Cedeño & Méndez is a company duly constituted and existing under the laws of the Republic of Panama, with domicile in Urbanization Obarrio, Calle 60, PH Obarrio 60, Floor 13, Panama City, Panama, with contact mail protecciondedatos@cedeymen.com (hereinafter the Company, ours, we). We want you to be familiar with how we collect, use and disclose your personal data. This Privacy Notice is designed to help you understand our privacy practices, including what personal data we collect, why we collect it, what we do with it, how we protect it, and your individual rights.

 

We appreciate your interest in our Company and our products. By accessing or using the www.cedeymen.com site and/or its related channels (hereinafter referred to as the Web), including but not limited to online services, mobile Applications and other social media platforms (each a "Site"), whether automated or not, you agree that you will be bound by these Terms of Use and the terms and conditions referred to below or otherwise may apply to specific areas of the Site. Please read these Terms of Use before using the Site.

 

Your privacy is of real importance to us. You have shown your confidence in us through interaction with the Company's Pages and we value that trust. This means we are committed to protecting your privacy at all times.

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PRIVACY PRINCIPLES FOR CUSTOMERS AND SUPPLIERS

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At Cedeño & Méndez (business group formed by Administradora C&M, S.A., Cedeño & Méndez, Registros Centroamericanos, S.A. and C&M Accounting & Tax Solutions Solutions) we are committed to the protection of information and, above all, of personal data provided to us by our customers and suppliers, which is why in this document you will find the principles under which we work with respect to your data.

The principles indicated here cover the parameters established in the legislation of the Republic of Panama and cover a little more to safeguard the information provided.

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Personal data may be collected, used, transferred, or processed for one or more of the following purposes:

• Legitimate use of the contractual relationship between the parties, including, but not limited to, the execution of contracts or agreements with customers and suppliers

• Registration, execution and cancellation of service, product and/or material agreements

• Communications with commercial information, marketing, sales, or promotions

• Account management

• Customer Service

• Finance and accounting

• Shopping

• Internal control and management

• Investment management

• External communications

• Legal procedures and government requests

• Partnerships, acquisitions, joint ventures, conglomerates or similar

• Intellectual property management

• Executive processes and internal management, including processing necessary for activities such as corporate asset management, audits, investigations, and implementation of internal controls

• Health and safety, including activities necessary for the protection of the health and safety of employees and authentication of customers, visitors, and suppliers on access controls

• Compliance with legal obligations

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If we have an activity that has not been listed or that express consent is required by law, such consent will be requested individually and expressly prior to obtaining the data, for this we will inform you about the use that will be given to the data and all relevant details indicated by law.

 

The owner of the data has at all times the right to accept or deny such consent and to exercise their ARCO rights, in which case the use of the data will cease, or the information will not be collected.

 

The data collected will be used only for the purpose on which they have been acquired; however, it may be the case that they are used for secondary purposes if they are related. These secondary uses may be for the transfer of information to our records, internal audits or investigations, implementation of internal controls, statistics, historical investigations, records, legal processes, acquisition of consultancy services, insurance management.

 

It may also be the case where we obtain sensitive information, such data will be used and collected only when it is necessary for the business purpose being executed and will be processed only when:

• The owner has given his express consent

• By providing services to the holder

• When the sensitive data have been given regarding the commercial relationship between the parties and related to the service offered

• As accepted by national law

• For execution of legal processes

• For access control to our facilities

• To protect a legitimate interest

• By national or international legal requirement

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It is important to note that the data obtained will be stored for the duration of the contractual relationship and for the legal period applicable and established in national legislation. After this period the data will be deleted from our files as indicated in national legislation. While the data is in our Cedeno & Mendez database, we will keep it updated, however, it is the responsibility of the data holder to provide the correct information and indicate if any changes are made so that we can update our records.

 

Against the above mentioned, the data holder may exercise the rights of access, rectification, opposition, portability, and cancellation of personal data, by means of a communication to protecciondedatos@cedeymen.com.

 

It is important to indicate that the personal information provided may be shared with third parties affiliated with the company, as well as companies of the same economic group. It should be noted that this information will be shared with the necessary third parties and only if it is necessary to comply with the above actions and following the required security measures.

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We may need to share information with:

• Service providers: Third parties contracted by the company to execute services such as computer systems, administrative support, among others.

• Government authorities: When required by law it will be necessary to share data with the authorities that request it or for procedures required by the company.

• Advisors, consultants, similar: It may be required to share data with external advisors or consultants for specific cases or for the execution of the contracted services.

• Other providers: Information may be shared if necessary for corporate, banking, insurance, or other transactions.

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It may be the case that the information is shared with an international entity or to offices in other jurisdictions for the purpose of complying with the actions indicated herein. If that is the case, we will only do so to countries that maintain the same level of protection and security as required by law in the Republic of Panama. It will also be possible to exchange information between companies of our economic group in different countries, for which we comply with the protection requested by Panamanian legislation and an additional level to ensure that all information is secure at all times.

 

It should be considered that the data will remain stored as long as there is a relationship between the parties and subsequently the time required by law. If you require more information, you wish to exercise your ARCO rights or need to review the personal information we have in our files, you can do so by sending a communication to protecciondedatos@cedeymen.com. If you do not get a timely response, you may contact our data protection officer at the following address jmedina@cedeymen.com (Jineth Medina - Data Collection Officer).

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TYPE OF INFORMATION COLLECTED, TIME AND FORM OF PROTECTION

 

By Personal Data we understand that we refer to information related to you and that it allows you to identify you, either directly or in combination with other information we may have. Such data may be collected when you register for marketing communications and promotions, participation in draws, contests and other similar activities. Also, when making comments, questions, ratings and reviews of products online or when interacting through our communications channel or contacts. Interaction can also occur through our social networks and blogs by posting likes in a post, sharing information, posting comments, and submitting comments and/or reviews. In this regard, your personal data will be processed by a third party that offers digital marketing services to the Company and therefore will have a copy of your public interactions with us.

