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Updated September 8, 2026

Personal data processing policy

This is a courtesy translation. The official text is the Spanish version, which prevails in case of any difference.

INVERSIONES CELEFREY S.A.S.
COLEGIO DE EDUCACIÓN TÉCNICA Y ACADÉMICA CÉLESTIN FREINET

Effective and Publication Date: September 2026

Article 1. General principles

INVERSIONES CELEFREY S.A.S. guarantees the protection of the fundamental rights to Habeas Data, privacy, personal intimacy, good name and image of its entire educational community. All operations involving the collection, storage, use, circulation or deletion of data shall be strictly governed by the principles of good faith, legality, purpose, freedom, truthfulness, transparency, restricted access and circulation, security and confidentiality.

Article 2. Identification of the data controller

Commercial Establishments and Affiliated Campuses:

  1. Bogotá Main Campus: Carrera 132 # 133-30 (Commercial Registration CCB No. 00673404).
  2. Ciudad Verde Campus (Soacha): Carrera 31 No. 17-201 (Commercial Registration CCB No. 03341324) | Authorized by Resolution No. 0471 of March 9, 2022.
  3. Physical facilities and annex campuses contractually associated with the company’s provision of educational services.

Article 3. Applicable legislation

  • Political Constitution of Colombia, Articles 15 and 20
  • Law 1581 of 2012 (General Personal Data Protection Regime)
  • Law 1266 of 2008 (Regulation of Financial, Credit and Commercial Data)
  • Law 2300 of 2023 (Regulation of channels and hours for commercial and collection contact).
  • Sole Regulatory Decree 1074 of 2015 and Decree 1377 of 2013
  • External Circulars No. 001 of 2024 and No. 002 of 2025 issued by the Superintendence of Industry and Commerce

Article 4. Processing of minors' data (children and adolescents)

In compliance with Law 1581 of 2012 and the Code on Childhood and Adolescence, the processing of data of children and adolescents shall strictly respond to and respect their Best Interest. The collection of their academic and school conduct information is optional and shall always require the prior, express and informed authorization of their parents, guardians or legal representatives. The processing of minors’ data that does not serve a strictly educational, institutional, safety or school well-being purpose is prohibited.

Article 5. Processing of sensitive data

Sensitive data in the School’s custody are those that affect the data subject’s privacy or whose improper use may give rise to discrimination. They shall be protected by enhanced security measures, and their authorization is strictly optional:

Biometric and Video Surveillance Data: Images and footage collected through the Closed-Circuit Television (CCTV) systems installed on the campus premises shall be used exclusively to guarantee the safety of students, staff and the institution’s property, infrastructure and facilities at all its campuses.

Health and Psychosocial Support Data: Basic medical histories, EPS/ARS records, allergies, and behavioral or psychological assessments and follow-ups carried out by the school counseling department. Their processing has the sole purpose of safeguarding the physical, mental and emotional integrity of students, activating medical emergency protocols or referring the minor to competent external professionals or entities when their health or rights are at risk.

Article 6. Purposes of data processing

The data subjects’ information shall be collected, stored, processed, compiled and exchanged in accordance with the following legitimate purposes registered with the supervisory authority:

A. Academic, Pedagogical and School Conduct Management

  • Formalize the processes of application, enrollment, renewal of school places and financial capacity forms.
  • Manage school records, report cards, attendance control, school planners, grades, extracurricular activities and the issuance of certificates at the preschool, elementary, secondary and upper secondary levels.
  • Enable, control, restrict and suspend user access to the PHIDIAS academic management platform and other institutional web applications.
    • Operational Paragraph: In accordance with the provisions of the enrollment contract, the institution is expressly authorized to apply the restriction or blocking of the platform’s complementary information modules in the event of late payment of mandatory tuition fees.
  • Carry out the pedagogical, cultural, sports and artistic activities set out in the Institutional Educational Project (P.E.I.), and grant scholarships and aid to students.

