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Data Processing Policy

Last updated: March 2026

PRO CORP S.A.S. (hereinafter "Pro Corp"), with registered address at Calle 127A #7-19, Office 301B, Centro Empresarial Acces, Bogotá, Colombia, and representative office at Calle Jorge Juan 30, Floor 1, 28001 Madrid, Spain, is committed to protecting the privacy and personal data of its users, clients, and collaborators in accordance with applicable regulations.

01Applicable Regulations

This policy complies with: (i) Colombian Law 1581 of 2012 and Decree 1377 of 2013 on Personal Data Protection; (ii) EU General Data Protection Regulation (GDPR) 2016/679; (iii) Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights Guarantee (LOPDGDD).

02Data Controller

PRO CORP S.A.S. Calle 127A #7-19, Office 301B Centro Empresarial Acces, Bogotá, Colombia Email: extranjeria@pro-corp.net Phone: +57 300 929 2911

03Data We Collect

We collect the following categories of personal data: • Identification data: full name, ID/passport number, nationality • Contact data: email, phone number, postal address • Professional data: company name, position, industry • Service data: immigration case details, corporate structuring information, investment preferences • Technical data: IP address, browser type, device information, navigation data • Communication data: messages sent through our contact forms and LIA chat assistant

04Purpose of Processing

Your personal data is processed for the following purposes: • Provision of legal, immigration, and corporate advisory services • Management of investment portfolio consultations • Communication about the status of your processes and cases • Sending relevant information about our services (with prior consent) • Compliance with legal and regulatory obligations • Improvement of our digital platform and user experience • Operation of our AI assistant LIA for customer support

05Legal Basis

The processing of your data is based on: • Contractual necessity: to provide the services you have requested • Legitimate interest: to improve our services and platform • Legal obligation: to comply with applicable regulations • Consent: for marketing communications and non-essential cookies

06International Transfers

Given our operations in Colombia and Spain, your data may be transferred internationally between our offices. These transfers are carried out with appropriate safeguards, including standard contractual clauses approved by the European Commission and compliance with Colombian data protection regulations.

07Data Retention

Personal data will be retained for the duration of the contractual relationship and, thereafter, for the legally required periods. For immigration and legal cases, data is retained for a minimum of 5 years after case closure as required by applicable regulations.

08Your Rights

You have the right to: • Access your personal data • Rectify inaccurate or incomplete data • Request deletion of your data • Object to or restrict processing • Data portability • Withdraw consent at any time To exercise these rights, contact us at extranjeria@pro-corp.net. We will respond within 15 business days (Colombia) or 30 calendar days (EU).

09Contact & Complaints

For inquiries about data processing: extranjeria@pro-corp.net You also have the right to file a complaint with the competent supervisory authority: • Colombia: Superintendencia de Industria y Comercio (SIC) • Spain: Agencia Española de Protección de Datos (AEPD)

© 2026 Pro Corp S.A.S. — extranjeria@pro-corp.net