Privacy Policies

In compliance with current regulations on Personal Data Protection, this privacy policy describes how the Veritran Group processes users' personal data obtained through our website, platform, social media and related services, such as our in-person and virtual events.

The Veritran Group operates in several different countries. Due to this, it is obliged to inform users about any matter related to the processing of their personal data, which is classified by the company as "Strictly Confidential" information.

The Veritran Group (Veritran Holding LTD; On Time Mobile SA de CV; Veritran Colombia SAS; Veritran Perú SA; Veritran LLC; Veritran Guatemala SA; Crumarel SA; Veritran SA; Veritran SA; Tralmey SA; Veritran Brasil Soluções Digitais em Informatica LTDA and Veritran Europe SL) will process your personal data in accordance with the legislation in the applicable country or territory, thus guaranteeing your rights as a Data Subject and using your personal data only for the purposes described in this privacy policy, for which your prior authorization has been obtained. Attached to this document, you can find the contact details of the Data Controllers in each of the countries or territories where the Veritran Group operates.

The information collected will be treated under the processing parameters defined in this document. If you have any questions about the processing of your data or questions related to the privacy and security of your information, you can contact us at: GDPR@veritran.com. You may use this email to send any queries, requests, complaints or claims relating to the processing of your information.

Glossary

For a better understanding of this document, key concepts will be defined when referring to the processing of personal data. The definitions have been obtained from current legislation.

Personal Data: Any information relating to an identified or identifiable natural person. An identifiable natural person is one whose identity can be determined, either directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors relating to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data Processor: The natural or legal person who processes personal data on behalf of the data controller.
Business Group: A group consisting of a controlling company and its controlled companies.
Data Controller: The natural or legal person who, either alone or jointly with other persons, carries out the processing of the data and determines the purposes and means thereof.
Owner: The natural person whose personal data is being processed.
Processing: Any set of operations performed on personal data or sets of personal data, such as collection, use, access, maintenance, modification, retrieval, consultation, use, disclosure, deletion or otherwise allowing access, comparison or combination, restriction, erasure or destruction.

Data processed by Veritran

In order to carry out our business activities, Veritran collects only the data necessary for that purpose. The personal data we process depends on the relationship authorized by the user with respect to Veritran. Therefore, it is possible that, at certain times and with due authorization, we use your data to send and promote events and send newsletters. In addition, data that the user voluntarily provides when using our website or interacting on social networks.

The following table contains a summary of the types of data we collect and process:

Category	Example	Collectives
Contact information.	Names, contact addresses, corporate email, professional phone number, position, sector, country, as well as any other information you provide us through our contact forms, email, social media, events, etc.	Clients, future clients, suppliers, collaborators, press.
Datos relativos al contrato.	Detalle de los servicios utilizados, representantes de entidades firmantes, direcciones de correo corporativo, información bancaria, información fiscal, etc.	Clientes, futuros clientes, proveedores, colaboradores.
Browsing data.	Web pages visited in our online offering, cookies, pixels, IP address, browser and device characteristics, language preferences, referring URLs, etc.	Website visitors.
Professional information.	Professional experience, address, photograph, academic background, and any other information you wish to share in your CV, motivation letter, or candidate profile on social media.	Clients, future clients, suppliers, collaborators.
Data for marketing activities.	Data that you provide in the context of a webinar, podcast or event organised by Veritran, entry on our blog, website, etc. (for example, photograph, participation in a recording, etc.)	Customers, future customers, suppliers, collaborators.
Data related to the employment relationship.	Name and identification of the worker, family group, address, telephone number, name of spouse or permanent partner and beneficiaries, name and identification of children, medical history, social security affiliations, medical insurance, age, date of birth, information on studies, health status, medications used, medical authorizations, among others; resume, education, experience, links with entities, links with companies; salary and other payments; pension contributions; debt balance; legal proceedings, seizures; information on membership in employee funds, unions; employment contract; employee's work history; psychological evaluation report; occupational clinical history of the worker; fingerprint; photographic record, union membership, academic information, immigration data.	Employees.

Veritran no procesa datos relacionados con niños o adolescentes. Los datos procesados son proporcionados y autorizados por los propietarios de dichos datos.

