Privacy Policy

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

The Veritran Group operates in several different countries. Because of this, it has an obligation to inform users of any matters concerning 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 Data Owner and using your personal data solely for the purposes described in this privacy policy, for which your authorization has been obtained in advance. Attached to this document, you can find the contact details of the Processing Responsible Parties 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 regarding 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 can use this email to submit any inquiries, requests, complaints or claims related 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 about an identified or identifiable natural person. An identifiable natural person is any person whose identity can be determined, either directly or indirectly, particularly by means of an identifier, such as a name, an identification number, location data, an online identifier or one or more elements related to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Processing Party: The natural or legal person who processes personal data on behalf of the data processing responsible party.
Business Group: A group consisting of a company that exercises control and its controlled companies.
Processing Responsible Party: The natural or legal person, who, either alone or together with others, carries out the processing of the data and determines the purposes and means of it.
Owner: It is the natural person whose personal data is being processed.
Processing: It refers to any set of operations carried out using personal data or sets of personal data, such as the collection, use, access, maintenance, modification, extraction, consultation, using, dissemination, deletion or any other form of access enabling, comparison or interconnection, limitation, deletion 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 regard 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 and bulletins. In addition, data that is voluntarily provided by the user when using our website or interacting on social networks.

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

Category	Example	Group
Contact details.	Names, contact addresses, corporate email, professional telephone number, position, sector, country, as well as any other details that you give us through our contact forms, e-mail, social networks, events, among others.	Clients, future clients, suppliers, collaborators, press.
Data related to the agreement.	Details of the services used, representatives of signatory entities, corporate email addresses, bank information, tax information, among others.	Clients, future clients, suppliers, collaborators.
Navigation data.	Websites visited in our online offering, cookies, pixels, IP addresses, browser and device features, language preferences, referral URLs, among others.	Website visitors.
Data related to careers.	Professional experience, address, photography, education, and any other information you want to share in your resume, cover letter or candidate profile on social networks.	Clients, future clients, suppliers, collaborators.
Data for marketing activities.	Information that you provide in the context of a webinar, a podcast or an event organized by Veritran, a post on our blog, website, etc. (for example, photography, participation in a recording, etc.	Clients, future clients, suppliers, collaborators.
Data related to the employment relationship.	Name and identification of the employee, family group, address, telephone number, name of spouse or permanent partner and beneficiaries, name and identification of children, medical records, social security numbers, medical insurance policy, age, date of birth, information regarding examinations, health conditions, medications they use, medical authorizations, among others; resume, education, experience, relationships with entities, relationships with companies; salary and other payments; pension contributions; balance of debts; legal proceedings, foreclosure proceedings; information on affiliation to employee funds, unions; employment contract; work history of the employee; psychological examination report; work-related medical records of the worker; fingerprint information; photographic records, union membership, academic information, immigration data.	Employees.

Veritran does not process data related to children or adolescents. The data processed is provided and authorized by the owners of such data.

PURPOSES OF DATA PROCESSING

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

To communicate with our clients about the services we provide, including conferences, seminars, forums, and bulletins, among others.
To identify key contacts within a target company for the purpose of carrying out or starting business relationships.
To address your inquiries, questions, complaints or claims.
For marketing purposes, to segment the information and content that you receive to provide services and products that are interesting to you.
For statistical purposes that allow us to learn about your interactions on social networks and on the website with regard to our products and services. To learn about the number of user visits from different countries and the frequency of access to websites and social networks.
In the use of IP addresses or location identifiers of the users accessing the website.

HOW IS DATA COLLECTED

The personal data that Veritran uses for the purposes described above is mainly provided by the data owner. However, some data is obtained through the website 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: it 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 owners’ contact details and identification information.
Download Form: It can be found in the Market Insights and Success Stories sections. The form requests the owners’ contact details and identification information.
Press Form: It is a short questionnaire where contact details are requested.
Provided by you via 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 commercial executives.
Information that is 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 that use our website. These data are used for statistical purposes, which allow us to improve our operation.
Some data may be obtained from other personal data that you have provided, through your website, when you send or communicate by email, when you attend virtual or face-to-face seminars or when you provide data through social networks or interactions hereby, with us.

OUR PLATFORM

We retain personal data when we have a valid legal basis for doing so. When we no longer have legal basis for processing personal data, we will delete or add it or, if this is not possible (for example, because the personal data has been stored in backup files), we will store it securely and isolate it from any other processing until its deletion is possible. We may retain personal data to comply with our legal or regulatory obligations. In any case, when these obligations cease, personal data will be deleted from our systems and records, as well as from those of our subcontractors, if any, or will be archived or anonymized in a way that can no longer be identified.

SOCIAL MEDIA

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 processing the data of its users, followers, or people who comment on them. It also exempts itself from any type of liability derived from users and followers’ comments 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 to perform the 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 located in the EU, Facebook Ireland Ltd., (“Facebook “). This tool allows us to track user behavior after they have been redirected to the provider's website when clicking on a Facebook ad, allowing us to measure the effectiveness of Facebook ads for statistical and market research purposes. 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 can link this information to your Facebook account and also use it for its own promotional purposes, in compliance with Facebook's data usage policy. A cookie can also be stored on your computer for these purposes.

LinkedIn: This site uses the LinkedIn online advertising tool to track your behavior as a user when you have seen or interacted with advertisements on LinkedIn. This gives us a better overview of LinkedIn campaigns success and allows us to continuously optimize these campaigns. The pixel tag loads to or from your device when you respond to an advertisement that we publish 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 behavior as a user. The pixel tag is not used to identify you as an individual.