B. Administrative Management, Billing and Payment Collection Management (Adjusted to Law 2300 of 2023)

  • Issue invoices, statements of account and account summaries, and charge monthly tuition fees.
  • Transmit commercial databases and contact information to the partner firm EDUCAPITAL S.A.S. (NIT 901.460.723-8) for payment collection, administration, and pre-litigation and litigation debt collection processes.
  • Consult, process, report, update and delete debtors’ payment and credit behavior with the credit information bureaus Experian Colombia S.A. (DataCrédito), PROCRÉDITO and CIFIN S.A.S.
  • Contact Restriction (Law 2300 of 2023): Collection efforts and payment reminders shall be carried out using only one contact channel at a time from among those provided by the obligated parties. Such communications shall take place exclusively within the legally permitted hours: Monday to Friday from 7:00 a.m. to 7:00 p.m., and Saturdays from 8:00 a.m. to 3:00 p.m. Contact on Sundays and public holidays is prohibited. Likewise, the data of the personal references provided at enrollment shall under no circumstances be used to carry out collection activities.

C. Image and Copyright Management (Institutional Use and Dissemination)

  • Scope of Image Processing: Capture, store, fix, publish and broadcast the image rights (photographs and audiovisual productions/videos) of students, parents, foster parents and guardians, as well as the copyright, related rights and intellectual property arising from the minor’s school activities and literary or artistic productions.
  • Dissemination Media: This authorization extends to printed physical media (brochures, magazines, bulletin boards), electronic, digital, magnetic and optical media, data messages, the internet, intranet and the institution’s official corporate social networks (Facebook Fan Page, Instagram, the institution’s website), on a non-exclusive basis, free of charge, without geographic or territorial limitation, and without implying exclusivity with respect to third parties. The institution shall strictly comply with the current rules on authors’ moral rights, which shall remain with their holder.

Article 7. Adoption of cloud technologies (External Circular No. 002 of 2025)

Under the principle of Demonstrated Accountability, INVERSIONES CELEFREY S.A.S. declares that the cloud software implemented for school management (the PHIDIAS platform) and the electronic payment gateways comply with the information security standards required by the SIC. The transmission of data to these providers is covered by prior contractual agreements guaranteeing that the Data Processor will adopt preventive technical and administrative measures to prevent users’ information from being altered, lost, or consulted, used or accessed without authorization.

Article 8. Rights of data subjects (Simplified Procedure - External Circular No. 001 of 2024)

Parents, foster parents, guardians (on behalf of minors), alumni, joint and several co-debtors and employees have the right to know, consult, update and rectify their personal data held by the institution free of charge.

  • Right to Advertising or Commercial Exclusion: Data subjects have the right to partially revoke their authorization for marketing purposes, requiring the immediate exclusion of their data from the institution’s advertising or dissemination channels, without this affecting the continuity or provision of the contracted educational service.
  • Legal Impediment to Deletion: A request for data deletion or for revocation of the authorization shall not proceed when the debtor, co-debtor or data subject has a current legal or contractual obligation with the company (such as overdue financial balances, or historical academic records required by law by the Ministry of National Education or the Secretariats of Education).

Article 9. Procedure for exercising rights (Habeas Data)

Data subjects may exercise their rights through a simplified, free-of-charge procedure by sending a communication containing: the full name of the data subject and of the represented minor, identity documents, a clear description of the right to be exercised (to know, update, rectify or delete) and contact details for the response.

Enabled Reception Channels:

Maximum Response Times:

  • Inquiries: These shall be resolved within a maximum of ten (10) business days from their receipt.
  • Claims and Corrections: These shall be resolved within a maximum of fifteen (15) business days from their filing.