 

The use given to this data is intended to improve our products or services and improve your user experience, but also to have an overview of the category of audiences who are interested in certain products or services.

In the course of providing services, we may collect information that may disclose your racial or ethnic origin, your physical or mental health, your religious beliefs, or the alleged perpetration or conviction for criminal offenses. Such information is considered “confidential personal data”. Such data will only be collected when you have given your explicit consent, when necessary, or when you have deliberately made that information public. In order to protect your information, we seek to use reasonable organizational, technical and administrative measures to protect your personal data within our organization. Unfortunately, data transmission or storage system cannot be guaranteed to be 100% secure. If you have arguments to believe that your interaction with us is no longer secure, notify us immediately at protecciondedatos@cedeymen.com. Your data will be kept for as long as necessary or permitted for the purposes for which it was collected. The criteria we use to determine our retention periods include: The period in which we have a continuing relationship with you, if there is a legal imperative to which we are subject; or if retention is recommended under our legal position (for example, in relation to applicable limitation periods, litigation or regulatory investigations). If you wish, you may submit a request to rectify, delete, restrict, refuse or access the processing of personal data you have provided us previously, or submit a request to receive an electronic copy of your personal data for transmission to another company (to the extent that applicable law allows this right of data portability), you may write to us at protecciondedatos@cedeymen.com. We will respond to your request in accordance with applicable law.

 

We appreciate that, at the time of your request, you are as clear and explicit as possible indicating what actions you wish to take regarding your data. Please note that we will only be able to perform the actions you expressly have indicated to us and your identity will need to be verified after the action requested is executed.

 

COOKIES POLICIES

 

"Cookies" are small data files stored on your device at the request of a website. Cookies allow a web page, among other things, to store and retrieve information about a user's or computer's browsing habits and, depending on the information they contain and how they use your computer, they can be used to recognize the user. Cookies may also be used to improve your experience on the Site (for example by storing your username) and/or obtaining general use and aggregated statistical information. Most browsers can be configured to detect cookies and will give you an opportunity to decline cookies, but rejecting cookies may, in some cases, limit your use of the Site or its features.

 

The first purpose of Cookies is to provide the User with faster access to the selected Services. In addition, Cookies personalize services and advertising, facilitating and offering you information that is of interest to you or that may be of interest to you, in response to the use you make of the Web.

 

This website uses Cookies to personalize and facilitate the user's navigation as much as possible. Cookies are only associated with an anonymous user and their computer and do not provide references that allow them to deduce their personal data. You can configure your browser to notify and reject the installation of Cookies sent by the Web, without affecting the user's ability to access the contents. However, we would like to point out that, in any case, the quality of operation of the Website may decrease.

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"Local shared objects," such as "Flash cookies," can be stored on your computer or device using a media player or other software installed on your computer or device. Local shared objects work a lot like cookies, but they can't be handled in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to handle them by configuring software.

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The above tracking technologies may be deployed by us or our service providers on our behalf. We may use third-party web beacons to help analyze where visitors go and what they do during their visit to our website. By using our site, you agree to our use of these tracking technologies.

 

SOCIAL MEDIA

 

We will be able to maintain presence in various social networks and blogging platforms, such as Facebook, Instagram, Twitter, Youtube, Wordpress, Google, Pinterest, and similar. We may also incorporate some third-party social media features or use third-party platforms intended to post or operate the Site or part thereof. Through these platforms and features, we receive some personal data and some information about your use of the site, and this privacy policy applies to that information as well. In addition, some of our social media providers or blog platforms (such as, but not limited to, Facebook, Instagram, Twitter, YouTube, Wordpress, Google and Pinterest) have their own privacy policies that explain how third parties provide services such as they may collect, use and protect your information.

 

THIRD PARTY ADVERTISING

 

Please note that third party ads, such as banners, steals pages and other advertising formats may appear on the Web and/or its social networks. These ads, while permitted by the Company, may contain links to other web pages not controlled by the Company. If a user clicks on an ad, the advertiser will automatically receive the IP address. Likewise, these third-party advertisers may also download cookies to your computer or use other technologies to measure the effectiveness of your ads and personalize your content. This allows the ad network to recognize your team every time you send an ad in order to measure its effectiveness and personalize its content. The Company does not have access to or control over cookies that third party advertisers may download, so we recommend that you carefully read the security and data processing policies of these third party advertisers. In any event, the Company warrants that third parties do not have access to user information stored on the Web, nor are information provided to them, unless the user voluntarily decides to share it with them.

 

MODIFICATIONS TO THIS PRIVACY POLICY AND TERMS OF USE

 

The use of the Website and any dispute arising from it are subject to this privacy policy and conditions of use.

The Company reserves the right to modify or update this privacy policy and terms of use at any time and without prior notice. Changes to it will be posted on this website so that you can always know the latest version. When the Company makes a change, it will publish it in this section of privacy policy and conditions of use and will indicate the new effective date of the rules at the top of this page. Therefore, users are advised to check it regularly.

Likewise, Company will not use or communicate any personal data provided by you under this Privacy Policy for any other purpose as reported in this Policy, without first informing you and giving you the opportunity to object to such modifications regarding the use or communication of your personal data.

 

Applicable regulations

All contents found on the Web belong to Cedeño & Méndez and are protected by copyright and other intellectual property rights. If any material is required, it must be authorized in advance for use. The relationship between users and the company is governed by this privacy policy and terms of use and by local laws applicable in each case. For all legal purposes, the law of the Republic of Panama shall apply.