POLICY:
This Privacy and Data Management Policy ("Policy") describes how the hm pools & more S.A. ("we" or "hm pools") collects, uses, shares and protects information when you interact with us, whether you provide your personal information or by any other means ("Services").
PURPOSE:
The purpose of this Policy is to protect the privacy of our clients and other data owners (defined in section three of this Policy) of personal data, for which we collect and use your information for the sole purpose of offering a better service and better fulfilling our corporate mission, in accordance with the purposes and limitations described in this Policy.
Comply with the applicable legislation on privacy and data protection, in order to inform the relevant aspects in relation to collecting, storing, using, circulating, transmitting and transferring personal data that hm pools performs with personal data, by virtue of the authorization that has been granted by the data owner to advance said use or treatment.
hm pools describes in this Policy, the corporate guidelines, subject to applicable law, that the company complies with for the use or processing of personal data, and indicates the rights that the data owner possesses, as well as the internal and external procedures that exist for their use.
SCOPE: Content and framework
This Policy applies to the physical databases and / or databases stored in electronic or digital means of hm pools.
The Policy will be binding for all processes, procedures and tasks where personal data, employees, suppliers, contractors and advisors of companies or any person are captured,
used, circulated, processed, stored, processed, transmitted and transferred. that, by virtue of a commercial or legal relationship, provides personal data to hm pools..
I. POLICY DEVELOPMENT
1. hm pools includes in all its activities, procedures and mechanisms the option to exercise the rights of data owners in the protection of their personal data.
2. Data collection will be limited to the personal data that is pertinent and adequate for the purposes of hm pools corporate purpose. We may collect the following categories of information:
• Contact information and any other information you choose to include when you communicate with us by email, postal mail, telephone or other channels;
• Profile and subscription information, your name, postal address, email address, telephone number, and usage and subscription preferences, which may include registering for some of our Services or communications from us;
• Device information when you use our technology platforms, including model, serial number, device location, usage data, and operational information;
• Biographical information when you inquire or apply for a position with us.
Some of this information may be collected by service providers on our behalf. If you provide us with information about another person, you represent that you have that person's consent to provide us with their information and to allow us to use the information in accordance with this policy.
hm pools will ensure respect for the principles established by the applicable regulations, and will include in its daily activities the responsible handling of information and personal data, as well as the purposes that arise from its collection.
hm pools has implemented relevant procedures and strategies to comply with the rights of the owners.
II. PURPOSES FOR THE PROCESSING OF PERSONAL DATA
hm pools recognizes that the Owner of personal data has the right to guarantee the protection and privacy of their data, considering, in any case, their responsibilities, rights and obligations of hm pools.
Your personal information or data is used by hm pools to:
a) Establish and manage the pre-contractual and contractual commercial, labor, civil and any other relationship that arises by virtue of the fulfillment of a legal or contractual obligation in charge of hm pools.
b) The control and prevention of fraud and money laundering, due diligence, including consultation on restrictive lists, and all related information.
c) Manage the contractual relationship of the employee with hm pools, including the possible signing of employment contracts as applicable.
d) Execute the contracts that have been signed with hm pools.
e) Send the information to government or judicial entities at the express request of the same in the exercise of their functions.
f) Support tax audit processes, external and internal audit.
g) Send and receive messages for marketing, commercial, advertising and/or attention to requests, complaints, claims and suggestions.
h) Register the information of employees (active and inactive).
i) Register the information of suppliers (active and inactive) in the PriceSmart databases.
In order to carry out the purposes described above, your personal data may be disclosed for the purposes set out above to data processors, consultants, contractors and other persons and offices, as appropriate.
hm pools may subcontract to third parties for the processing of certain functions or information.
When we actually subcontract the processing of your personal information to third party parties or provide your personal information to third party parties who are service providers, we advise such third party parties of the need to protect said personal information with appropriate security measures, we prohibit them from using your personal information for their own purposes and we prevent them from disclosing your personal information to others through confidentiality and personal data protection clauses.
