Published: 1 October 2026
ANNEX A — GROUP ENTITY IDENTIFICATION SHEET
VALENCIA HOLDING GROUP
VHG Group Digital Legal Framework — Annex A
Identification of the Data Controller and of the entities adhering to the MLD-VHG
Version 1.0 — October 2026
Mandatory publication document — Public access
Language notice. The governing language of this instrument is Spanish. This English version is published as a courtesy translation. In the event of any discrepancy, and in particular with respect to data subjects domiciled in Colombia, the Spanish version prevails.
DOCUMENT CONTROL
| Field | Detail |
|---|---|
| Document | Annex A — Group Entity Identification Sheet |
| Master document | VHG Group Digital Legal Framework (MLD-VHG) |
| Instruments referring to this Annex | MLD-01 s. 1.2 and 2.2; MLD-02 s. 2.2; MLD-03 s. 2; MLD-04 s. 1.4 and 2.1 |
| Version | 1.0 |
| Effective date | 1 October 2026 |
| Governing language | Spanish |
| Status | In force |
Function of this Annex. All four instruments of the Framework refer to this sheet for the specific identification of the Data Controller. Its publication and upkeep is a condition of the Framework's enforceability vis-à-vis data subjects and supervisory authorities. This Annex is updated without any need to amend the published instruments whenever a new Adhering Entity joins or an identification detail changes.
1. Site operator and Data Controller
Valencia Holding Group LLC is the Group's Parent Company, the issuing unit of the Digital Legal Framework and the entity operating the corporate site https://vhg.capital. In that capacity it is the Data Controller for personal data collected through that site.
| Field | Detail |
|---|---|
| Corporate name | Valencia Holding Group LLC |
| Legal form | Limited Liability Company |
| Jurisdiction of incorporation | State of Delaware, United States of America |
| Status within the Group | Parent Company — controlling entity |
| Status vis-à-vis data subjects | Data Controller |
| Digital platform operated | https://vhg.capital |
| Domicile | Delaware, United States of America |
| Address for judicial and administrative service | Delaware, United States of America |
| Designated formal channel for service | info@vhg.capital |
| Single channel for contact and exercise of rights | info@vhg.capital |
| Telephone | Not published. Service is provided through the designated electronic channel |
| Service hours | Permanent electronic intake. Response within the statutory periods, counted in business days |
| Area responsible for requests, enquiries and complaints | VHG Group Data Protection Office |
| Tax identification (EIN) | Withheld from publication. Held in the internal register and disclosed to any authority so requiring |
| Corporate registration | Delaware Division of Corporations. Held in the internal register |
| Applicable supervisory authorities | United States: Federal Trade Commission. Colombia: Superintendency of Industry and Commerce — Delegate Office for the Protection of Personal Data |
Regarding the address for service. The VHG Group publishes its jurisdiction of domicile and expressly designates the mailbox info@vhg.capital as the formal channel for receiving notices, requests from authorities and requests to exercise data subject rights. The registered agent's full physical address is held in the internal register and is supplied to any authority, or to any data subject demonstrating a legitimate interest, upon request through that channel.
2. Adhering Entities
The following companies are Group subsidiaries and become subject to the Framework upon executing the Deed of Adhesion in Annex E. Each is an autonomous Data Controller in respect of the databases whose purposes and means it determines.
