Comprehensive Personal Data Protection Policy of VortexPay

Informed Consent

The user expressly, informedly, voluntarily, and unequivocally consents to the inclusion of all personal data provided through VortexPay in the databases owned and under the responsibility of VortexPay, as well as to the processing of all their personal data for the purposes described in the following sections of this document and subject to the terms and conditions established therein. Additionally, by using VortexPay, the user accepts and gives their free, express, and informed consent to the terms of this Privacy Policy. We commit to obtaining your consent clearly and transparently. Therefore, the user must read these Privacy Policies carefully. BY ACCESSING, CONNECTING, OR OTHERWISE USING VortexPay, THE USER CONFIRMS THAT THEY HAVE READ, UNDERSTOOD, AGREED, AND ACCEPTED THE TERMS AND CONDITIONS OF THESE PRIVACY POLICIES. IF THE USER DOES NOT AGREE WITH THE TERMS OF THIS POLICY, THE USER SHOULD NOT USE VortexPay.

Data Collected

Through VortexPay, we collect certain data, including personal data. Personal information is information that can identify the user to VortexPay, and your privacy and the security of your information are very important to us. Therefore, we will only request the strictly necessary data for you to use the services that VortexPay offers. To this end, VortexPay may request and process the following data, without this list being exhaustive: Contact information (such as name and surname; addresses, phone number, email); Identity documents; profession, average income, demographic data (such as nationality; date and place of birth, age, gender); a “selfie” photograph; social media information provided by the user; politically exposed person status; declaration regarding the origin and legality of funds; and information that the user provides to us regarding their inquiries or comments. We collect this data at the time of your registration, and we also gather personal information about you when you provide information directly to us or when you interact with us through VortexPay.

Additionally, VortexPay may collect information about the devices on which the application is installed, such as those related to the mobile operator, brand, model, and operating system of the device, geolocation, and may monitor traffic, views, interactions, and any other activity in the application (this data could be collected through the use of cookies, web beacons, pixels, canvas fingerprinting, and/or similar technologies). The user is solely responsible for the truthfulness, accuracy, completeness, currency, authenticity, and certainty of the information provided, and must notify VortexPay immediately of any updates or modifications that are necessary. Notwithstanding the above, VortexPay may verify the personal data and/or information provided – either directly or through third parties – by resorting to public entities, specialized companies, or credit bureaus, among others, which you expressly consent to.

In the event that the user does not provide the personal data that is mandatory for registration and use of the services, or if falsity and inaccuracy are detected in the personal data provided, VortexPay may suspend and/or cancel the user and/or partially or totally disable their access to the VortexPay application and/or its services. This does not prevent VortexPay from reporting such falsities and/or inaccuracies to third parties and/or competent authorities.

Purpose of Processing Personal Data

The data we collect may be used for the following purposes: providing VortexPay services; enabling access to the application and its functionalities; communicating with the user; sending promotional materials and other communications; responding to inquiries; personalizing preferences and visits to VortexPay by our users and offering content tailored to their interests and how they navigate and interact with VortexPay; operating, evaluating, and improving our products and services; collecting supporting documentation and other data justifying any type of operation or transaction; and complying with, preventing illegal activities such as money laundering, tax evasion, and fraud, and enforcing applicable legal requirements, sector-specific regulations, contractual obligations, and our policies. In the event that we intend to use your personal data for purposes other than those described above, we will communicate this specifically at the time of collection.

Furthermore, through VortexPay, we may use third-party analytical services. Web analytics service providers managing these services use technologies such as cookies, network server logs, and web beacons to help us analyze how users use VortexPay. Information collected through these means (including IP address) may be shared with providers of such analytical services and other third parties who may use the information collected to, among other purposes, evaluate the use of VortexPay.

Finally, VortexPay may engage in the use of mass data analytics solutions, commonly known as “analytic solutions,” provided by third parties, which may process data collected through the VortexPay application or website, including details regarding visited screens, interaction patterns (such as screen actions, gestures: clicks, scrolling, etc.), and device details used to access the VortexPay application or website (type, version, model, operating system).

Processing of Minor’s Data

VortexPay recognizes the importance of protecting the privacy of children and adolescents. Minors may use our products and services only if acting through or duly authorized by their parents or legal guardians. To ensure proper handling of personal data of minors, we will respect their best interests and fundamental rights. Accordingly, we will seek explicit consent from parents, mothers, or legal guardians before processing any personal data of a minor. Additionally, we will implement strong and robust security measures to protect minors’ information in accordance with applicable data protection laws. VortexPay is committed to complying with all relevant legal provisions and taking necessary measures to ensure the privacy and security of children and adolescents’ data.

Information We Share

The personal data collected through VortexPay may only be disclosed to third parties in accordance with the terms described in this Privacy Policy. Personal data collected through VortexPay may be disclosed for the purposes previously described to our affiliates, associated entities, branches, agencies, representations, parent companies, subsidiaries, controlled entities, affiliated entities, and any natural or legal person that may be related to VortexPay and/or with whom VortexPay has a commercial relationship to provide services, such as our strategic partners in relation to certain products we offer. We will also disclose such personal data to service providers who provide services on our behalf in accordance with our instructions and the purposes detailed in these Privacy Policies, such as our hosting service providers, cloud storage providers, call centers, and others. We do not authorize these service providers to disclose or disclose your personal data except for uses that are strictly necessary for the provision of services on our behalf or to comply with legal obligations.