Purposes of data processing

In all cases, the processing of your data is aimed at achieving development in commercial terms and sending advertising to our customers. It is important to note that some of your data may be used to comply with legal obligations or when facing judicial processes or administrative procedures. That said, your data will be processed to provide information that allows us, among other activities, to achieve the following:

Communicate with our clients about the services we offer, including conferences, seminars, forums, newsletters, among others.
Identify key contacts within a target company in order to conduct or initiate business relationships.
Respond to your queries, questions, complaints or claims.
For marketing purposes, segment the information and content you receive to provide services and products that are of interest to you.
For statistical purposes to allow us to understand your interactions on social media and on the website regarding our products and services. To understand the number of visits from users from different countries and the frequency of access to websites and social media.
In the use of IP addresses or location identifiers of users accessing the website.

How is data collected?

The personal data that Veritran uses for the purposes described above are mainly provided by the data subject. However, some data is obtained through the website's cookies. Before obtaining the data, the user must authorize the use of cookies when accessing the website. As a result, your data is obtained through the following means:

Full form: This can be found on the website homepage, in the Contact Details section, Business Solutions and in the main sections of the website. This form requires the contact details and identification information of the owners.
Download form: can be found in the Market Insights and Success Stories sections. The form requests contact details and identifying information of the owners.
Press Form: This is a short questionnaire requesting contact details.
Provided by you by email.
Collected through the use of cookies and through our website. Note: We only collect data from cookies that you have previously authorized before accessing our website.
Through our sales executives.
Information provided by the user on our service channels or through social networks.
When the user registers to participate in virtual or in-person events.
Automatically, from devices using our website. This data is used for statistical purposes, allowing us to improve our operation.
Some data may be obtained from other personal data that you have provided, such as through your website, by sending or communicating by email, by attending virtual or in-person seminars or by providing data through social media or interactions with us.

Our platform

We retain personal data when we have a valid legal basis to do so. When we no longer have a legal basis to process personal data, we will either delete or aggregate it or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible. We may retain personal data to comply with our legal or regulatory obligations. In any event, when these obligations cease, personal data will be deleted from our systems and records, as well as those of our subcontractors, if any, or archived or anonymized in such a way that it is no longer identifiable.

Social networks

Veritran has the following profiles on the main social networks on the Internet: LinkedIn, Instagram, Facebook, Twitter, YouTube and our own Blog, and is responsible for the processing of the data of its users, followers or people who comment on them. It is also exempt from any type of responsibility derived from the comments of users and followers on its social networks.
Veritran may use the profiles described above to inform its customers and other parties about topics that could be of interest.

Recipients of personal data

Wagtail:

This website uses Wagtail for statistical analysis of visitor traffic, for platform and hosting services and for user registration and authentication.

Facebook:

This website uses the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Inc., or, if you are located in the EU, Facebook Ireland Ltd., ("Facebook"). This tool allows us to track user behavior after being redirected to the provider's website by clicking on a Facebook ad, allowing us to measure the effectiveness of Facebook ads for statistical purposes and market research. The data collected in this way is anonymous to us, which means that we do not see the personal data of individual users. However, this data is stored and processed by Facebook, so you will be informed based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's data usage policy. A cookie may also be stored on your computer for these purposes.

LinkedIn:

This site uses LinkedIn's online advertising tool to track your user behavior when you have viewed or interacted with ads on LinkedIn. This gives us a better overview of the success of LinkedIn campaigns and allows us to continuously optimize these campaigns. The pixel tag is loaded onto or from your device when you respond to an advertisement we place on LinkedIn, for example by clicking on a link to our website. In this context, a pixel ID is created and stored in a cookie so that we can temporarily analyze your user behavior. The pixel tag is not used to identify you as an individual.

Twitter:

This website uses the Twitter online advertising tool "Conversion Tracking" and the associated pixel technology from Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter"). This tool allows us to track your user behavior when you have viewed or interacted with advertisements on Twitter. This gives us a better overview of the success of Twitter campaigns and enables us to continuously optimize these campaigns. The pixel tag is loaded onto or from your device when you respond to an advertisement we publish on Twitter, for example by clicking on a link to our website. In this context, a pixel identifier is created and stored in a cookie so that we can temporarily analyze your user behavior. The pixel tag is not used to identify you as an individual.

