DATA PROTECTION POLICY

I.INTRODUCTION:

At SURECO & Partners, we are firmly committed to compliance with national standards (Republic of Panama) and the incorporation of good regional and/or international practices regarding data protection. We recognize the importance of safeguarding the personal data and commercial information of our clients, collaborators, consultants and partners.

In an increasingly interconnected world, where information has become a critical asset, responsible management of personal data is essential to preserve trust and integrity in all business relationships.

The implementation of this policy is not simply compliance with a legal obligation, but rather an expression of our commitment to excellence in the internal and external management of the organization.

II.POLICY OBJECTIVE:

Safeguard the privacy and security of the personal data that SURECO collects, uses, processes and stores, and establish the guidelines that will guide its operations in accordance with the principles of transparency, consent, and respect for the privacy rights of the owner.

III.SCOPE OF THE POLICY:

This policy covers all relevant actors related to the organization. It is important that all members of SURECO & Partners are familiar with this policy and apply it in their daily activities. Furthermore, to the extent applicable, the policy also extends to our own clients, who must be aware of the established principles and commitments.

For the purposes of this policy, Personal Information will be called any data provided, directly or indirectly, by any natural or legal person (Owner) to SURECO & Partners in the course or execution of its corporate and commercial purpose. The collection, treatment, use and storage of Confidential Information will be carried out in accordance with the Confidentiality and Non-Disclosure Agreements signed by SURECO & Partners with its respective consultants, collaborators, clients, suppliers, partners and others.

 

Under no circumstances does SURECO collect, use, process or store sensitive information , which includes: racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, social organizations, human rights organizations or those that promote interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data related to health, sexual life and biometric data.

IV.PRINCIPLES OF ACTION:

At SURECO & Partners we are committed to following the following principles of action to appropriately collect, use, process and store personal information.

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  1. Freedom and truthfulness.

SURECO will collect, use, process and store personal information only with the prior, express and informed consent of the Owner. Personal information may not be obtained or disclosed without prior authorization from the Owner and except for purposes previously agreed upon with the Owner for the execution of the corporate purpose and the ordinary course of business of SURECO.

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For its part, the personal information that is processed must be true, complete, updated, verifiable and understandable. The processing of fragmented or misleading personal information is prohibited. In this sense:

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  1. The Owner will refrain from making false or otherwise erroneous statements of its connection/relationship with a natural or legal person. Likewise, you will refrain from providing information of an offensive or aggravating nature or that contains threats, harm or mechanisms to capture or distort information.
  2. The Owner may not send an email message, transmit or otherwise provide illegal, harmful, abusive, hostile, defamatory, discriminatory, vulgar and libelous content to SURECO and on behalf of SURECO.
  3. The Owner must not collect or promulgate personal information or information related to other users of the website. Nor must it collect and/or promulgate information disclosed through it or that, failing that, is found in SURECO's own information systems.

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SURECO will not be responsible for any deletion resulting from inaccurate, false, deficient or incomplete Personal Information provided by the Owner.

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  1. Purpose

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SURECO collects, uses, processes and stores the personal information provided according to the purposes agreed with the Owner. Under no circumstances does SURECO process personal information for commercial purposes other than those of the execution of SURECO's corporate purpose and the ordinary course of its business. Nor will it make personal information available on the Internet or other means of dissemination or mass communication, except with the prior authorization of the Owner for certain types of data and purposes and/or if access is technically controllable to provide knowledge restricted only to the owners or authorized third parties.

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SURECO does not transfer or share the Owners' information to third parties for commercial purposes other than those of the execution of SURECO's corporate purpose and the regular course of its business, or any other purpose not previously agreed/notified with the Owner. Personal Information will only be transferred to third parties, for example, when one of the following causes arises:

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  1. By legal obligation or power.
  2. When it is necessary to claim or exercise rights or defend legal actions and there is no reason to assume that the Party has a primary interest worthy of protection in that your data is not disclosed.
  3. At the request of a competent authority.

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Likewise, SURECO only retains and stores the Owner's Personal Information for as long as necessary to fulfill the purposes for which it was collected. The applicable retention period depends on the nature of the information collected and its purpose.

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  3.   Legality

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This Data Protection Policy is governed by the laws of the Republic of Panama, the country where SURECO & Partners is legally constituted, especially Executive Decree 285 of 2021. In Panama, the authority that regulates data protection at the national level personal information is the National Authority for Transparency and Access to Information “ANTAI”. For any official contact for the protection of personal data, go to the portal of the aforementioned entity.

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Any dispute or conflict generated by the collection, use, processing and storage of personal information will privilege the jurisdiction of the Republic of Panama, without having effect on the conflict with other laws of other countries or state of current residence of the Owner.

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4.    Protection.

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The Owner of the Personal Information may exercise their rights of access, rectification, opposition and cancellation of the processing of their Personal Information. The rights in relation to personal data are summarized in:

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  1. Access: Every Owner has the right to obtain Personal Information that is stored or subject to processing in databases, and know the purpose and origin for which it was collected. It includes the right of portability, by which the Owner has the right to request a copy of the personal data that SURECO has about the User. Exceptions apply, such as the case where providing said informatio
  2. Rectification: The Owner has the right to inform if their Personal Information is not accurate or has changed, so that SURECO keeps the Personal Information updated, accurate, and complete.
  3. Opposition: The Owner has the right to oppose the processing of his/her Personal Information and request SURCO to block, delete or restrict it.
  4. Cancellation or Deletion: The Owner has the right to delete his/her Personal Information when the data is no longer necessary for the purposes for which it was collected, or in the cases indicated by law.

Paragraph 1. The exercise and materialization of these rights will be regulated as stipulated in articles 24 to 30 of Executive Decree 285 of 2021 - Republic of Panama, or any that repeals, modifies or adds it.

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Paragraph 2. When the processing of data is based on the consent of the Owner, the Owner may revoke it at any time, without this having retroactive effects. It is the Owner who is directly in charge of the respective rectification, opposition or cancellation of their Personal Information. To execute the process, it is necessary for it to identify itself and communicate what information it wishes to access, correct or delete, etc. to the email admin@surecoandpartners.com 

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Paragraph 3. SURECO reserves the right to not approve the processing of applications that, when studied: 1) DO NOT meet the minimum specifications as established in the standards that regulate the matter. For example, to exercise the right to rectification, the User must indicate in the request what data it refers to and the correction to be made. As well as accompanying the request with supporting documentation; 2) some of the exceptions to the exercise of the right of cancellation of the law that regulates the matter are incurred; 3) expose or compromise the informational privacy of our databases; 4) demand excessive technical effort.

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  1. Transparency

SURECO reserves the right to modify, clarify, add or dispense, unilaterally, at any time and without prior notice, of sections stipulated in this Policy, as deemed necessary, in order to comply with the pertinent legal requirements. Any changes to our Policy will be posted on this page.

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To make any suggestion, observation or concern regarding any of the aspects mentioned in this Data Processing Policy, you can contact S&P at the following physical address: PH Ocean One, Costa del Este, Panama, or virtually through the following email admin@surecoandpartners.com

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