| Field | Valencia Capital Group | Valencia Investment Group |
|---|---|---|
| Name | Valencia Capital Group S.A.S. | Valencia Investment Group S.A.S. |
| Abbreviation | VCG | VIG |
| Legal form | Simplified Stock Corporation — Colombian Law 1258 of 2008 | Simplified Stock Corporation — Colombian Law 1258 of 2008 |
| Jurisdiction of incorporation | Colombia | Colombia |
| Registered office | Medellín, Antioquia, Colombia | Medellín, Antioquia, Colombia |
| Tax ID (NIT) | Held in the internal register. Added to this sheet upon adhesion | Held in the internal register. Added to this sheet upon adhesion |
| Status within the Group | Adhering Entity — subsidiary | Adhering Entity — subsidiary |
| Own digital platform | None. Its institutional information is published at https://vhg.capital | None. Its institutional information is published at https://vhg.capital |
| Channel for contact and exercise of rights | info@vhg.capital | info@vhg.capital |
| Supervisory authority | Superintendency of Industry and Commerce — Delegate Office for the Protection of Personal Data | Superintendency of Industry and Commerce — Delegate Office for the Protection of Personal Data |
| Adhesion status | Pending execution of the Annex E Deed | Pending execution of the Annex E Deed |
Illustrative character. This list is not exhaustive. Any other affiliate, subsidiary, company, brand or business unit that may in future join the Group, be incorporated by it, or come under its direct or indirect control — within the meaning of Article 261 of the Colombian Commercial Code — joins the Framework by executing the Deed of Adhesion, requiring only an update to this sheet and no amendment to the published instruments.
3. Group Data Protection Office
| Field | Detail |
|---|---|
| Name | VHG Group Data Protection Office |
| Nature | Framework governance function with functional independence |
| Scope | All VHG Group entities |
| Contact channel | info@vhg.capital |
| Functions | Maintaining, interpreting and updating the Framework; coordinating and verifying its implementation; advising on impact assessments; consolidating incident reporting; acting as interlocutor with supervisory authorities; presenting the annual compliance report; approving Adhering Entity supplements |
4. Intellectual property — registration status
| Distinctive sign | Jurisdiction | Status | Basis invoked |
|---|---|---|---|
| VHG Group distinctive signs | Colombia | Pending registration before the Superintendency of Industry and Commerce | Until registration is granted, the Group asserts no trademark exclusivity and reserves unfair-competition actions |
| VHG Group distinctive signs | United States | Pending | Until registration is granted, the Group asserts no trademark exclusivity |
| Site content, text, designs and software | All | Protected without registration | Article 52 of Andean Decision 351 of 1993 and the Berne Convention |
Warning. Colombia and the Andean Community operate an attributive system: the exclusive right to a trademark arises from registration, under Article 154 of Andean Decision 486 of 2000. Publicly asserting an exclusivity not yet constituted exposes the Group to a claim of misleading representation. This sheet is updated upon the grant of each registration.
5. National Database Register
| Entity | Exceeds 100,000 UVT in total assets | Registration required | Last verification |
|---|---|---|---|
| Valencia Holding Group LLC | Not applicable — entity not domiciled in Colombia | No | 1 October 2026 |
| Valencia Capital Group S.A.S. | No | No | 1 October 2026 |
| Valencia Investment Group S.A.S. | No | No | 1 October 2026 |
The Data Protection Office verifies this table annually, within one month of approval of each entity's financial statements, in accordance with section 16 of instrument MLD-04, and documents the verification whether or not the threshold is exceeded.
6. Processing destinations and international transfers
| Destination | Nature of the flow | Adequacy status | Basis |
|---|---|---|---|
| Colombia | Processing by the Adhering Entities | Jurisdiction of origin | Not applicable |
| United States of America | Site hosting and corporate email | Declared adequate by External Circular 005 of 2017 of the SIC | Article 26 of Law 1581 of 2012 |
The VHG Group carries out no transfers or transmissions to jurisdictions not declared adequate. Enabling any flow to a different destination requires the Data Protection Office's prior documented verification of its basis, in accordance with section 13 of instrument MLD-04.
7. Updating this sheet
This sheet is updated, without any need to amend the published instruments, whenever: a new Adhering Entity joins; an identification detail of any entity changes; a trademark registration is granted or refused; an entity exceeds the RNBD threshold; or a new processing destination is enabled.
Updating is the responsibility of the Group Data Protection Office, which records the date and reason for each change.
| Version | Date | Reason |
|---|---|---|
| 1.0 | 1 October 2026 | Initial issuance |
END OF ANNEX A
Valencia Holding Group — VHG Group Digital Legal Framework
Annex A — Entity Identification Sheet | Version 1.0 | Governing language: Spanish