PERSONAL DATA PROTECTION TREATMENT POLICY OF THE HOLDERS
BITPoint PANAMA INC.

The company BITPoint PANAMA INC. adopts the present policy for the treatment of personal data, which will be informed to all the holders of the data collected or that in the future will be obtained in the exercise of commercial activities.

In this way, BITPoint PANAMA INC. states that it guarantees the rights of privacy, privacy, good name, in the treatment of personal data, and consequently all its actions will be governed by the principles of legality, purpose, freedom, truth or quality, transparency, access and restricted circulation, security and confidentiality.

All persons who, in the development of different commercial activities, among others, whether permanent or occasional, will come to supply the company BITPoint PANAMA INC. any type of information or personal data, you can know, update and rectify.

IDENTIFICATION OF THE RESPONSIBLE OF  TREATMENT

NAME OF THE COMPANY: BITPoint PANAMA INC. registered in Folio Electrónico No. 155668141 (S) of the Mercantile Section of the Public Registry of Panama, hereinafter referred to as BITPOINT PANAMÁ, a company duly incorporated and domiciled in Panama, Panama City.

ADDRESS AND ADDRESS: BITPoint PANAMA is domiciled in the city of Panama, and its effective administrative headquarters is located at Calle Ricardo Arias Banking Area, Ed Proconsa Ofi 2-D, Panama City, Panama

EMAIL: support@bitpoint.com.pa

AREA OF APPLICATION

This policy will be applicable to personal data registered in any database of BITPoint PANAMA whose owner is a natural or legal person.

DEFINITIONS

For the purposes of this policy and in accordance with current regulations on the protection of personal data, the following definitions shall be taken into account:

Authorization: Prior, express and informed consent of the Holder to carry out the processing of personal data.

Privacy notice: Verbal or written communication generated by the person in charge, directed to the Owner for the processing of their personal data, by means of which they are informed about the existence of the information treatment policies that will be applicable to them, the way to access to them and the purposes of the treatment that is intended to give personal data.

Database: Organized set of personal data that is subject to treatment.

Causairee: person who has succeeded to another because of the death of this one (heir).

Personal data: Any information linked to or associated with one or several natural persons determined or determinable.

Public data: It is the data that is not semi-private, private or sensitive. Public data are considered, among others, the data related to the civil status of the persons, to their profession or trade and to their status as merchants or public servants. By its nature, public data may be contained, among others, in public records, public documents, gazettes and official bulletins and judicial sentences duly executed that are not subject to reservation.

Sensitive data: Sensitive data are those that affect the privacy of the Holder or whose improper use may generate discrimination, such as revealing racial or ethnic origin, political orientation, religious or philosophical convictions, membership in unions, organizations social rights, or that promotes the interests of any political party or that guarantees the rights and guarantees of

Opposition political parties, as well as data related to health, sexual life, and biometric data.

Responsible for the Treatment: Natural or legal person, public or private, that by itself or in association with others, performs the processing of personal data on behalf of the person responsible for the Treatment.

Owner: Natural person whose personal data is subject to Treatment.

Treatment: Any operation or set of operations on personal data, such as collection, storage, use, circulation or deletion.

Transfer: The transfer of data takes place when the person in charge and / or in charge of the processing of personal data, located in Panama, sends the information or personal data to a receiver, who in turn is responsible for the treatment and is inside or outside from the country.

Transmission: Treatment of personal data that involves the communication of these within or outside the territory of the Republic of Panama when it has for its object the performance of a treatment by the person in charge on behalf of the person in charge.

Values

n order to guarantee the protection of personal data, BITPoint PANAMÁ will apply the following principles harmoniously and comprehensively, in light of which the processing, transfer and transmission of personal data must be carried out:

Principle of freedom: the processing of personal data can only be done with the prior, express and informed consent of the Holder. Personal data may not be obtained or disclosed without prior authorization, or in the absence of legal, statutory, or judicial mandate that relieves consent.

Principle of truth or quality: The information subject to the processing of personal data must be truthful, complete, accurate, updated, verifiable and understandable. The processing of partial, incomplete, fractionated or misleading data is prohibited.

Principle of transparency: In the processing of personal data, BITPoint PANAMA will guarantee the Holder its right to obtain at any time and without restrictions, information about the existence of any type of information or personal data that is of interest or ownership.

Principle of access and restricted circulation: The processing of personal data is subject to the limits that derive from the nature of these, the provisions of the law and the Constitution. Consequently, the treatment can only be done by persons authorized by the owner and / or by the persons provided by law. Personal data, except public information, may not be available on the Internet or other means of dissemination or mass communication, unless the access is technically controllable to provide restricted knowledge only to holders or authorized third parties in accordance with the law.

