TestKokoro Privacy Policy

This document contains the guidelines regarding the collection, use, disclosure and any type of processing of personal data of the Users of the Services provided by TestKokoro SPA (hereinafter, “TestKokoro” or “Kokoro”), through its website and its recruitment and personnel selection platform.

TestKokoro SPA is a company incorporated under the laws of the Republic of Chile:

This Policy applies to Users in all countries where TestKokoro provides services. The applicable legislation depends on the User’s place of residence:

• Users in Chile: Law 19.628 on Protection of Private Life and its amendments.

• Users in Colombia: Law 1581 of 2012, Decree 1377 of 2013 and Decree Único 1074 de 2015, in accordance with the Master Commercial Agreement signed with LeaderSearch S.A.S. (elempleo.com) as exclusive local partner.

• Other countries: applicable local legislation on personal data protection.

Specific section for Colombia: see Section 10 of this Policy, which applies complementarily and prevalently to Users residing in Colombia.

By registering on the platform, the User expressly authorizes TestKokoro to process their personal data in accordance with the purposes described below, and in compliance with the applicable legislation according to their country of residence.

Upon registration on the platform and during the provision of services, TestKokoro collects the following data from Users:

Important for Users in Colombia: the data described in section d) may be classified as sensitive data under Article 5 of Law 1581 of 2012 and require prior, express and informed authorization, in accordance with Article 6 of the same law. See Section 10 for details of the applicable regime.

Additionally, in some cases, certain personal data may be requested from the User in order to improve and personalize the Services and marketing campaigns. For the same reason, we may supplement the personal information provided with publicly available information from other sources, to the extent permitted by applicable law.

It is presumed that the data has been provided by its owner or by a person authorized by them, and that it is correct, complete, current and accurate. In the event of any change in personal information, the User is responsible for updating it in a timely manner.

TestKokoro is not responsible for the use that third parties may make of the information that is published or contained on the website and platform, beyond its legal obligations as data controller or processor, as applicable.

The personal data of Users is used for the following purposes related to the provision of recruitment and personnel selection Services:

a) Processing of registration and creation of the User account.

b) Publication of job postings on selected job portals.

c) Collection and automated selection of information of candidate Users.

d) Conducting psychometric, psychological, competency, vocational and other similar evaluations.

e) Generation and delivery of evaluation reports to the employer User or contracting company.

f) Communication and interaction with Users.

g) Processing and validation of payments made by the employer User.

h) Response to Users’ inquiries and complaints.

i) Monitoring of User activity when using the Services, in order to personalize and improve the Services.

j) Sending promotions, discounts, offers, surveys and other communications related to the marketing of the Services. The User may unsubscribe at any time.

k) Aggregated and anonymized analysis of User data.

l) Improvement of User experience and evaluation models (always based on anonymized data).

m) Compliance with legal, accounting, tax and contractual obligations.

n) Attention to requests from competent authorities.

Likewise, TestKokoro may communicate to third parties the personal data of Users when access to or use of such information is necessary for the following purposes:

a) To comply with a judicial resolution, a request from a competent authority, or a legal or regulatory provision.

b) To ensure compliance with the Terms and Conditions and this Privacy Policy, including the investigation of possible infringements.

c) To detect, prevent or address illegal or allegedly illegal activities, and technical or security issues.

d) To protect the rights, property or safety of TestKokoro and its Users, as required or permitted by applicable law.

e) Aggregated and anonymized analysis of User data.

f) To inform the employer User of the results of all types of evaluations carried out by the candidate User, through the TestKokoro website and platform.

TestKokoro will not sell personal data to third parties nor transfer it for purposes other than those stated in this Policy.

For the provision of the Services, TestKokoro may contract other companies or providers (hereinafter, the “Providers”) to assist in the provision of the Services, in accordance with the purposes described above. In this regard, TestKokoro may contract Providers of services such as:

• Psycholabor evaluations and consulting
• Marketing and communications
• Cloud-based technological infrastructure
• IT and development services
• Payment processing and payment methods
• Customer support
• Data analytics and telemetry
• Satisfaction surveys

Providers may have access to Users’ personal data and are obliged to use and process the data exclusively for the purposes for which they were transferred, and in accordance with this Privacy Policy. It is strictly prohibited for Providers to use, communicate or process personal data for any other purpose, except with the express consent of the Users.

In particular, candidate Users expressly authorize the processing of their personal data for the performance of psycholabor evaluations and any other type of evaluation regarding their aptitudes, capabilities and suitability, and the communication of their results to the employer User.

• Colombia: LeaderSearch S.A.S. (NIT 830.065.157-8), operator of elempleo.com, acts as exclusive commercial partner and, in accordance with the Master Agreement signed on December 29, 2025, as Data Controller under Law 1581 of 2012. TestKokoro acts as Data Processor of the data transmitted by LeaderSearch S.A.S.

• Chile and other countries: TestKokoro acts directly as Data Controller in accordance with applicable local legislation.

The User expressly authorizes that their data be communicated outside their country of residence to any country where TestKokoro has facilities, servers or activities with Providers.

The destination countries may have a different level of data protection than that of the User’s country of residence. TestKokoro guarantees that it will apply technical and organizational measures equivalent or superior to those required by local regulations, regardless of the physical location of the processing.

