PRIVACY AND PERSONAL DATA PROTECTION POLICY

1. IDENTIFICATION OF THE DATA CONTROLLER

This Privacy Policy governs the processing of personal data by SYNERA MANAGEMENT S.A. (hereinafter, "the Company"), in compliance with the applicable regulations in the Republic of Panama.

2. APPLICABLE REGULATORY FRAMEWORK

The processing of personal data is carried out in accordance with the provisions of:

• Law No. 81 of March 26, 2019, on the Protection of Personal Data

• Executive Decree No. 285 of May 28, 2021, which regulates Law 81

SYNERA MANAGEMENT S.A. guarantees that the processing of personal data will be carried out in accordance with the principles of loyalty, purpose, proportionality, truthfulness, security, and confidentiality.

3. PERSONAL DATA SUBJECT TO PROCESSING

The Company may collect and process, among others, the following personal data:

a) Identification data: full name

b) Contact data: email, telephone number

c) Professional data: job title, company, sector

d) Browsing data: IP address, cookies, and website behavior

4. PURPOSE OF PROCESSING

Personal data will be processed for the following purposes:

a) Respond to requests for information and queries made by the owner

b) Manage the commercial and/or contractual relationship

c) Provide information on the services offered by the Company

d) Send commercial communications after obtaining the consent of the owner

e) Comply with applicable legal and regulatory obligations

5. LEGAL BASIS FOR PROCESSING

The processing of personal data is based on:

• The prior, express, and informed consent of the owner

• The performance of a contractual or pre-contractual relationship

• Compliance with legal obligations

6. DATA RETENTION

Personal data will be retained for the strictly necessary period to comply with the purposes described or as established by applicable legislation.

7. SECURITY MEASURES

SYNERA MANAGEMENT S.A. implements technical, organizational, and administrative measures necessary to guarantee the security of personal data, preventing its alteration, loss, unauthorized access, or improper processing.

8. TRANSFER AND TRANSFER OF DATA

Personal data will not be transferred to third parties, except in the following cases:

a) When necessary for the provision of services through authorized suppliers

b) At the request of the competent authority

c) With the express consent of the owner

In the event of international data transfer, the Company will ensure compliance with the applicable legal provisions.

9. RIGHTS OF THE DATA SUBJECT

The owner of the data may exercise the following rights, in accordance with Law 81:

• Right of access

• Right to rectification

• Right of cancellation

• Right to object

• Right of portability, when applicable

To exercise these rights, the owner may communicate with the Company through the channels indicated in this policy.

10. MODIFICATIONS TO THE POLICY

SYNERA MANAGEMENT S.A. reserves the right to modify this Privacy Policy at any time in response to regulatory changes or internal adjustments. Modifications will be published on the website in due course.

11. CONTACT DETAILS

For queries related to this Privacy Policy or the processing of personal data, the owner may contact:

SYNERA MANAGEMENT S.A.

E-mail: customerservices@syneramanagement.biz

Phone: +507 310-8190