We may modify our Privacy Notice at any time and at our discretion and/or as a result of a change in the regulations on the protection of personal data. Any changes will be notified to you, prior to the start of the new treatment activities.

Personal data is defined by the personal data legislation as any information concerning natural persons, which identifies them or makes them identifiable, among these you can find data such as names, surnames, telephone number, email, or any other data that may identify it directly or indirectly.

As a result of our activity, we collect personal data for the exercise of our legal services and obligations, from a previous stage of quotation until the moment of contracting. We typically collect personal data as follows:

• As part of our customer acquisition and acceptance processes
• As part of the acceptance of our services.
• When you or any other company request a service or legal assistance
• When you or your company provide services to us or refer a client to us
• When you send a comment through our contact methods such as our website, social networks, LinkedIn, phone call and any similar means

Generally, we will need you to provide us with personal data in order to legally assist you at any stage, pre-contractual, contractual or post-contractual. However, in some cases we may obtain your data through third-party resources, such as online search servers or through databases that are in the public domain, as defined in the regulations on personal data

The personal data that we typically collect and process are the following:

• The personal data that we collect for the fulfillment of our processes for retention and hiring of clients, including all the personal data necessary for quotes, due diligence forms, engagement letters, billing and any other document or information that is necessary for you to provide for these purposes.
• Personal data that is necessary to collect and process to comply with legal obligations imposed on us
• Your identification, such as name, title, position, status.
• Your contact information such as your e-mail, physical address and telephone numbers
• Your bank details
• Any other information that you provide us for the purposes of attending meetings or events.
• Personal data sent to us by you, on behalf of / or in relation to our clients, associates, service providers and employees
• Any type of data legally generated by us in the execution of the instructions sent by our clients.
• Video recordings through our surveillance cameras for security reasons, when you visit our office.
• Any type of personal data that you can voluntarily provide us.

Regardless of the way in which we collect your personal data, we will only process that data for the purpose of our legal services, which is your specific case, or purposes that are inherently related to these, including the fulfillment of any legal obligation imposed to us.

Your personal data will typically be processed for the following purposes:

• Under your free, prior and informed consent, for which we will treat the data provided for the purposes for which the free and prior informed consent has been granted.
• Provide our legal advice and legal services to you or our clients
• Comply with legal obligations, specifically those due dilligence obligations , regarding the prevention of money laundering, and the financing of terrorism and weapons of mass destruction, established in the various Panamanian and international regulations for this purpose.
• Conflict of interest check
• Administer and manage our relationship with you and / or your company, including billing and collection reasons.
• Security of access to our offices.
• Purposes of legitimate interests pursued by us or a third party, provided that the interests or fundamental rights and freedoms of you as an interested party do not prevail over said interests.
• In order to fulfill the purpose for which you gave us personal data, typically, legal procedures, applications, billing, among others.
• To keep you updated with respect to legal updates, news and events organized by the firm, where it is our legitimate interest to do so.
• In order to establish, exercise or defend legal procedures based on our legitimate interest or compliance with legal obligations, as appropriate.

It is possible that on some occasion in order to provide you with our service and exercise any action contemplated in point 5, we need to process personal data considered as special data categories, among which is sensitive data, defined by Panamanian regulations  as “one that refers to the intimate sphere of its owner, or whose misuse may give rise to discrimination or entail a serious risk for it. By way of example, personal data that may reveal aspects such as racial or ethnic origin are considered sensitive; religious, philosophical and moral beliefs or convictions; union membership; political opinions; data related to health, life, sexual preference or orientation, genetic data or biometric data, among others, subject to regulation and aimed at uniquely identifying a natural person "

In the event that it is necessary to treat this category of personal data, it will generally be on the basis of i) necessary treatment for the satisfaction of a legitimate interests pursued by the person responsible for the treatment or a third party, ii) The exercise of their defense in any legal procedure that requires access to them. In any case, we will notify you of the purposes and purposes for which this category of data will be processed by our office, and we will provide you with the pertinent and necessary information on the treatment of the category of special data for your particular case.

We will process your personal data only under the conditions of lawful treatment established in the personal data protection regulations, specifically those that are set out below:

• Under the consent of the owner of the personal data: in which case you adhere to the policies described here and your personal data will only be processed for the purposes for which they were collected. At any time, you may revoke the consent you have given us without it having retroactive effects.
• Treatment necessary for the execution of a contractual obligation: by offering you our services as your lawyers for legal matters, whatever service you hire, we enter into a contractual relationship for the provision of our service, under our terms and conditions of service and / or letters of commitment, in which you are a part of the processing of personal data. Take into consideration that in this case the obtaining and processing of your personal data is necessary to be able to provide you with our service and only those personal data that are considered pertinent, lawful and minimum for the purpose for which you have hired us will be requested. Failure to provide us with this data may limit our action and representation of your interests, since without this data we will not be able to act.
• Necessary treatment for a legal obligation for which we are subject: CLD Legal is considered as a non-financial subject obliged to comply with Law 23 of 2015, therefore we have the legal obligation to treat your personal data for preventive purposes money laundering, financing and proliferation of weapons of mass destruction and financing of terrorism.

