted through the following means:

Address: Jirón Ocoña No. 160, Cercado de Lima, Province and Department of Lima, Peru.
Email: privacidad@colektia.com

This email address may be used to exercise data protection rights and receive notifications related to the processing of personal data.

I. COLLY AS AN ARTIFICIAL INTELLIGENCE SYSTEM

Colly is an artificial intelligence agent developed by COLEKTIA that operates without direct human intervention and communicates with data subjects through telephone calls, emails, WhatsApp messages, SMS, web chatbots, and social media platforms. Its purpose is to facilitate collections management in an automated, efficient manner and in compliance with Peruvian regulations.

II. PURPOSES OF PERSONAL DATA PROCESSING

The processing of personal data carried out by Colly has the following primary purposes:

• Contacting individuals to remind, notify, and manage the resolution of outstanding debts.
• Verifying the identity of data subjects during automated interactions.
• Maintaining communication through digital and telephone channels.
• Analyzing interaction data to optimize automated collections processes.
• Ensuring compliance with legal and contractual obligations arising from the relationship between COLEKTIA, its clients, and data subjects.
• Producing statistical reports and predictive models to improve collections strategies.

III. PERSONAL DATA PROCESSED

Colly may process all personal data necessary to properly perform collections activities, including:

• Identification data, such as name, national identity document number (DNI), or taxpayer identification number (RUC), where applicable.
• Contact information, including telephone number, email address, physical address, messaging profiles, and social media accounts.
• Information related to payment obligations, including outstanding balances, payment history, and creditor information.
• Technical data used to record interactions, such as date, time, and IP addresses.

Sensitive personal data will not be processed unless provided incidentally by the data subject. In such cases, enhanced security measures will be applied in accordance with Law No. 29733.

IV. LEGAL BASIS FOR PROCESSING

The processing of personal data by Colly is based on:

• The fulfillment of contractual obligations between creditors and data subjects.
• Collections activities carried out in the legitimate interest of creditors.
• Compliance with applicable legal and regulatory obligations.
• The explicit consent of the data subject when required by law.

V. OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA

Data subjects may limit the use or disclosure of their personal data by submitting a request to privacidad@colektia.com in order to be included in COLEKTIA’s Exclusion List, ensuring that their data is not used for purposes other than those described in this Privacy Notice.

VI. DATA PROTECTION AND SECURITY MEASURES

COLEKTIA protects personal data processed by Colly in accordance with the principles established under Law No. 29733 by implementing administrative, technical, and physical safeguards designed to prevent loss, alteration, unauthorized access, or misuse.

These measures include:

• Access controls
• Data encryption
• Database segmentation
• Activity monitoring
• Incident response protocols
• Business continuity procedures
• Security breach notification procedures when required by law

VII. DATA TRANSFERS AND DATA SUBJECT RIGHTS

Personal data may be shared with:

• Clients and creditors that engage COLEKTIA for collections services.
• Technology service providers operating under agreements that ensure confidentiality and regulatory compliance.
• Competent authorities when required by applicable law.

No transfers will be carried out without a legal basis or consent where consent is required.

Data subjects may exercise their rights of access, rectification, cancellation, objection, and deletion by sending a request to privacidad@colektia.com together with a copy of their official identification.

COLEKTIA will respond within a reasonable period in accordance with Law No. 29733.

VIII. DATA OBTAINED FROM INDIRECT SOURCES

If personal data is obtained from public sources or third parties, such as creditor clients of COLEKTIA, the data subject will be informed of this Privacy Notice during the first contact before the data is used for collections purposes.

IX. CHANGES TO THIS PRIVACY NOTICE

COLEKTIA reserves the right to modify this Privacy Notice at any time to reflect regulatory, technical, or business changes.

Updates will be published through the usual communication channels and on the following website: www.colektia.com/privacy

X. USE OF COOKIES AND SIMILAR TECHNOLOGIES

When Colly interacts through websites, cookies and similar technologies may be used for analytics and service improvement purposes.

Data subjects may configure their browser settings to reject or delete cookies. However, disabling cookies may affect the functionality of certain services.

In compliance with Law 1581 of 2012 on Personal Data Protection and other applicable regulations, COLEKTIA COLOMBIA S.A.S. (“COLEKTIA”), in its capacity as the data controller, makes this Privacy Notice available to data subjects. This notice applies to the use of the artificial intelligence system known as Colly, designed to perform automated collections activities through various communication channels.