For these purposes the BITPoint PANAMA obligation will be as an intermediary

Principle of security: The information is bind to treatment by BITPoint PANAMA, shall be handled with the technical, human and administrative measures that are necessary to grant security to the records avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

Principle of confidentiality: All persons who are in BITPoint PANAMA, administration, management, updating or access to information of any type that is found in the data bases, are obliged to maintain the reservation of the information, in which they  commit to maintain and sustain confidentiality and not disclose to third parties. except in the case of activities expressly authorized by the data protection law. This obligation must be maintained even after it has been completed.

RIGHTS OF HOLDER´S INFORMATION

BITPoint, in its search for compliance with international data protection standards, lists the following rights of the holders of personal data:

  1. Access, know, update and rectify your personal data in front of BITPoint PANAMA in its capacity as responsible for the treatment. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose treatment is expressly prohibited or has not been authorized.
  2. Request proof of the authorization granted to BITPoint PANAMA for the treatment of data, by any valid means, except in the cases in which the authorization is not necessary
  3. Be informed by BITPoint PANAMA, upon request, regarding the use that has been given to your personal data.
  4. Revoke the authorization and / or request the deletion of the data when in the treatment the principles, rights and constitutional and legal guarantees are not respected.
  5. Access free of charge to your personal data that have been processed, at least once each calendar month, and whenever there are substantial modifications of this policy that motivate new consultations.

These rights may be exercised by:

  • The owner, who must prove his identity sufficiently by the different means that BITPoint PANAMA makes available to him.
  • The titleholders of the owner, who must prove such quality.
  • The representative and / or agent of the owner, prior accreditation of representation or empowerment.
  • Another in favor or for which the owner has stipulated.

Rights of adolescents and children

In the processing of personal data, respect for the prevailing rights of minors will be ensured.

The processing of personal data of minors is prohibited, except for those data that are of a public nature, and in this case the treatment must comply with the following parameters:

  1. Respond and respect the best interests of minors.
  2. Ensure respect for the fundamental rights of minors.

DUTIES OF BITPOINT PANAMA AS RESPONSIBLE FOR THE TREATMENT OF PERSONAL DATA

BITPOINT PANAMA recognizes the ownership of personal data held by individuals and, consequently, they can exclusively decide on it. Therefore, BITPoint PANAMA will use the personal data for the fulfillment of the purposes expressly authorized by the title or by the regulations in force.

In the treatment and protection of personal data, BITPoint PANAMA will have the following duties, without prejudice to others provided for in the provisions that regulate or come to regulate this matter:

  1. Guarantee the holder, at all times, the full and effective exercise of the right of habeas data.
  2. Request and keep, copy of the respective authorization granted by the owner for the processing of personal data.
  3. Properly inform the owner about the purpose of the collection and the rights that assist him by virtue of the authorization granted.
  4. Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
  5. Ensure that the information is true, complete, accurate, updated, verifiable and understandable.
  6. Update the information in a timely manner, thus taking care of all the news regarding the data of the owner. Additionally, all necessary measures must be implemented so that the information is kept up-to-date.
  7. Rectify the information when it is incorrect and communicate the pertinent.
  8. Respect the security and privacy conditions of the holder’s information.
  9. Process inquiries and claims formulated in the terms indicated by law.
  10. Identify when certain information is under discussion by the owner.
  11. Inform at the request of the owner about the use given to their data.
  12. Inform the data protection authority when there are violations of the security codes and there are risks in the administration of the information of the owners.
  13. Allow access to information only to people who can access it.
  14. Use the personal data of the owner only for those purposes for which it is duly empowered and respecting in all cases the current regulations on protection of personal data.

AUTHORIZATION AND  HOLDER´S CONSENT

BITPOINT PANAMA requires the free, prior, express and informed consent of the owner of the personal data for the treatment of these, except in the cases expressly authorized by law, namely:

  1. Information required by a public or administrative entity in the exercise of its legal functions or by court order.
  2. Data of public nature.
  3. Cases of medical or sanitary emergency.
  4. Processing of information authorized by law for historical, statistical or scientific purposes.

Manifesting authorization

The authorization to BITPoint PANAMA for the treatment of personal data will be granted by:

  • The owner, who must prove his identity sufficiently by the different means that BITPoint PANAMA makes available to him.
  • The titleholders of the owner, who must prove such quality.
  • The representative and / or agent of the owner, prior accreditation of representation or empowerment.
  • Another in favor or for which the owner has stipulated.

Means for granting authorization

BITPoint PANAMA will obtain the authorization through different means, among them the physical, electronic, data message, Internet, Websites, or in any other format that in any case allows obtaining consent through unambiguous behaviors through which it is concluded that if it had not been supplied by the owner or the person legitimated to do so, the data would not have been stored or captured in the database.

The authorization will be requested and given by accepted and understood in the creation of the user’s account and in the moment in which he accepts the terms and conditions of use of the site and with which he has the evidence of authorization of this.

