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Privacy Policy

1. General Conditions.

1.1 Our commitment to privacy. This Privacy Policy (the “Privacy Policy”) indicates the information that Atanor S.R.L (hereinafter “Atanor”) may collect and the use that may be given to that information. It also explains the security measures taken to protect the information, the possibility of the Holders to access their information, and who they may contact at Atanor so that their queries in relation to this Privacy Policy are attended to, and so that any other matters that may arise in this regard are resolved.

1.2. This Privacy Policy complements the General Terms and Conditions of Use of the Site and the Cookies Policy. Everything expressed in this Privacy Policy is in strict compliance with the provisions of Law 18,331 on the Protection of Personal Data, its regulatory decrees and its concordant and modifying regulations (“LPDP”).

1.3. This Privacy Policy is only applicable to this site. If Data Subjects visit another site that is not operated by Atanor, by clicking on advertisements or third-party links, it is recommended that they review the privacy statement posted on the corresponding site to inform themselves about the personal information that may be collected through that particular site and how it will be processed.

2. Application of this Privacy Policy.

2.1. This Privacy Policy applies to the Personal Data provided to Atanor by its Data Subjects – as such terms are defined in art. 4 of the LPDP – and to the management of such personal information in any form, whether oral, electronic or written.

2.2. If we disclose the Personal Data that we hold about Data Subjects to third parties, we will do so respecting the principles of purpose, confidentiality and security, as well as the formal and substantive safeguards established by the LPDP for sharing such Personal Data.

3. Personal Data.

The types of Personal Data that Atanor processes may include Personal Data from unrestricted public access; Personal Data collected by Atanor with consent from its Data Subjects; Personal Data provided to Atanor within the framework of a contractual relationship between Atanor and the Data Subjects; and/or Personal Data collected by Atanor in compliance with a legal obligation.

4. Collection and purpose of use of Personal Data.

4.1. In all cases where the Data Subjects provide Personal Data, they declare that the information provided is true and complete. