Privatam Inc

Services

We design investment solutions to offer clients customized advisory services in structured products.

Policies

Know your client

Privatam, Inc must comply with AML Manual and the regulations in relation with anti-money laundering, the treatment of funds originating from criminal activities and corruption under the Laws of Panama and in particular with the Law 23 of Abril 27th, 2015. In this context, Privatam is under the obligation to exercise “Know your Client (KYC)” due diligences and scrutiny of transactions concerning its customers and business counterparts when entering into a relationship but also at any time over the lifetime of a contract.

Data Protection Policy

Our goal is the protection of your data

At Privatam, Inc. we recognize the importance of privacy and the sensitivity of the information we maintain in our database, especially personal information about the people we deal with, whether they are clients, users, collaborators, candidates, suppliers or others. As an Investment Advisor regulated by the Superintendencia del Mercado de Valores and financial service providers, we have a professional, ethical and legal obligation to keep confidential all information we receive as part of our advisor-client relationship. Additionally, we are committed to safeguarding the information we store and/or process from individuals, whether natural or legal persons.

In this Data Protection Policy ("Policy"), we set forth the practices we have implemented in our business with respect to the handling of your data, from its collection, its use and with whom we share such information.

This Policy supplements all prior agreements, whether oral or written, between you and us regarding the collection, use and disclosure of your personal, business or financial information.

To whom this policy applies

This policy applies to us, as custodian of the database and as the party responsible for the processing of your personal data, and to you, natural or legal person, as the data subject. When we refer to "We", we mean "Privatam, Inc. When we talk about "you," we mean you as a customer, user, visitor, collaborator, candidate, supplier or person who for any other reason shares your data with us.

Legal basis for this policy

This Policy is based on Law 81 of March 26, 2019 on Personal Data Protection, which seeks to protect the rights of natural persons in their capacity as holders of their personal data, regarding the use of such data, ("Law 81") and Executive Decree 285 of May 28, 2021 which regulates it. Law 81 applies to all databases located in the territory of the Republic of Panama, when they store personal data of nationals or foreigners, or when the data controller is domiciled in the Republic of Panama. Exceptions are made for databases of subjects regulated by special laws provided that these laws establish minimum technical standards necessary for protection equal to or higher than those established by Law 81.

Privatam, Inc. is also regulated by Law 23 of April 27, 2015, as amended, which adopts measures to prevent money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction and other provisions, and the decrees and agreements that complement it, among others.

Definition

Below are the definitions provided by Law 81 for the terminology we use in this policy.

TYPES OF DATA

1) Personal data. Any information concerning natural persons, which identifies them or makes them identifiable. We treat all personal data as confidential data.

2) Confidential data. Data that by its nature should not be known to the public or to unauthorized third parties, including data that is protected by law, by confidentiality or non-disclosure agreements, in order to safeguard information. In the cases of the Public Administration, they are those data whose processing is limited to the purposes of this administration or if the express consent of the owner is given, without prejudice to the provisions of special laws or regulations that develop them. Confidential data will always have restricted access.

3) Sensitive data. That which refers to the intimate sphere of its owner, or whose improper use may give rise to discrimination or entail a serious risk to the owner. By way of example, personal data that may reveal aspects such as racial or ethnic origin; religious, philosophical and moral beliefs or convictions; union membership or political opinions; data relating to health, life, sexual preference or orientation, genetic data or biometric data, among others, subject to regulation and aimed at univocally identifying a natural person, are considered sensitive.

STORAGE

1) Data storage. Storage or custody of data in a database established in any medium provided, including Information and Communication Technologies (ICTs).

2) Database. An ordered set of data of any nature, whatever the form or modality of its creation, organization or storage, that allows the data to be related to each other, as well as to carry out any type of processing or transmission of these data by its custodian.

3) Accessible source. Databases that are not restricted in access or contain any reservation for consultation, or that are publicly accessible, such as official government publications, the media, telephone directories and the list of persons belonging to a group of professionals containing only name, title or profession, activity, work or business address, as well as information indicating their membership in organizations.