Proof of authorization

BITPoint PANAMA will keep proof of the authorization granted by the holders of the personal data for its treatment, for which it will use the mechanisms available to it at present, as well as adopt the necessary actions to maintain the registration of the form and date and in which he obtained this one. Consequently, BITPoint PANAMA may establish physical files or electronic repositories made directly or through third parties contracted for this purpose.

Authorization revoke

Holders of personal data may at any time revoke the authorization granted to BITPOINT PANAMA for the processing of their personal data or request the deletion of these, provided that it is not prevented by a legal or contractual provision. BITPoint PANAMA will establish simple and free mechanisms that allow the owner to revoke their authorization or request the deletion of their personal data, at least by the same means by which it was granted.

It must be taken into account that the revocation of the consent can be expressed, on the one hand, in a total way in relation to the authorized purposes, and therefore BITPoint PANAMA must cease any data processing activity;  on the other hand partially in relation to certain types of treatment, in which case they will be those on which the treatment activities will cease, such as for advertising purposes, among others. In the latter case, BITPoint PANAMA may continue to treat personal data for those purposes in relation to which the owner has not revoked his consent.

Process TO WHICH THE DATA WILL BE SUBMITTED AND PURPOSE OF THIS

The processing of personal data of registered or non-active users, ex-users, or of any person with whom BITPoint PANAMA has established or established a permanent or occasional relationship, will be done within the legal framework that regulates the matter and by virtue of its status as a commercial company, and they will be all necessary for the fulfillment of its market objectives.

In any case, personal data may be collected and processed to:

  1. Make the sending of information related to promotions, activities, special discounts, notification of awards, content by area of ​​interest, products and other goods or services offered by BITPoint PANAMA.
  2. Develop the corporate purpose of BITPoint PANAMA according to its bylaws.
  3. Comply with the rules applicable to suppliers and contractors, including, but not limited to, tax and commercial ones.
  4. Conduct surveys related to the services or goods of BITPoint PANAMA.
  5. Develop new business activities in accordance with its bylaws.
  6. Keep in contact with commercial allies.
  7. Fulfill all your contractual commitments.

Sensitive data

In the case of sensitive personal data, BITPoint PANAMA may use and process them when:

  1. The owner has given his explicit authorization, except in cases that by law is not required the granting of such authorization.
  2. The treatment is necessary to safeguard the vital interest of the Holder and this is physically or legally incapacitated. In these events, the legal representatives must grant their authorization.
  3. The Treatment refers to data that are necessary for the recognition, exercise or defense of a right in a judicial process.
  4. The treatment has a historical, statistical or scientific purpose. In this event, the measures leading to the suppression of identity of the holders must be adopted.

Without prejudice to the exceptions provided for in the law, in the processing of sensitive data requires the prior, express and informed authorization of the owner, which must be obtained by any means that may be subject to further consultation and verification.

PRIVACY NOTICE

The Privacy Notice is the physical document, electronic or in any other format, made available to the owner to inform you about the treatment of your personal data. Through this document, the owner is informed of the information related to the existence of the information processing policies of BITPoint PANAMA that will be applicable, the way to access them and the characteristics of the treatment intended to be given to the personal data.

The privacy notice must contain, as a minimum, the following information:

  1. The identity, address and contact information of the controller.
  2. The type of treatment to which the data and the purpose of this will be submitted.
  3. The rights of the owner.
  4. The general mechanisms provided by the person in charge so that the owner knows the information treatment policy and the substantial changes that take place in it. In all cases, you must inform the owner how to access or consult the information processing policy.
  5. The optional nature of the answer regarding questions about sensitive data.

GUARANTEES OF THE RIGHT OF ACCESS

To guarantee the right of access of the owner of the data, BITPoint PANAMA will make available to the latter, after proof of identity, legitimacy, or personality of its representative, without any cost or expense, in a detailed and detailed manner, the respective personal data through all types of media, including electronic means that allow the owner direct access to them. This access must be offered without any limit and must allow the owner the possibility of knowing and updating them online.

PROCEDURE FOR THE ATTENTION OF CONSULTATIONS, CLAIMS, REQUESTS FOR RECTIFICATION, UPDATING AND DELETION OF DATA:

Queries:

Holders or their successors in title may consult the personal information of the owner who resides in BITPOINT PANAMA, who will provide all the information contained in the individual record or that is linked to the identification of the Holder.

