Privacy Notice

This Privacy Notice is published in compliance with current regulations on personal data protection and as part of PRODEO PANAMÁ’s effective management of personal data. Through this document, PRODEO PANAMÁ aims to share with the owners of personal data the legitimate interest for collection, the purposes for which such data are requested, the data processing conducted, the protection measures used to ensure confidentiality, integrity, and availability, and the rights that data owners and/or their duly authorized representatives can exercise.
 

Data Controller

PRODEO PANAMÁ, as the Data Controller, expresses its commitment to protecting personal data and all personally identifiable information that could compromise personal integrity and/or privacy of its clients, while complying with the regulations in each jurisdiction where the organization operates.
 

Personal Data Collected

The personal data that PRODEO PANAMÁ collects and processes through the use of our official digital platforms and customer service channels include, or may include:
 

• Personal details (e.g., name, surname, identification information)

• Contact details (e.g., phone, email, mobile number)

• Professional details (e.g., company, position in the company, company contact)

• Transactional details (e.g., information on complaints or suggestions)
   

When required or permitted by law and local regulations, we monitor or record your communications with us, including messages and emails. We will use this information to verify instructions, for evidentiary purposes, to evaluate and improve our services to you, and for training and quality purposes.
 

We collect information and personal data from individuals who use our website, as well as our customer service platforms. If you use our customer service platform, PRODEO PANAMÁ may request certain personal data for proper identification. We also collect information from individuals visiting the website through the use of cookies and similar technology.
 

Purpose

The personal information managed by PRODEO PANAMÁ is requested from our clients solely for the proper provision of the services and products we offer, as well as to fulfill regulatory obligations.
 

Personal data will only be subjected to processing authorized by legislation, by the existing contractual relationship, or by prior, informed, and express authorization of the data holders. In general terms, personal data will be used for:
 

• Managing the relationship with our clients

• Sharing relevant information with our clients

• Managing clients’ products and services

• Processing clients’ instructions or requests

• Conducting research and analysis to improve our services
   

The personal data received under the terms and for the purposes mentioned in this Privacy Notice will not be shared without prior and express authorization from their holders with third parties unrelated to the products or services arising from the existing contractual relationship between the data holder and PRODEO PANAMÁ.
 

Exceptionally, personal data may be shared when required by a judicial order and/or mandate, or in cases established in applicable legislation and regulations, based on which a judicial or regulatory authority can and should have access to the personal data managed by PRODEO PANAMÁ. In such cases, access will only be allowed to the specific personal information described and related to the situation or matter being addressed, not to all personal information held by our organization.
 

Data Processing
 

Information is collected from forms filled out by the data owner when requesting information about a service and/or product, from electronic correspondence, and from some data collected from visits and/or forms on our website.
 

Processing

Personal data may be used to improve our websites and other digital applications available to our clients and to keep them informed of changes in our schedules and other services that should be communicated promptly for their benefit. In any case, our policy limits access to the managed personal data, and access is only permitted to employees and third parties who, for legitimate purposes, need access to that personal information.

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When providing a global service to our clients, personal data may be accessed from PRODEO PANAMÁ’s international offices when necessary to carry out a transaction with the client or to comply with legal or regulatory requirements imposed on us. Any other transfer of personal data must be authorized in advance and expressly by the data holder.

For the contracting of external hosting services, PRODEO PANAMÁ will require its providers to comply with equal or higher levels of personal data protection, and it will not host information on servers located in countries without data protection legislation similar to or higher than that established in the Republic of Panama. In any case, communication between our systems and external servers, whether within or outside the Republic of Panama, will be carried out using the highest industry information security standards.

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Data Retention and Disposal

Personal data will be retained based on the existing contractual relationship and within the legal and/or regulatory retention periods established for such purposes. After these periods expire, and within the time established by current legislation, personal data will be securely deleted from our systems and/or returned to their holders upon express request. Unless expressly authorized by the data holders, Law 81 of 2019 establishes that PRODEO PANAMÁ cannot process any stored personal data without a legitimate interest to do so.

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To ensure compliance with current regulations and based on recognized security standards, once the legitimate interest for processing personal data disappears, the documents containing personal data will be deleted. During the deletion process, the Personal Data will be extracted from the Databases and repositories used by PRODEO PANAMÁ's platforms and applications and securely stored to begin the secure deletion protocol, ensuring that recovery is impossible once deleted.

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Security

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Protecting personal data is a priority for PRODEO PANAMÁ, which is why technical and physical security measures have been implemented to safeguard the integrity and confidentiality of the personal data we manage. Our entire technological and operational infrastructure is equipped with security controls to minimize the risk of unauthorized access, both internal and external, and protocols that ensure a prompt response when a security event or incident is identified.

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In the event of any violation of PRODEO PANAMÁ's computer systems that could compromise the confidentiality of the information or personal data provided by you, PRODEO PANAMÁ commits to notifying the data holder as soon as the violation is discovered.

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Data Holders' Rights and Actions

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For the purposes of this Privacy Notice, the data holders are natural persons whose personal data is subject to processing by PRODEO PANAMÁ. The company guarantees the data holders' right to exercise the ARCOP Rights, so that, upon verification of their identity and legitimacy, and at no cost, they have complete access to their Personal Data through the exercise of ARCOP Rights.

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Rights

The current regulations in the Republic of Panama recognize and establish the rights of data holders, called ARCOP Rights (Access, Rectification, Cancellation, Objection, and Portability).

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Limitation of Liability for Social Networks and Instant Messaging Use

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Social networks and instant messaging applications are complementary platforms for sharing information and exchanging communication through digital means with clients and the general public. However, they are not under the responsibility of PRODEO PANAMÁ. Consequently, any information provided by users through these platforms does not constitute or form part of the Personal Data subject to protection by PRODEO PANAMÁ and remains the sole responsibility of the individual providing the information and the companies managing these platforms.

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Use of Social Networks

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PRODEO PANAMÁ may use these communication platforms as a complementary means of promoting products and services. Communications published through social networks are directed to the general public. The profiles that PRODEO PANAMÁ uses on social networks are open, and the channels offered by the companies managing these networks are used, making posts appear more frequently for certain types of clients based on the personal data processing authorizations given by users when subscribing to these networks.

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Use of Instant Messaging Applications

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PRODEO PANAMÁ may use these instant messaging platforms as a tool to streamline communication between employees and between employees and clients. However, since PRODEO PANAMÁ does not control the access and use of information by the company that owns the application, PRODEO PANAMÁ discourages its employees and clients from exchanging sensitive information and documents containing personal data through these networks. Such information should be shared through secure email or any other secure communication channel that PRODEO PANAMÁ may implement.

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Privacy Notice: Version 1.01 | Date of publication: May 9, 2024.