For all matters related to this Privacy Notice, COLEKTIA may be contacted through the following means:

Address: Cr 18 A No. 103-11, Bogotá D.C., Colombia.
Email: privacidad@colektia.com

This email address may be used to exercise data protection rights and receive notifications related to the processing of personal data.

I. COLLY AS AN ARTIFICIAL INTELLIGENCE SYSTEM

Colly is an artificial intelligence agent developed by COLEKTIA that operates without direct human intervention and communicates with data subjects through telephone calls, emails, WhatsApp messages, SMS, web chatbots, and social media platforms. Its purpose is to facilitate collections management in an automated, efficient manner and in compliance with Colombian regulations.

II. PURPOSES OF PERSONAL DATA PROCESSING

The processing of personal data carried out by Colly has the following primary purposes:

• Contacting individuals to remind, notify, and manage the resolution of outstanding debts.
• Verifying the identity of data subjects during automated interactions.
• Maintaining communication through digital and telephone channels.
• Analyzing interaction data to optimize automated collections processes.
• Ensuring compliance with legal and contractual obligations arising from the relationship between COLEKTIA, its clients, and data subjects.
• Producing statistical reports and predictive models to improve collections strategies.

III. PERSONAL DATA PROCESSED

Colly may process all personal data necessary to properly perform collections activities, including:

• Identification data, such as name, national identification number (Cédula de Ciudadanía), or equivalent identification document.
• Contact information, including telephone number, email address, physical address, messaging profiles, and social media accounts.
• Information related to payment obligations, including outstanding balances, payment history, and creditor information.
• Technical data used to record interactions, such as date, time, and IP addresses.

Sensitive personal data will not be processed unless provided incidentally by the data subject. In such cases, enhanced security measures will be applied in accordance with Law 1581 of 2012.

IV. LEGAL BASIS FOR PROCESSING

The processing of personal data by Colly is based on:

• The fulfillment of contractual obligations between creditors and data subjects.
• Collections activities carried out in the legitimate interest of creditors.
• Compliance with applicable legal and regulatory obligations.
• The explicit consent of the data subject when required by law.

V. OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA

Data subjects may limit the use or disclosure of their personal data by submitting a request to privacidad@colektia.com in order to be included in COLEKTIA’s Exclusion List, ensuring that their data is not used for purposes other than those described in this Privacy Notice.

VI. DATA PROTECTION AND SECURITY MEASURES

COLEKTIA protects personal data processed by Colly in accordance with the principles established under Law 1581 of 2012 and its implementing regulations by implementing administrative, technical, and physical safeguards designed to prevent loss, alteration, unauthorized access, or misuse.

These measures include:

• Access controls
• Data encryption
• Database segmentation
• Activity monitoring
• Incident response protocols
• Business continuity procedures
• Security breach notification procedures when required by law

VII. DATA TRANSFERS AND DATA SUBJECT RIGHTS

Personal data may be shared with:

• Clients and creditors that engage COLEKTIA for collections services.
• Technology service providers operating under agreements that ensure confidentiality and regulatory compliance.
• Competent authorities when required by applicable law.

No transfers will be carried out without a legal basis or consent where consent is required.

Data subjects may exercise their rights of access, rectification, cancellation, and objection by sending a request to privacidad@colektia.com together with a copy of their official identification.

COLEKTIA will respond within a maximum period of 15 business days, in accordance with Law 1581 of 2012.

VIII. DATA OBTAINED FROM INDIRECT SOURCES

If personal data is obtained from public sources or third parties, such as creditor clients of COLEKTIA, the data subject will be informed of this Privacy Notice during the first contact before the data is used for collections purposes.

IX. CHANGES TO THIS PRIVACY NOTICE

COLEKTIA reserves the right to modify this Privacy Notice at any time to reflect regulatory, technical, or business changes.

Updates will be published through the usual communication channels and on the following website: www.colektia.com/privacy

X. USE OF COOKIES AND SIMILAR TECHNOLOGIES

When Colly interacts through websites, cookies and similar technologies may be used for analytics and service improvement purposes.

Data subjects may configure their browser settings to reject or delete cookies. However, disabling cookies may affect the functionality of certain services