Regarding to the attention of requests of consultation of personal data BITPoint PANAMA guarantees:

  • Enable electronic or other means of communication that you consider relevant.
  • Establish forms, systems and other simplified methods, which should be informed in the privacy notice.
  • Use the customer service or claims services you have in operation.
  • In any case, regardless of the mechanism implemented for the attention of requests for consultation, they will be attended within a maximum of (15) business days from the date of receipt. When it is not possible to attend the consultation within said term, the interested party will be informed before the expiration of the 15 days, stating the reasons for the delay and indicating the date on which the consultation will be attended, which in no case may exceed five (8) business days following the expiration of the first term.
  • Queries may be made to the email support@bitpoint.com.pa

Claims

The Holder or his successors who consider that the information contained in a database must be submitted  to correction, updating or deletion, or when they notice the alleged breach of any of the duties, may submit a claim before BITPoint PANAMA, which will be processed under the following rules:

  1. The claim of the Holder will be formulated by means of a request addressed to BITPoint PANAMA to the email support@bitpoint.com.pa, with the identification of the holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that are desired enforce. If the claim is incomplete, the interested party will be required within five (5) days after receipt of the claim to correct the faults. After two (2) months from the date of the request, without the applicant submitting the required information, it shall be understood that the claim has been abandoned.
  2. In the event that the person receiving the claim is not competent to resolve it, it will notify the corresponding party within a maximum period of two (2) business days and inform the interested party of the situation.
  3. Once the complete claim has been received, it will be cataloged with the label “claim in process” and the reason for it, in a term not exceeding two (2) business days. Said label will be maintained until the claim is decided.
  4. The maximum term to attend the claim will be fifteen (15) business days counted from the day following the date of its receipt. When it is not possible to attend the claim within said term, the interested party will be informed of the reasons for the delay and the date on which his claim will be handled, which in no case may exceed eight (8) business days following the expiration of the first finished.

PETITION FOR UPDATING AND / OR RECTIFICATION

BITPoint PANAMA will rectify and update, at the request of the owner, the latter information that is incomplete or inaccurate, in accordance with the procedure and the terms indicated above, for which the following will be taken into account:

  1. The owner must submit the request to the email support@bitpoint.com.pa indicating the update and / or rectification to be made and provide the documentation that supports your request.
  2. BITPoint PANAMA may enable mechanisms that facilitate the exercise of this right to the owner, as long as they benefit it. As a result, electronic or other means may be enabled that you consider pertinent, which will be informed in the privacy notice and made available to those interested in the website.

REQUEST FOR DELETING DATA

The holder of the personal data has the right to ask BITPoint PANAMÁ for its deletion  in any of the following events:

  1. Consider that they are not being treated according to the principles, duties and obligations set forth in the current regulations.
  2. They have ceased to be necessary or pertinent for the purpose for which they were collected.
  3. The period necessary to fulfill the purposes for which they were collected has been exceeded.

This suppression implies the total or partial elimination of personal information in accordance with the request by the owner in the records, files, databases or treatments performed by BITPoint PANAMA. However, this right of the owner is not absolute and consequently BITPoint PANAMA may deny the exercise of this when:

      1. The holder has a legal duty to remain in the database.
      2. The elimination of data hinder judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions.
      3. The data that are necessary to protect the legally protected interests of the owner; to perform an action based on the public interest, or to comply with an obligation legally acquired by the owner.

SECURITY OF INFORMATION AND SECURITY MEASURES

In compliance with the security principle established in the current regulations, BITPoint PANAMA will adopt the technical, human and administrative measures that are necessary to grant security to the records, avoiding their adulteration, loss, consultation, use or unauthorized or fraudulent access.

USE AND INTERNATIONAL TRANSFER OF PERSONAL DATA AND PERSONAL INFORMATION BY BITPOINT PANAMA

In compliance with the BITPoint PANAMA corporate purpose, and taking into account the nature of the permanent or occasional relationships that any person holding personal data may have with BITPoint PANAMA, the latter may carry out the transfer and transmission, even international, of all the data personal, as long as the applicable legal requirements are met; and consequently the holders with the acceptance of the present policy, expressly authorize to transfer and transmit, even at an international level, the personal data. The data will be transferred, for all the relations that can be established with BITPoint PANAMA.

BITPoint PANAMA may also exchange personal information with governmental or other public authorities (including, among other judicial or administrative authorities, tax authorities and criminal, civil, administrative, disciplinary and fiscal investigation bodies), and third parties participating in civil legal proceedings and its accountants, auditors, attorneys and other advisors and representatives, because it is necessary or appropriate: (a) to comply with the laws in force, including laws other than those of your country of residence; (b) to comply with legal processes; (c) to respond to requests from public authorities and the government, and to respond to requests from public and government authorities other than those of their country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, security or property, yours or those of third parties; and (g) obtain the applicable indemnities or limit the damages that may affect us.

RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

BITPoint PANAMA will be responsible for the processing of personal data.

The Marketing Department will be in charge of the processing of personal data, on behalf of BITPoint PANAMA.

VALIDATION

This policy applies as of December 1, 2018.

BITPoint PANAMÁ INC.

Copyright © 2018 BITPoint Panama Inc., All Rights Reserved.