Google:

This website uses (i) Google Analytics, a web analytics service provided by Google, Inc.; or if you are located in Europe, Google Ireland Ltd. (“Google”). Google Analytics uses a specific form of cookie, which is stored on your computer and enables an analysis of your use of our website. The information about your use of this website generated by the cookie is generally transmitted to a Google server in the United States and stored there. Google Analytics is used on this website, including the code “gat._anonymizeIp();” to ensure anonymous recording of IP addresses. In this way, your IP address is shortened by Google within the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and shortened there. Google uses this information on our behalf to analyze your use of this website in order to compile reports on website activities, enabling us to analyze the use of our website, improve our offer and make it more interesting for you as a user. In addition, we obtain information about the functioning of our website (e.g. to detect navigation problems); (ii) Google Ads to draw attention to our offers with the help of advertising materials on external websites. With the data from advertising campaigns, we can determine the success of individual advertising measures. To do this, we use cookies from advertising servers, through which certain parameters can be used to measure success, such as the insertion of ads or clicks by users. If you access our website via a Google ad, Google Ads stores a cookie on your device. These cookies are not intended to identify you individually. We only receive statistical evaluations from Google. Based on these evaluations, we can recognize which advertising measures used are particularly effective. We do not receive any further data due to the use of advertising material; in particular, we cannot identify users based on this information. For this cookie, the unique cookie ID, the number of ad impressions per placement (frequency), the last impression (relevant for post-view conversions) and opt-out information (indicates that the user no longer wishes to be redirected) are stored as analysis values. We have no influence on the scope and further use of the data arising from the use of this tool by Google, and therefore we inform you according to our knowledge: By integrating conversion advertising, Google receives information that you interacted with the appropriate element on the Internet or clicked on one of our ads. If you are registered with a Google service, Google can associate your visit with your account. Even if you are not registered with Google or are not logged in,(iii) Google Tag Manager, this service allows you to manage website tags via an interface. Google Tag Manager only implements tags. This means that no cookies are used and no personal data is stored. Google Tag Manager activates other tags, which in turn collect data if necessary. However, Google Tag Manager does not have access to this data. If a deactivation occurred at domain or cookie level, this remains valid for all tracking tags, if they were implemented with Google Tag Manager.

Huawei Cloud:

The site is hosted on Huawei Cloud and all content is stored there.

Salesforce:

The Website uses Salesforce.com, Inc. database technology. It is primarily used in customer relationship management (CRM) to manage and track our marketing efforts. Our CRM databases include personal data belonging to our customers and other entities with whom we already have a business relationship or want to develop one. Personal data used for these purposes includes relevant business information such as: contact details, publicly available information (e.g. membership of the Board of Directors, published articles, press releases, your public posts on social media sites if relevant for business purposes), your responses to targeted email (including web activity following links in our emails), website activity of registered users of our website, and other business information included by Veritran professionals based on their personal interactions with you.

Spotify:

This site uses Spotify's statistics and measurement tool, using the website's own cookies that capture data such as name, email and preferences. These tools allow us to track your behavior as a user when you have interacted with our podcasts or our Veritran profile on Spotify, we can track the type of content our users listen to and learn what their topics of interest are. We can analyze your interactions with our podcast.

Links to third-party sites

Our website contains links to external websites operated by other organisations. This privacy policy applies only to our website, not to the external websites to which we are linked, which will have their own privacy policies. We are not responsible for these external websites or their privacy policies and practices. In addition, if you have accessed our website from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external website and we recommend that you check the privacy policy of that external site. In particular, we inform you that by selecting "WATCH VIDEO" in any of the sections of this website, you will be redirected to the relevant YouTube or Vimeo websites, and their respective privacy policies will apply.

Data retention time

Veritran retains personal data for as long as it is necessary for the purposes set out for the processing mentioned above and as long as there is a valid legal basis for doing so. As soon as the data has fulfilled the purpose for which it was collected, it will be deleted from the databases. If it is not possible to delete personal data (for example, data that has been stored in backup archives), it will be stored under the necessary security measures until deletion is possible. Veritran may retain personal data to comply with its legal or regulatory obligations. Once these obligations cease, the data will be deleted from the archive.