Integrated privacy notice

INVERSIONES CELEFREY S.A.S. (NIT 900.029.295-7) and its establishment COLEGIO DE EDUCACIÓN TÉCNICA Y ACADÉMICA CÉLESTIN FREINET hereby inform you that the personal data collected through this channel will be processed for academic, administrative, payment collection and debt collection purposes (in partnership with EDUCAPITAL S.A.S.), reporting to credit risk bureaus (DataCrédito, Procrédito, Cifin) and security. As a data subject, you have the right to know, update and rectify your information through the unified email addresses c.cf@celestinfreinet.edu.co and secretariaciudadverde@celestinfreinet.edu.co. Our updated Personal Data Processing Policy (Decision 001 of 2026), adjusted to Laws 1581 of 2012 and 2300 of 2023, can be consulted at www.celestinfreinet.edu.co.

INVERSIONES CELEFREY S.A.S.

In the city of Bogotá D.C., on the EIGHTH day of the month of September of the year 2026, the undersigned SORAYA GONZALEZ CIFUENTES, identified with C.C. No. 52.035.409 of Bogotá D.C., in my capacity as Manager and Legal Representative of the company INVERSIONES CELEFREY S.A.S., identified with NIT. 900.029.295-7, in accordance with the legal and statutory powers conferred by Colombian law and the company’s bylaws, hereby issue a formal decision based on the following:

Considerations

  1. That Article 15 of the Political Constitution of Colombia enshrines the constitutional right of all persons to know, update and rectify the information collected about them in data banks and in the files of public and private entities (Habeas Data).
  2. That pursuant to Law 1581 of 2012 and Sole Regulatory Decree 1074 of 2015, all legal entities acting as Controllers of personal data processing must develop, adopt and implement an Internal Manual of Policies and Procedures that guarantees due compliance with the law.
  3. That the company INVERSIONES CELEFREY S.A.S., as owner and operator of the educational establishments COLEGIO DE EDUCACIÓN TÉCNICA Y ACADÉMICA CÉLESTIN FREINET (Bogotá Campus and Soacha Campus - Ciudad Verde), collects, stores and manages databases containing information on minors, parents, debtors, teachers and contractors.
  4. That due to the country’s regulatory developments, which include the enactment of Law 2300 of 2023 on collection contact channels and the current External Circulars of the Superintendence of Industry and Commerce (SIC) on technological security and simplified procedures, it has become imperative to update the company’s Personal Data Processing Policy.

In view of the foregoing, the Legal Representation of the company:

Resolves

ARTICLE ONE. ADOPTION AND APPROVAL: To officially adopt and approve the new MANUAL OF POLICIES AND PROCEDURES FOR THE PROCESSING OF PERSONAL DATA OF INVERSIONES CELEFREY S.A.S., which shall govern the databases of all of the School’s campuses.

ARTICLE TWO. SCOPE OF APPLICATION: To provide that the guidelines contained in the adopted manual are mandatory and binding on all permanent employees, service providers, suppliers and third parties acting as data processors on behalf of the company.

ARTICLE THREE. PUBLICATION: To order the administrative and IT departments to immediately publish the full text of the policy on the institution’s official website (www.celestinfreinet.edu.co) to guarantee the principle of transparency toward the public and the data subjects.

ARTICLE FOUR. UPDATE OF CHANNELS AND CONTRACTS: To order the immediate substitution and replacement of the previous Habeas Data texts in the enrollment contracts for the 2027 school year and in employment contracts, as well as the enabling of the dedicated public-facing institutional email address.

ARTICLE FIVE. REGULATORY REPORTING: To authorize the company’s Data Protection Officer to report and update the corresponding changes in the application of the Registro Nacional de Bases de Datos (National Database Registry, RNBD) administered by the Superintendence of Industry and Commerce (SIC).

ARTICLE SIX. EFFECTIVE DATE: This decision and the policy adopted herein are effective as of the date of its signature and repeal any prior internal institutional provision or guideline to the contrary.

Issued in Bogotá D.C.; for the record and for strict compliance, it is signed on the Eighth of the month of September of 2026.

SORAYA GONZALEZ CIFUENTES
Legal Representative / Manager
INVERSIONES CELEFREY S.A.S.
C.C. 52.035.409 of Bogotá D.C.