We may transfer your personal data with a third party in the following cases:

• Individuals who are part of our organization, at the level of our different offices, and who require access to it to provide corresponding legal assistance. This includes any of our allies that assist us in providing you with another service that you hire, such as digital marketing and accounting, for the cases of our ILITIA by CLD Legal service.
• Any service provider that has to access your personal data to provide us with support services, as providers of technological services and / or, accounting and / or storage services, among others.
• Third parties to whom we must transfer the information obtained as a result of the relationship with our clients.
• Any partner and / or correspondent to whom we need to transfer your data for a service required by you.
• Third parties to whom we must transfer your information, as a result of legal and / or judicial obligations that the signature has.

CLD Legal, sometimes you must carry out international transfer of personal data to its own entities and / or outside of CLD Legal in order to offer you the services contracted by you and / or in quotes regarding the services to which you require assistance. For this, by accepting our privacy policies, you give us your prior, informed and express consent to make said international transfer and understand that said transfer is lawful under the content of article 33 (1) of Law 81 of 2019 - regulations in matter of protection of personal data-.

At all times CLD Legal will respect your ARCO rights, which are described below:

• Right of Access: you can obtain your personal data that is being processed by CLD Legal and know its origin and purpose at all times.
• Right of Rectification: in case your data is found to be incorrect, irrelevant, incomplete, outdated, inaccurate, false or irrelevant, you have the right to request its correction
• Right of Cancellation: in case your data is found to be incorrect, irrelevant, incomplete, out of date, inaccurate, false or irrelevant, you have the right to request the deletion of the same.
• Right of Opposition: for any reason, as long as you have well-founded and legitimate reasons related to a particular situation, you may refuse to provide your personal data or to be given a certain treatment. This right also includes the revocation of consent to process your personal data.

- Right of Portability: if you wish, and request us, you have the right to obtain a copy of the personal data that is being processed by us, in a generic and commonly used format.

You may exercise your ARCO rights for free at any time, directly or through a legal representative.

To exercise your rights, you can contact info@cldlegal.com . In your communication, in accordance with the provisions of the regulations on data protection, you must be able to prove your identity, as well as provide us with the necessary contact information to provide you with a response.

In the event that you exercise your rights through a legal representative, you must be able to prove that representation through the general rules of the mandate. For security reasons, we will not be able to assist you in the execution of your ARCO rights through a legal representative if you are not able to demonstrate this representation.

We will retain your personal data only for the legally permitted period, once this term has been fulfilled, your personal data will be immediately and irrevocably destroyed unless we are instructed otherwise.

A. Conservation periods

As non-obligated financial subjects, we must keep the information contained in the due diligence documents and corporate documents for a period of no less than 5 years from the termination of the relationship with the client.

We must also keep our accounting records for a period of no less than 5 years counted as follows:

• Counted from the last calendar year within which the transactions that apply to the records were completed, or
• Counted from the last calendar year in which the legal entity ceases its operations.

Additionally, Law 81 of 2019 allows the person responsible for the treatment to keep the personal data for an additional period of 7 years counted from the expiration of the legal obligation to keep it, that is, the period previously established.

Therefore, CLD Legal, in compliance with the aforementioned rules, will keep personal data and its files for a period of 7 years from the date on which the legal obligation to keep it, provided in point A, was extinguished, depending on each document. and each relationship

In the event that you contact us, as a company, intermediary or any other corporate entity, and that you transmit to us with personal data of third parties such as, your employees, associates, affiliates, partners, service providers, clients or prospective clients, directors and Any other individual, you are responsible for ensuring the following:

• You obtained the personal data of this third party in a lawful manner under the provisions of the personal data regulations and you can verify through traceability mechanisms that you are authorized to use it.
• You, immediately, will send this privacy policy to the owner of the personal data and will let him/her know that they apply directly to him/her.
• You are fully responsible directly to those owners and must adhere to the laws of protection of personal data.
• You will request any information, approval, consent and / or any other requirement that may be required about that owner and you will send us the same without delay.
• You are solely responsible for sending us the correct and updated information to date
• You are solely responsible for informing us in case such personal data changes and you will send us the correction thereof.

Therefore, you declare that in case you are transferring third-party data to us, you will hold us harmless from any liability, claim, damages, compensation resulting from any legal action that may be taken against you as a result of the provision of this data by your part to us.

For us, your security is our priority, that is why we have adopted information security measures in our technological equipment, as well as in our physical space. We have adopted technical and organizational measures that allow us to respond to any anomaly and minimize possible risks.

Generally, we do not carry out or take profiling activities and /or automated decisions, however, due to our obligations as non-obligated financial subjects, established in Law 23 of 2015 and other regulations that develop it, we must carry out due diligence measures in order to prevent money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction, in which we can use systems and / or programs that can carry out these activities, however, automated decisions will not be made that cause legal effects that may affect you significantly, by the use of these programs.

If you have a question about these policies, you can contact us at:

Location:

P.H SL 55.

21st floor, office 2

Ave Samuel Lewis & Calle 55

Panama City, Panama

Phone: +507 2631042

Email info@cldlegal.com