These Personal Data Processing and Protection Policies (hereinafter, the “Policies”) have been drafted in accordance with the provisions of Article 42 of the Constitution of the Republic of Panama.

1. Data Controller

These Personal Data Processing and Protection Policies (hereinafter, the “Policies”) have been drafted in accordance with the provisions contained in Article 42 of the Constitution of the Republic of Panama.

2. Purpose and Objectives of Personal Data Processing

Legal Solutions Latam S.A. collects, stores, and uses its clients’ personal data for the purpose of building its client database for the following purposes: commercial, promotional, and marketing of its products and services in pursuit of its corporate purpose.

3. Prior Authorization from Legal Solutions Latam S.A. Clients for the Processing of Personal Data

The processing of personal data by Legal Solutions Latam S.A. requires the prior authorization of the data subjects (users of Legal Solutions Panama), which must be requested no later than at the time of collection of the personal data.

4. Data Protection Officer

The department responsible for personal data protection at Legal Solutions Latam S.A. is the Marketing Department of Legal Solutions Latam S.A. (hereinafter, the “Personal Data Protection Officer”), which will process requests, inquiries, and complaints from data subjects exercising their right to access, update, correct, and delete their personal data, as well as revoke their authorization for the processing thereof. The Personal Data Protection Officer can be contacted at Ave. Samuel Lewis and Calle 34E, Obarrio. Torre Generalli, 20th Floor, Panama City, Phone: 67736021, email info@legalsolutionspanama.com. Data subjects may at any time request that the Data Protection Officer inform them about the Policies, and about any changes or modifications thereto.

5. Rights of Data Subjects

Data subjects shall have the following rights: a) To access, update, and correct their personal data with Legal Solutions Latam S.A. This right may be exercised, among other things, with respect to data that is partial, inaccurate, incomplete, fragmented, misleading, or data whose processing is expressly prohibited or has not been authorized. b) To request proof of the authorization granted to Legal Solutions Latam S.A., in its capacity as the data controller. c) To be informed by Legal Solutions Latam S.A., upon request, regarding how your personal data has been used. d) To revoke consent and/or request the deletion of your personal data when the processing does not comply with constitutional and legal principles, rights, and safeguards. e) To access, free of charge, your personal data that has been processed.

6. Procedure for Exercising Rights

Data subjects have the right to know whether their personal data is being processed, as well as the scope, conditions, and general nature of such processing. To this end, data subjects have the right to request their personal data from the Data Protection Officer described in section 4 of this document, attaching a copy of their identification document to the request. 

6.2. Right to Access Personal Data

Data subjects or their successors may access the personal data of the data subjects stored in the database of Legal Solutions Latam S.A. To do so, they must direct their requests to the Data Protection Officer described in section 4 of this document, attaching a copy of their identification document to the request. The Data Protection Officer will respond to requests within a maximum of ten (10) business days from the date of receipt. If it is not possible to address a particular inquiry within that timeframe, the Data Protection Officer will inform the data subject in writing, explaining the reasons for the delay and indicating the date by which the inquiry will be addressed, which in no case may exceed five (5) business days following the expiration of the initial timeframe.

6.3. Complaints

Data subjects or their successors who believe that the information contained in the Legal Solutions Latam S.A. database should be corrected, updated, or deleted, or who become aware of an alleged breach of any of the duties set forth in Article 42 of the Constitution of the Republic of Panama, may file a complaint with the Data Protection Officer described in Section 4 of this document, which will be processed in accordance with the following rules: a) The complaint shall be filed by means of a request addressed to the Personal Data Protection Officer, including the data subject’s identification, a copy of their identification document, a description of the facts giving rise to the complaint, their address, and any supporting documents to be submitted. If the complaint is incomplete, the Personal Data Protection Officer will request that the data subject correct the deficiencies within five (5) calendar days of receiving the complaint. If two (2) months have elapsed since the date of the request and the complainant has not submitted the required information, it will be understood that the complainant has withdrawn the complaint. b) Once the complete complaint is received, a note stating “complaint pending” and the reason for it will be included in the corresponding Legal Solutions Latam S.A. database within a period not exceeding two (2) business days. This notation shall remain in place until a decision is made on the complaint.
c) The maximum timeframe for addressing the complaint shall be fifteen (15) business days, counted from the day following the date of receipt. If it is not possible to address the complaint within this period, the Data Protection Officer will inform the data subject of the reasons for the delay and the date by which the complaint will be addressed, which in no case may exceed eight (8) business days following the expiration of the initial period. 

6.4. Request to Revoke Consent and/or Delete Personal Data

Data subjects may at any time request that the Data Protection Officer described in Section 4 of this document delete their personal data and/or revoke the consent granted for the processing thereof by filing a complaint.

7. Information Security

Legal Solutions Latam S.A. is committed to the proper processing of data subjects’ personal data, preventing unauthorized access by third parties that could allow them to access, compromise, modify, disclose, or destroy the information stored in its databases. For this reason, Legal Solutions Latam S.A. has security protocols and access controls in place for its information systems, storage, and processing, including physical security measures for this purpose.

8. Effective Date of the Policies

These Policies take effect on April 1, 2019, and will remain in effect for as long as Legal Solutions Latam S.A. exists. The Legal Solutions Latam S.A. customer database will be maintained for as long as is reasonable and necessary, in accordance with the purposes that justified the processing, taking into account the applicable provisions regarding the matter in question and the administrative, accounting, tax, legal, and historical aspects of the information.

LEGAL SOLUTIONS LATAM S.A., in compliance with the provisions of Article 42 of the Constitution of the Republic of Panama, hereby informs you that its database contains information previously provided by you, which has been collected for commercial and marketing purposes in pursuit of our corporate purpose.

In accordance with our Personal Data Processing and Protection Policies, we inform you that your personal data is treated confidentially, and the Company guarantees its security, confidentiality, and privacy.

The Company requires your authorization to continue processing your personal data to fulfill the purposes described above.

If you wish to have your personal data removed from the Company’s database, please notify us in writing at Ave. Samuel Lewis and Calle 34E, Obarrio. Torre Generalli, 20th Floor, Panama City, Phone: 67736021, email info@legalsolutionspanama.com, within thirty (30) business days from the date of receipt of this notice. If, after the aforementioned period, we do not receive a communication from you in accordance with the terms described above, the Company will be authorized by you to continue using your personal data for the same purposes.

The foregoing is without prejudice to your right to access, update, correct, and delete your personal data at any time under the terms set forth in Article 42 of the Constitution of the Republic of Panama.