Privacy Policy

Effective date: 08/20/2021

1. Introduction

This Privacy Policy explains how APS Consultores Gerenciales, S.A. a company incorporated under the laws of Panama (hereinafter “APS”, "Company," "we," or "us") collects, uses, shares and processes your information as well as the rights and choices you have associated with that information.

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.cybsconsulting.com (hereinafter the "website" or “site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website;
• In email, text, and other electronic messages between you and APS through the website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by APS or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will manage it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using this website, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Electronic communication

By using this website or communicating with us by electronic means, you agree and acknowledge that we may communicate with you electronically on our website or by email, and you agree that all agreements, notices, disclosures, and other communications that we provide to you electronically, satisfy any legal requirement.

3. Information We Collect About You

We collect several types of information from and about users of our website, including information:

• By which you may be personally identified, such as name, e-mail address, telephone number and position or occupation, as well as any other personal information you choose to disclose ("personal information");
• About your internet connection, the equipment you use to access our website, and usage details.

We collect this information:

• Directly from you when you provide it to us;
• Automatically as you navigate through the site. Information collected automatically may include usage details, and information collected through cookies, web beacons, and other tracking technologies.

Information you provide to Us:

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our website. This includes information provided at the time of subscribing to our mailing or requesting further services. We may also ask you for information when you report a problem with our website;
• Records and copies of your correspondence (including email addresses), if you contact us.

4. How We Use Your Information

We do not sell data to third parties. We use the information that we collect about you or that you provide to us, including any personal information to:

1. Present our website and its contents to you;

2. Provide you with information, products, or services that you request from us;

3. Fulfill any other purpose for which you provide it;

4. Notify you about changes to our website or any products or services we offer or provide though it;

5. Allow you to participate in interactive features on our website;

6. In any other way, which we may describe when you provide the information;

7. For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ services that may be of interest to you. If you do not want us to use your information in this way, please let us know.

5. Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

1. To our subsidiaries and affiliates;

2. When necessary, to contractors, service providers, and other third parties we use to support our activities and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

3. To fulfill the purpose for which you provide it;

4. For any other purpose disclosed by us when you provide the information;

5. With your consent;

6. We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Please bear mind that in order to provide the services required by you, it could be necessary to transfer the information provided to some other jurisdiction. If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from the Panamanian legislation, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

As described above, we also may outsource the processing of your data to, or otherwise share your data with, other members, related or affiliates of APS; service providers, and business partners in countries other than your country of residence, including the United States of America and Chile, in accordance with applicable law.

Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use. This does not imply in any case a breach or violation of the rights of the user in terms of protection of the user's privacy and the appropriate treatment of the data collected.

6. Your rights

We take reasonable steps to ensure that your personal information is accurate, complete, and up to date, in accordance to Panamanian legislation and as provided by the Act 81-2019 and its Regulations, you have the following rights:

• Access: you may submit a request for access to the data we process about you;
• Correction: you may, at any time, request that we correct or complete personal data that we hold that it is incorrect or inaccurate;
• Overview: You may request an overview, in a commonly used format, of the data we process about you;
• Withdrawal: You may, at any time, withdraw your consent to process your information and request for us to delete it;
• Objection: You may object to the processing and we will comply, unless there are reasonable reasons for the processing of said information;
• Portability: If you want to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used format.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise the above-referred rights, please contact us at info@cybsconsulting.com.

7. Use of Cookies and Similar technologies

We may use cookies, tags, and similar technologies to automatically collect information on our website. These tracking technologies allow our technology partners to collect information including your IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags. We may also use web beacons or pixels to analyze usage patterns on our website.

The technologies we may use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our website;
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies;
• Web Beacons. Pages of our the website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit APS, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity);
• Analytics: We may use third-party service providers to monitor and analyze the use of our website. Currently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=es. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

Some content or applications, on the website are served by third-parties, these third parties may use cookies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

8. Retention

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

9.Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly;
• Promotional Offers from APS or its affiliates . If you do not wish to have your email address used by APS to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to info@cybsconsulting.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

10. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk.

11.Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. It is your obligation to periodically check this policy for changes or updates. The date provided at the beginning of this Privacy Policy is the latest revision date. Changes to this Privacy Policy will become effective upon such changes being posted to this website. Your continued use of this website following the posting of changes or updates will be considered notice of your acceptance to abide by and be bound by this Privacy Policy.

12. Children

Our Website is not intended for individuals under 18 years of age. No one under age 18 may provide any personal information to or on the website. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on this website. If we discover we have collected or received personal information from an individual under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us.

13. Contact information

To ask questions or comment about this Privacy Policy, contact us at:

• Email: info@cybsconsulting.com
• Telephone number: +507 269 4502
• Telephone number: +507 269 4502