PARTICIPANTS

1) Data subject. Natural or legal person to whom the data refer.

2) Custodian of the database. Natural or legal person, public or private law, lucrative or not, who acts on behalf of the data controller and is responsible for the custody and preservation of the database.

3) Data controller. Natural or legal person, public or private law, for profit or not, which is responsible for the decisions related to the processing of data and determines the purposes, means and scope, as well as issues related to these.

DATA PROCESSING

1) Data processing. Any operation or complex of operations or technical procedures, whether automated or not, that makes it possible to collect, store, record, organize, elaborate, select, extract, confront, interconnect, associate, dissociate, communicate, assign, exchange, transfer, transmit or cancel data, or use them in any other way.

2) Consent. Manifestation of the will of the owner of the data, by means of which the processing of the data is carried out.

3) Data blocking. Temporary restriction of any access to or processing of stored data.

4) Cancellation or deletion of data. Permanently delete or erase data stored in databases, regardless of the procedure used to do so.

5) Data modification. Any change in the content of data stored in databases.

6) Dissociation or anonymization procedure. Any data processing that prevents the information available in the database from being associated with a specific or determinable natural person.

7) Transfer of data. To disclose, divulge, communicate, exchange and/or transmit, in any form and by any means, from one point to another, intra or extra-border, the data to natural or legal persons other than the owner, whether determined or undetermined.

GUIDING PRINCIPLES

1) Loyalty. We obtain your personal data only with your knowledge and consent.

2) Purpose. When we collect your personal data we inform you about the purpose and we will only use it for the stated purposes.

3) Proportionality. We will only ask you for the necessary personal data related to the stated purpose.

4) Truthfulness and Accuracy. We will always strive to ensure that your data is accurate and kept up to date. Remember that updating is a shared responsibility.

5) Data security. We have taken appropriate technical and organizational measures against unauthorized and unlawful processing of your personal data and information. You can rest assured that we have a robust technological platform, and a highly specialized team that has developed a strategy to continuously optimize the security of your personal data.

6) Transparency. We will always strive to communicate our data protection policies in easy-to-understand language.

7) Confidentiality. All persons who by their role have access to your data are obliged not to disclose it. We have internal processes, policies and tools to support us in maintaining the confidentiality of your data.

8) Legitimacy. When we collect your data, we make sure we have your consent and document it for future reference.

9) Portability. If requested by you, we will share your personal information in a generic and common format in a timely manner.

How and why do we collect personal information?

As a financial services provider, we collect personal data as part of our professional activities in order to serve our customers and comply with the legal regulations that apply to us. We never collect personal data without your knowledge and consent. We do not use your personal data for purposes other than those stated.

Importantly, we do not disclose or sell your personal information or business contact information to third parties to enable them to market their products and services to you.

IF YOU ARE A CUSTOMER OR POTENTIAL CUSTOMER

When you request a service or quote for a service we may collect your information and data, as part of the introduction process, to understand, access and assist you with your financial needs, to comply with obligations under special laws or to ensure that the information is correct and up to date, among others. We only collect your data through legal and consensual means. Some of the information we typically collect is:

- Information and basic personal data to identify you unequivocally: full name, date of birth, nationality, passport or identification number, in case you are a legal entity, your role within the organization, among others.

- Contact information to be able to communicate with you and invoice you: physical address, e-mail address, telephone numbers and in case of being a legal entity, address and tax identification number.

- Information necessary to comply with the Know Your Customer policy and Due Diligence requirements: in addition to the data mentioned in the previous points, copy of your identification document, proof of address, in case of being a legal entity, certificate of existence or equivalent, among others.

Generally, you will have provided information and data in the course of our relationship. However, as necessary, in order to provide requested services and/or comply with legal obligations, we may validate or collect information about you against our various databases, such as those of other companies in our economic group, or through third parties such as accessible sources, other authorities and/or state entities and service providers.

We use your personal data only in our regular professional activities and to fulfill our obligations under contracts or agreements entered into to provide you with our services, perform checks for possible conflicts or anti-money laundering searches, to comply with our legal obligations in the jurisdictions where we operate and to defend their legal rights, as well as to comply with court and/or administrative orders if necessary.

We will keep your personal data for a minimum of five (5) years after the termination of any business or contractual relationship. We will keep your personal data after this period for as long as it is necessary to deal with any claims or attention arising from the processing for which it has been collected or to comply with special laws or regulations implementing them. As part of our professional relationship, we may send you information about our services, about new products or services, events and news about our company or other companies in our economic group. You may at any time withdraw your consent by notifying us at compliance.panama@privatam.com.

IF YOU VISIT US AT OUR FACILITIES

- The building where Privatam's offices are located uses video surveillance in the surrounding area to maintain the security of our clients, collaborators and other visitors, as well as to protect against theft, fraud and damage to property. Therefore, when you visit us on our premises, you may be recorded. All recordings are destroyed at the discretion of the building management.

- If you visit us on our Internet pages or service portals

- When you browse our web pages, we do not collect personal data through cookies or similar methods.

- When you enter one of our customer service portals, we also collect the information that you provide us at the time and that is strictly necessary for it to fulfill the purpose for which it was designed. In all cases, we always seek your convenience and the security of your data. In these cases your data will be stored for the periods established by the applicable laws in this policy.

- If you provide us with your contact information through our contact form to communicate with us, we will pass your information to the right people to attend your message. It is not used for any other purpose. If a relationship with you does not materialize, your data will be discarded after an appropriate time.

IF YOU VISIT US ON OUR SOCIAL MEDIA ACCOUNTS

By visiting PRIVATAM, INC. accounts on LinkedIn you will have accepted the Data Protection Policies of these networks. PRIVATAM, INC. does not collect data from you or offer advice through social networks.

IF YOU PROVIDE US WITH A SERVICE AS A SUPPLIER

When you are a supplier to us, we may ask you for general information about your business, such as public registration, contact details, trade references, references in the CPA, dignitaries and any other information that is required to perform due diligence and assess the risk of a contractual relationship. We will store the personal data you provide to us in the course of our business relationship for a minimum of 5 years after the end of any business or contractual relationship.

We will keep your personal data beyond this period for as long as is necessary to deal with any claims or concerns arising from the processing for which it was collected or to comply with special laws or regulations implementing them.

IF YOU ARE A COLLABORATOR OR CANDIDATE

When you apply for a position with us, we collect the information you provide with your resume. In addition, we may be collecting additional information, for example through forms, interviews or your references. We use this information for the purpose of evaluating candidates for employment with us. If you are not hired, we keep your information for a reasonable period of time and then delete it. If you are hired by us, your information will be part of our employee database and your personnel file, for which we may request and store additional information in order to develop the employment relationship. Once the employment relationship is terminated, we keep your data according to the special applicable laws, such as Law 51 of 2005, which amends the Organic Law of the Social Security Fund and dictates other provisions, which defines a 20-year term for the prescription of contributions, so the relevant information will be kept for at least 20 years after the termination of the employment relationship.

How do we share or transfer your information?

In the course of our business relationship, we provide information to our staff for reasonable business purposes and to provide services to you. Our staff is trained to maintain the confidentiality and security of your data. All our personnel and those of our related companies have signed a confidentiality agreement and receive continuous training on confidentiality policies and protocols, data protection and our code of ethics, among others. To provide some of our services we may sometimes use external service providers or professionals who work with us, such as experts, translators, IT service providers, banks and others, who may have access to your personal data. In these cases, we require that these providers comply with practices and policies that ensure the security and confidentiality of your personal information and that it is not processed for purposes other than those specified above. Some of our companies, sites or service providers may be located in different jurisdictions. When it is necessary to transfer or transmit your personal information for the indicated purpose, we always ensure that the protection and confidentiality of your data is maintained as if they were in national territory and always in compliance with the applicable regulations. Always keep in mind that we must and will provide your basic data and information to government authorities when requested and required to do so by law.

INFORMATION SECURITY

The information we collect is used strictly for the purposes indicated. Our employees' access to your information is restricted and limited only to those who are authorized and trained in the proper handling of personal data information. We have adopted and implemented physical, electronic, procedural and practical security safeguards and practices to ensure that your information is kept confidential and secure as required by law and our internal procedures and practices. If you have any questions about our security measures, please contact us at tech@privatam.com.

PRESERVATION OF INFORMATION

You agree that we may maintain and use information about you in our records for the purposes described in this Policy, even if you cease to have a relationship with us, subject to applicable laws.

ACCURACY OF PERSONAL INFORMATION

As long as there is a business relationship with Us, you must at all times provide and keep updated all personal information, and you must notify Us as soon as there are changes to it so that We can update our databases and ensure that there are no mishaps in the contractual relationship that We maintain.

WE TAKE CARE OF YOUR RIGHTS AS A PERSONAL DATA SUBJECT

- Access. You can obtain your personal data, know their origin and the purpose for which they have been collected, within a period not exceeding 10 working days from the request.

- Rectification. You may request correction of your personal data if you believe it is incorrect, irrelevant, incomplete, outdated, inaccurate, false or irrelevant. In such a case we will proceed with the corresponding correction within 10 working days following the request.

- Cancellation. You may request deletion of your data if you believe it is incorrect, irrelevant, incomplete, outdated, inaccurate, false or irrelevant.

- Opposition. When you consider that there are well-founded and legitimate reasons related to something in particular, you can refuse to provide your personal data or to be subject to certain processing, as well as to revoke your consent.

- Portability. If requested by you, we will share your personal data in a generic and common format, within 10 business days of the request. Please note that in order to protect your rights we may delete, delete, modify or block your personal data without a request from you, when there is evidence of inaccuracy of your data. When the accuracy of your data cannot be established or is of doubtful validity, we may block your data.

ACCESS TO YOUR INFORMATION AND PROCEDURE FOR EXERCISING YOUR RIGHTS

To exercise the rights detailed above, please send an email to compliance.panama@privatam.com with a copy to tech@privatam.com requesting in the corresponding email the right(s) you wish to exercise, attaching the supporting documentation required to make the necessary changes or modifications. We will respond to you within 10 working days.

DATA PROTECTION OFFICER

There is no designated official for this purpose, however Privatam, Inc, as an entity is solely responsible for personal data and undertakes to comply with all instructions and requirements indicated in Law 81 of 2019, as well as related agreements and regulations, to ensure that the holder can exercise their rights when required, inform them of the use that will be made of their data, keep the information under security controls that prevent them from being used, adulterated, lost or have unauthorized personnel access, ensure that the information stored in our records is truthful, accurate, evidentiary, current and clear.

In addition, it must rectify the data when they are erroneous, process the consultations and and to inform the holder and the competent authorities in a timely manner when the holder there are security breaches that put personal data at risk.

VALIDITY OF THIS POLICY

This Policy was updated as of December 28, 2022 and will be reviewed according to regulatory requirements and or annual updates. You agree that we may review and change our Policy at any time in order to update our privacy commitment to you based on current privacy laws and best practices.

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Privatam INC

Oceania Business Plaza 2000 – 28th Floor

Boulevard Punta Pacifica

Panama, Rep. of Panama

+507-202-3155

Privatam, Inc. is an entity regulated and supervised by the Superintendencia del Mercado de Valores de la República de Panamá and holds an Investment Advisor license, issued by SMV Resolution No. 220 – 2014.

Privatam, Inc. es una entidad regulada y supervisada por la Superintendencia del Mercado de Valores de la República de Panamá y posee licencia de Asesor de Inversiones, emitida mediante Resolución SMV No. 220 – 2014 .