VortexPay understands the importance of maintaining the confidentiality of all data that may be collected. Therefore, it is noted that VortexPay and those involved in any phase of personal data processing are bound by professional secrecy regarding such data. VortexPay subscribes to confidentiality agreements and implements policies and processes to ensure the confidentiality of the personal data it processes.

Furthermore, we may disclose your personal data (i) if we are required to do so by applicable law, to law enforcement authorities, or other public officials when legitimately requested, (ii) when we believe such disclosure is necessary or appropriate to prevent physical harm or financial loss, or (iii) in connection with an investigation of fraudulent or illegal activities, or activities suspected of being fraudulent or illegal.

Finally, you authorize us to transfer your personal data in the event of a sale or transfer of all or part of our company or assets (including cases of restructuring, dissolution, or liquidation).

Data Transfers

The User understands and consents that their personal data collected through VortexPay may be transferred for the purposes detailed above and to the parties listed earlier, which may involve international transfers of data to jurisdictions that may not have the same data protection laws as those in Panama or the countries of its subsidiaries and/or may not provide adequate levels of protection under local regulations. When we transfer your personal data to other countries, we will protect them as described in this document and in accordance with applicable law.

Security of Your Personal Data

The data collected will be kept strictly confidential and secure. VortexPay will only use such data as long as your relationship with VortexPay is active and its use is strictly necessary for the fulfillment of the purposes detailed above. In particular, we maintain advanced administrative, technical, and physical security measures designed with privacy in mind from the outset to protect the personal data you provide us from destruction, loss, alteration, unauthorized access, disclosure, or use, whether accidental, unlawful, or unauthorized.

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of the personal data you provide us, VortexPay has implemented certain physical, electronic, administrative, and security procedures to safeguard and secure your personal data collected online. We safeguard your personal data according to established security standards and procedures and continuously evaluate new technology to protect that information. This includes encryption, regular security audits, and protection against online threats. VortexPay ensures that its internal database processes comply with the legal obligations of security and confidentiality imposed by Personal Data Protection Regulations.

We strive to ensure that your privacy is protected by default in our operations and are committed to transparency in our data handling practices and compliance with all applicable privacy laws and regulations. However, you acknowledge that existing technical means providing security are not impregnable, and that despite taking all reasonable security precautions, manipulation, destruction, and/or loss of information may still occur.

Finally, if you believe that your interaction with us is no longer secure (for example, if you believe the security of an account you have with us has been compromised), please notify us immediately using the contact methods provided in the “Contact Information” section.

User Rights and Choices

VortexPay presumes the accuracy of all information provided by the User. Consequently, VortexPay does not verify, nor does it assume the obligation to verify, the accuracy, validity, sufficiency, and authenticity of the data provided by the User. The User is responsible for keeping this information updated at all times. The User may access, modify, rectify, delete, and update their personal data at any time by contacting us as established in the following sections. The User may access the information provided to VortexPay free of charge, at intervals not less than six months, unless they demonstrate a legitimate interest to the contrary. If the data is incorrect, or if the User wishes to update, rectify, or delete it, we will update, correct, or delete that information at their request free of charge. To exercise the rights of access, rectification, updating, or deletion, you must send an email to: [email protected] indicating which right you wish to exercise and following the identity verification process that VortexPay will indicate for this purpose. The information provided by the User will be stored as long as the relationship with VortexPay is active, and for a period of 10 (ten) years thereafter and/or for any additional period required by applicable legislation for accounting and/or legal purposes.

In the event that the information provided by the User to VortexPay is considered incomplete, false, or incorrect at the discretion of VortexPay, the company reserves the right to terminate the present contract without assuming any responsibility, in accordance with the terms stipulated in this Data Protection Policy.

Links to Other Websites

VortexPay may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with us. Typically, linked websites have their own privacy policies or notices, which we recommend that the User reads if they visit any linked websites. We do not assume any responsibility for the content of websites other than our own, nor for the use of such websites, nor for their privacy practices.

Updates to These Privacy Policies

VortexPay reserves the right to make modifications or updates to these Privacy Policies at any time without prior notice, to reflect changes in our practices regarding personal data. In the case of substantial changes, VortexPay may modify the Privacy Policies at any time by notifying the User via email and/or notification within the App, and by publishing an updated version of these Privacy Policies on the website: www.vortex-pay.com with the date of the last modification stated. Any modification to these clauses of the Privacy Policies will take effect on the date indicated in the notification. Within 10 (ten) calendar days following the notification of the modifications, the User may communicate via email if they do not accept them; in that case, the contractual relationship will be dissolved. Once this period has elapsed, it will be considered that the User accepts the new Terms of Privacy Policies, and the contract will continue to bind both parties.

From the moment of their publication through VortexPay, your interaction with us after the introduction of these modifications will signify that the User accepts such modifications.

Contact Information

If the User wishes to contact us to update their data, exercise their rights, or has any questions regarding the scope of this policy and/or concerns about the privacy and/or security of the information provided to VortexPay, they may do so directly through the email address: [email protected].