Similarly, hm pools may transfer or transmit (as appropriate) your personal data to other companies for reasons of security, administrative efficiency and better service, in accordance with the authorizations that have been granted by the data owners. hm pools has adopted the appropriate measures so that these companies implement in their jurisdiction and in accordance with the laws applicable to them, standards of security and protection of personal data even similar to those provided in this document, and in general, in the hm pools policies on the matter.
How we may share your information with:
• Service providers. We may share your information with service providers who we believe need the information to perform a technology, business, or other professional function for us, such as billing and collections, IT services, maintenance and hosting of our Services, payment processors, marketing, accounting, auditing and tax services, and other professional services.
• Social networks. If you interact with us on social media platforms, the platform may collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking the Facebook "Like" button), both the Platform and your connections on the Platform may see that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
• Affiliates. We share information with other entities in our corporate family, for purposes consistent with this Privacy Policy.
• Corporate event. We reserve the right to transfer to another entity or its affiliates or service providers some or all of your information in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing operation. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information in the same manner as described in this Policy.
• Legal. We may share information as necessary to comply with applicable law, to respond to requests from law enforcement or other judicial or government authorities, or third-party supporters, as permitted by law, and without your consent as necessary to protect our customers, employees or property; in emergency situations; or to enforce our rights under our terms of service and policies.
How we protect your information
We use a combination of physical, technical, and administrative security measures to protect the information we collect through the Services. Although we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices and databases that we operate or that operate on our behalf.
III. RIGHTS OF THE OWNERS
You, as an Owner, have the right to:
• Know, update and rectify your personal data.
• Be informed, upon request, of the treatment, regarding the use that has been given to the personal data.
• Submit to the competent authorities, complaints for violations of the provisions of applicable to data protection laws.
• Revoke the authorization and/or request the deletion of the data.
• Free access to your personal data that has been processed.
IV. ADDITIONAL INFORMATION COLLECTED ONLINE AND RELATED SECURITY
Financial information:
When you visit our website, we may collect information: your network address, your computer's operating system, the browser you use, the site website from which you linked to our page, your activity on our website, the time and date you visited.
V. PERIOD OF VALIDITY OF THE DATABASES AND THE PRIVACY OR DATA PROCESSING POLICY AND hm pools
Your personal data will be processed in accordance with the authorization granted and while the purposes for the treatment remain in force. If our need to use or process your data ceases, it may be removed from our databases unless such data is necessary to comply with an existing legal or contractual obligation.
This Policy and its subsequent updates will become effective upon approval and its corresponding publication on the hm pools website and in the other means of communication implemented by it.
Periodic reviews of the correct application of this Policy may be made jointly with General Management, Human Management, IT Manager, Risk & Compliance, Internal Audit, Data Operators, Information Security Officer or whoever acts on their behalf and other dependencies that the Management of hm pools has designated.
The approved version of this Policy will be posted on hm pools website. It is the duty of all hm pools employees and collaborators to be aware of this policy and take the pertinent actions for its compliance, implementation and maintenance.
The human resources team must ensure that this Policy is disclosed with each incorporation of new employees. The legal area will make the corresponding contractual and legal adjustments so that, in the contracts, agreements and other instruments used for the development of hm pools corporate purpose, confidentiality agreements are signed and include clauses for the protection of personal data that could be subject to treatment in each particular case.
Updates to this Privacy Policy
We may revise or update this Privacy Policy at any time. We will post the updated version on our
Services and may notify you of any significant changes to our Privacy Policy. We will indicate in our Privacy Policy when it was last updated. Your continued use of our Services after such updates will constitute your: (i) acknowledgment of such updates; and (ii) agreement to comply with and be bound by the updated Privacy Policy.
Jurisdiction Specific Notices
Certain jurisdictions may grant additional rights to individuals with respect to the collection and use of the personal information we have collected. For example, you may have the right to request that: (i) we disclose to you any personal information we hold about you; (ii) correct or delete the personal information we have about you (subject to certain exceptions); or (iii) not disclose or sell your information to a third party (excluding qualified service providers).
VI. PETITIONS, INQUIRIES OR CLAIMS
To exercise your rights, file any request, query or claim, or to direct any concern, you may contact hm pools by email info@hmpoolspanama.com.
Revised: November 10, 2023