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PRIVACY NOTICE AND PERSONAL DATA PROTECTION

At INFOTECH, S.A. DE C.V. (hereinafter, “INFOTECH” or the “COMPANY”) we recognize the importance of protecting the personal information entrusted to us. Therefore, we adopt the necessary measures to seek to ensure that personal data is processed in a responsible and secure manner and in accordance with current legislation.

This NOTICE is intended to inform clients, suppliers, employees, candidates, contractors, and any other persons who maintain any type of relationship with INFOTECH about the way in which we may obtain, use, retain, and, where applicable, share their personal data.

The processing of information will be carried out in accordance with the PERSONAL DATA PROTECTION LAW OF EL SALVADOR (LEGISLATIVE DECREE No. 144) and other applicable legal and regulatory provisions.

  1. PERSONAL INFORMATION THAT WE MAY OBTAIN

Depending on the nature of the existing relationships with INFOTECH, we may request and process different categories of personal information. These may include:

  1. a) First and last names;
  2. b) Identification documents;
  3. c) Contact information, including address, telephone number, and email;
  4. d) Nationality and family status, when necessary;
  5. e) Information related to studies, professional training, and work experience,
  6. f) Personal and professional references;
  7. g) Information necessary for hiring and selection processes;
  8. h) Data related to invoicing, payments, and commercial transactions;
  9. i) Any other information that is reasonably necessary to establish, manage, or fulfill the corresponding relationship.

INFOTECH will seek to limit the collection of information to that which is relevant to the purposes for which it is obtained.

  1. USE AND PURPOSE OF PERSONAL DATA

Personal information may be used depending on the relationship the person maintains with INFOTECH and in accordance with the purposes detailed below:

  1. CLIENTS, SUPPLIERS, AND OTHER COMMERCIAL RELATIONSHIPS

The data may be used to:

  1. Prepare, negotiate, formalize, execute, and manage contracts and commercial agreements.
  2. Manage orders, services, deliveries, requests, and other activities related to the commercial relationship.
  3. Issue invoicing documents and manage collections, payments, and financial obligations.
  4. Maintain communication with the corresponding person or entity regarding the services, products, requests, or transactions contracted.
  5. EMPLOYEES

In the case of our employees, the information may be processed to:

  1. Manage and execute the employment relationship.
  2. Manage salaries, benefits, perquisites, and other obligations arising from the employment relationship.
  3. Coordinate training, professional development, and performance evaluation processes.
  4. Fulfill the corresponding labor, tax, accounting, and administrative obligations.
  5. PERSONS PARTICIPATING IN SELECTION PROCESSES

When a person submits their candidacy to become part of INFOTECH, their data may be used to:

  1. Analyze their education, experience, knowledge, and skills.
  2. Determine their compatibility with an available position.
  3. Follow up on selection processes and communicate with the candidate.
  4. Consider their profile for future job opportunities that may be compatible with their characteristics and experience.
  5. COMMON PURPOSES

Regardless of the type of relationship, INFOTECH may use personal data when necessary to:

  1. Fulfill obligations established by applicable legislation.
  2. Respond to requirements from competent authorities.
  3. Fulfill tax, accounting, labor, regulatory, or administrative obligations.
  4. Manage inquiries, requests, claims, or communications related to the existing relationship.
  5. Protect the legitimate rights and interests of INFOTECH, its employees, clients, suppliers, and other related parties, within the limits permitted by applicable legislation.
  6. ACCESS TO AND DISCLOSURE OF INFORMATION TO THIRD PARTIES

Access to personal data will be limited to those persons and entities that need to know it for a legitimate purpose related to the provision of services, the management of the corresponding relationship, or compliance with legal obligations.

Accordingly, INFOTECH may disclose certain personal information:

  1. To employees and authorized personnel of INFOTECH, when access is necessary for the performance of their duties.
  2. To suppliers or third parties that provide services on behalf of or for the account of INFOTECH, including services related to commercial, administrative, recruitment, regulatory compliance, personnel management, or payroll processes.
  3. To public authorities or competent entities when there is a legal obligation, a valid request, or it is necessary for compliance with applicable provisions.
  4. To clients or commercial counterparties of INFOTECH, exclusively when such disclosure is necessary to fulfill contractual obligations, legal requirements, or responsibilities directly related to the functions or services of the corresponding person.

When INFOTECH uses third parties for the processing or handling of personal information, it will seek to establish the corresponding confidentiality, security, and non-disclosure obligations, in order to preserve the protection of the data during its use.

  1. RETENTION OF INFORMATION

INFOTECH will retain personal data for the period necessary to fulfill the purposes described in this NOTICE and, as a general rule, for a maximum period of FIVE YEARS, unless:

  1. The person validly withdraws their consent before such period ends; or
  2. A legal, contractual, or regulatory provision or a specific obligation requires the retention of certain information for a different period.

Once the data is no longer necessary and there is no obligation that justifies its retention, INFOTECH will seek to proceed with its deletion or any other appropriate measure in accordance with applicable regulations.

  1. RIGHTS OF DATA SUBJECTS

Persons whose data is processed by INFOTECH may exercise, under the terms established by applicable legislation, the rights that correspond to them with respect to their personal information, including the rights of access, rectification, objection, portability, erasure, and restriction of processing (ARCO-POL)

Likewise, when the processing is based on the data subject’s consent, the data subject may request its withdrawal at any time, without prejudice to the fact that certain data must continue to be retained where a legal obligation so requires.

To submit a request related to their personal data, the data subject may contact us via email at: privacidad@grupoinfotech.com, or at our physical offices at Colonia San Francisco Avenida Las Dalias #3, Pasaje Petaluma, Casa 2-B, District of San Salvador, Municipality of San Salvador Centro, department of San Salvador.

INFOTECH will address requests in accordance with the procedures and deadlines established by applicable regulations.

  1. MODIFICATIONS TO THIS NOTICE

INFOTECH may review and modify this PRIVACY NOTICE when necessary, whether as a result of changes in its internal processes, in the services it provides, or in applicable legislation.

When relevant modifications occur in the processing of personal data, INFOTECH may communicate them by publishing an updated version of this notice on its digital channels, sending an email communication, or through any other mechanism that adequately informs data subjects.

The modified version will take effect from the date of its publication, unless a different date is expressly indicated.

We recommend periodically reviewing this NOTICE to stay informed about the current practices of INFOTECH regarding privacy and personal data protection.