Rights of the holders

We know that the processing of your personal data must be carried out under all the guarantees of your Fundamental Rights. Therefore, it is a priority for Veritran that you know your rights. As the data owner, you have the right to:

i) Know the type of processing to which your data will be subjected;
ii) Know what personal data of yours we are processing. Request information about it;
iii) Correct, complete and update your personal data at any time;
iv) You have the right to request the deletion or erasure of your personal data;
v) You can demand that the processing be limited only to the authorized processing and for the established purpose;
vi) The data owner has the right to withdraw consent for the processing of the data, requesting that it no longer be processed;
vii) In some cases, you can request a copy of your personal data in a structured, commonly used and machine-readable format for transmission to another data controller;
viii) You can request that decisions not be made based solely on the automated processing of your data. This includes the development of profiles that produce legal effects or significantly affect the data subject.
ix) When the processing of your data requires your consent, you may refuse to give it. Similarly, if you have given your consent to the processing of your data, you may revoke it at any time.
If the deletion of data necessary to comply with legal obligations is requested, Veritran may reject your request. The data subject may exercise his or her rights at any time through our contact channels established for that purpose. If you have complaints about the processing to which your data is subjected, you may file a complaint with the competent authority for the protection of personal data.

Use of cookies on the website

Cookies are small files that web servers send to your computer to store and retrieve information about visitors, as well as to ensure the proper functioning of the website. Our site uses cookies for different purposes, such as collecting your user ID, session ID, region from which you access the website, browser type, operating system type, date and time you logged in or out, web pages visited, searches performed and advertisements viewed. Veritran uses the following cookies on its website:

Type of cookies	Purpose
Necessary and functional.	So that the website can be used by users and safe navigation is guaranteed.
Marketing.	Son utilizadas para rastrear a los visitantes en las páginas web. La intención es mostrar anuncios relevantes y atractivos para los usuarios individuales.
Statistics.	Their function is to understand how visitors interact with the website in order to provide usage information.
Preferences.	Preference cookies allow the website to remember information about changes to the way the website behaves or looks.
Third parties.	These are cookies from other websites such as Facebook, Instagram or Twitter that are used when the user enters our social networks or third-party pages associated with Veritran.

If you wish to obtain additional information about the cookies we use, we invite you to consult our cookie policy available at the following link: https://www.veritran.com/en/cookies-policy/.

We take care of your data

Veritran is committed to taking care of the personal data of its users. For this reason, it has a Personal Data Protection Policy. In addition, it has technical and administrative controls to guarantee the security, confidentiality, integrity and protection of your personal data. We have technical and human measures to ensure the proper processing of your data. We have a Comprehensive Program (Internal Program) to manage activities that contribute to regulatory and legal compliance, based on the principles of information security. We comply with the General Data Protection Regulation (GDPR). In addition, we have obtained the ISO 27001 security certification. For more information, please visit our Compliance website: https://www.veritran.com/en/compliance-and-certifications/.

Contact

If you have any questions about Veritran's processing of your personal data, you can contact us at: gdpr@veritran.com.

Policy Updates

Veritran reminds you that our Privacy Policy may be modified or updated at any time. If substantial changes are made, you will be notified by email. We recommend that you periodically consult the website to be aware of possible changes or updates to the Privacy Policy.
Note: If, after reading this document, you do not agree with the processing of your personal data, we recommend that you refrain from registering on any of our digital channels, interacting with our website or authorizing the processing of your personal data.

Appendix

Veritran Holding, LTD: Level 1, Palm Grove House, Wickham´s Cay 1, Rod Town, Tortola.
On Time Mobile SA de CV: Montes Urales 415, 1st floor, of.3 Colonia Lomas de Chapultepec I Miguel Hidalgo Delegation Section, Mexico.
Chile Agency: Libertador Bernardo O'Higgins Avenue 1316, 8320000, Santiago de Chile
Veritran Peru SA: Shopping Center, Artesanos Street 150 — 128, Santiago de Surco, 15039, Peru.
Veritran LLC: 78 SW 7 Street suite 800, Miami, Florida, 33130.
Veritran Guatemala SA: Reforma Avenue 6-20 Zone 9, Guatemala.
Crumarel SA: Brandzen Coronel 1956 Apt 10, Montevideo, Uruguay.
Veritran SA: Av. Corrientes 222, C1043 AAP, Buenos Aires, Argentina.
Veritran Brazil Digital Solutions in Informatica LTDA: Alameda Mamoré, No. 687, 06454-040, Brazil.
Veritran Europe, SL: NIF: B01766641; Avenida Diagonal, 601 — P.8, Barcelona, 08028, Barcelona, Spain (“Vertran Europe”).
Veritran Colombia SAS: NIT: 900.631.710-3; Calle 94 No. 14-73 block n. 30, Multicentro Empresarial y Comercial la Villa, Pereira, Risaralda, Colombia; (+57 6) 3110513 (“Veritran Colombia”).