Twitter: This website uses 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 seen or interacted with ads on Twitter. This gives us a better overview of the Twitter campaigns success and allows us to continuously optimize these campaigns. The pixel tag loads to or from your device when you respond to an advertisement that we publish on Twitter, 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 behavior as a user. The pixel tag is not used to identify you as an individual.

Google: This website uses (i) Google Analytics, a web analysis service from Google, Inc; or if you are in Europe, Google Ireland Ltd. (“Google”). Google Analytics uses a specific form of cookie, which is stored on your computer and allows an analysis of its use on 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 the anonymous registration 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 the activities of the website, which allows 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 operation of our site (for example, to detect navigation problems); (ii) Google Ads to draw attention to our offers with the help of advertising materials on external websites. With the advertising campaigns data, we can determine the success of the individual advertising measures. To do this, we use cookies from ad servers, through which certain parameters can be used to measure success, such as the insertion of advertisements or user clicks. If you access our website through a Google advertisement, 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 of the advertising measures used are particularly effective. We do not receive more data because of the use of advertising material; in particular, we cannot identify users based on this information. For this cookie, the unique identifier of the cookie, the number of ad impressions per location (frequency), the last impression (relevant to post-viewing conversions) and the opt-out information (states that the user no longer wants to be redirected) are stored as analysis values. We have no influence on the scope and subsequent use of the data that arises from the use of this tool by Google, and we therefore inform you according to our knowledge: By integrating ad conversion, Google receives information that you interacted with the appropriate element on the Internet or clicked on one of our advertisements. If you are registered with a Google service, Google can associate your visit to your account. Even if you are not registered with Google or logged in, providers may obtain and store your IP address; (iii) Google Tag Manager, this service allows you to manage website tags through an interface. Google Tag Manager only implements tags. This means that no cookies are used, and no personal data is stored. The 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 the domain or at cookie level, this is still valid for all tracking tags, if implemented with the Google Tag Manager.

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

Salesforce: The website uses database technology from Salesforce.com, Inc. It is mainly used in customer relationship management (CRM) to manage and follow 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. The personal data used for these purposes includes relevant commercial information, such as: contact details, publicly available information (for example, Board of Directors membership, published articles, press releases, your public publications on social media sites if relevant for business purposes), your responses to the addressed email (including web activity following links in our emails), the website activity of registered users of our website and others commercial information included by Veritran professionals based on their personal interactions with you.

Spotify: This site uses Spotify statistics and measurement tool, using the website 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 that 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 managed by other organizations. This privacy policy applies only to our website, not to the external websites we are linked to, 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 corresponding YouTube or Vimeo websites, and their respective privacy policies will apply.

DATA RETENTION TIME

Veritran keeps personal data 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 fulfils 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 files), it is stored under the necessary security measures until it is possible to delete them. 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.

OWNERS’ RIGHTS

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 treatment to which your data will be submitted;

ii) Know what personal data of yours we are processing. Request information about it;

iii) Correct, complete and update their personal data at any time;

iv) You have the right to request the deletion or deletion of your personal data;

v) You can require that the treatment be limited only to the authorized treatment and for the established purpose;

vi) The Data Owner has the right to withdraw consent to the processing of the data, requesting that they 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 processing responsible party;

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 interested party.

ix) When the processing of your data requires your consent, you can refuse to give it. Likewise, if you have given your consent for the processing of your data, it can be revoked at any time.

If the deletion of data necessary for compliance with legal obligations is requested, Veritran may reject your request. The Data Owner can exercise their rights at any time through our contact channels established for that purpose. If you have complaints about the processing to which your data is being submitted, you can 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, type of browser, type of operating system, date and time in which you logged in or out, web pages visited, searches performed and advertisements consulted.

Veritran uses the following cookies on its website:

Type of cookies	Purpose
Necessary and operational.	They are essential for the website to be used by the users and to guarantee safe browsing.
Marketing.	They are used to track visitors on web pages. The intention is to show ads that are relevant and attractive to individual users.
Statistics.	Its 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 in the appearance or behavior of the site.
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 want to have 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 Policy for the Protection of Personal Data. In addition, it has technical and administrative controls to ensure the security, confidentiality, integrity and protection of your personal data. We have technical and human measures in place to ensure proper processing of your data. We have a Comprehensive Program (Internal Program) to manage the activities that contribute to regulatory and legal compliance, based on the principles of information security. We comply with the General Regulation for the Protection of Personal Data (GDPR). In addition, we have earned 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 the processing of your personal data by Veritran, 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 recommended that you periodically check the website to be aware of possible changes or updates to the Privacy Policy.

Note: If, after reading this document, you disagree with the processing of your personal data, we recommend that you refrain from registering on any 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: Avenida Libertador Bernardo O’Higgins 1316, 8320000, Santiago de Chile

Veritran Peru SA: Shopping Center, Calle Artesanos 150 — 128, Santiago de Surco, 15039, Peru.

Veritran LLC: 78 SW 7 Street suite 800, Miami, Florida, 33130.

Veritran Guatemala SA: Avenida reforma 6-20 Zona 9, Guatemala.

Crumarel SA: Brandzen Coronel 1956 Apto 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, S.L.: TAX NUMBER: B01766641; Avenida Diagonal, 601 — P.8, Barcelona, 08028, Barcelona, Spain (“Veritran Europe”).

Veritran Colombia S.A.S.: TAX number: 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”).

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