For Users in Colombia: international transfer is carried out under the Personal Data Transfer Agreement (Annex 4 of the Master Agreement) signed with LeaderSearch S.A.S., in accordance with Articles 24 and 25 of Decree 1377 of 2013 and Article 2.2.2.25.5.1 of Decree 1074 of 2015. See Section 10.

In the event that TestKokoro is subject to a reorganization, restructuring, merger, sale or any other transfer of assets, it reserves the right to transfer the information —including Users’ personal data— provided that the recipient undertakes to process such personal data in accordance with this Privacy Policy or equivalent standards.

As stated in the Terms and Conditions, during the provision of the Services, the employer User may contract additional services that are provided by third parties, in which case these third parties may collect and process Users’ data in connection with the provision of their services.

In this case, the User is solely responsible for reviewing the terms and conditions and privacy policies of such third parties, and TestKokoro shall not be responsible for their information handling practices.

TestKokoro uses administrative, technical, physical and management measures necessary for the security and confidentiality of information, especially Users’ personal data. These measures include:

• Encryption in transit using TLS 1.2 or higher
• Encryption at rest with AES-256 standards for sensitive data
• Role-based access control with the principle of least privilege
• Audit logs regarding access to personal information
• Multi-factor authentication for internal staff with access to databases
• Periodic backups and business continuity plans
• Regular staff training in data protection
• Contractual confidentiality obligations for staff and providers

Notwithstanding the foregoing, no security system is infallible, therefore TestKokoro cannot absolutely guarantee the security or confidentiality of information. TestKokoro shall not assume responsibility for breaches caused by malicious attacks or the use of tools intended to obtain personal data fraudulently, beyond the diligent fulfillment of its legal obligations.

It is the User’s responsibility to protect the confidentiality of their access information, restrict access to their devices and adopt basic security measures (log out on public devices, use secure passwords, do not share credentials).

The User expressly consents to being notified of any breach or unauthorized access to their personal data that may occur in connection with the provision of the Services, within the timeframes and terms required by applicable law.

For Users in Colombia: TestKokoro will notify LeaderSearch S.A.S. within 72 hours of becoming aware of the incident (24 hours for high-impact incidents), in accordance with the Transfer Agreement and External Circular 002/2015 of the SIC.

TestKokoro guarantees Users the free exercise of their rights of access, modification, cancellation and blocking of their personal data, in accordance with Law 19.628.

TestKokoro guarantees Users the free exercise of the following rights, in accordance with Article 8 of Law 1581 of 2012:

a) To know, update and rectify their personal data

b) To request proof of the authorization granted

c) To be informed about the use given to their data

d) To file complaints before the Superintendence of Industry and Commerce (SIC)

e) To revoke authorization and/or request deletion of the data

f) To access their personal data free of charge (at least once per month at no cost)

The applicable response times are:

Users may submit requests by sending an email to:

• General channel (all countries): legales@testkokoro.com

• Operational support channel: soporte@testkokoro.com

• Colombia — main channel (Controller LeaderSearch): protecciondatos@elempleo.com

• Colombia — secondary channel (Processor TestKokoro): legales@testkokoro.com

The request must include identification of the Data Subject, a clear description of the request and the preferred response channel.

TestKokoro uses cookies and similar technologies to:

• Facilitate access and navigation on the platform
• Analyze user behavior and usage patterns
• Personalize the user experience
• Display advertising and marketing content

The User may configure their browser to reject cookies or notify their use. However, some functionalities of the platform may be affected.

Personal data will be stored for as long as necessary to fulfill the purposes described in this Policy, and in particular:

• While a contractual relationship exists with the User

• For the time necessary to comply with legal, accounting and tax obligations

• For the periods required for the defense against possible legal claims

Once these periods have elapsed, the data will be deleted or anonymized in a secure manner.

TestKokoro reserves the right to modify this Privacy Policy at any time.

In the event of substantial changes, Users will be notified through the platform or by email, prior to their entry into force.

Continued use of the Services after the notification of changes implies acceptance of the updated Policy.

This section applies in a complementary and prevailing manner to Users residing in the Republic of Colombia.

Law 1581 of 2012
Decree 1377 of 2013
Decree 1074 of 2015
External Circular 002 of 2015 of the SIC

Psychometric, personality and competency results constitute sensitive data.

Their processing requires prior, express and informed authorization, which may be revoked at any time.

Refusal to provide this data may imply the impossibility of continuing in the selection process.

TestKokoro does not intentionally collect data from minors.

If this occurs, it will require authorization from parents or legal guardians, and the processing will respect the best interest of the minor.

Superintendence of Industry and Commerce (SIC)

Email: habeasdata@sic.gov.co

This Policy is governed by the applicable legislation according to the User’s country of residence:

• Chile: Law 19.628

• Colombia: Law 1581 and complementary regulations

• Other countries: applicable local legislation

LeaderSearch S.A.S. (exclusive partner Colombia) - Data protection: protecciondatos@elempleo.com - Phone: 601 294 0100 ext. 2012 - Address: Diagonal 44 No 68B-65, Bogotá D.C., Colombia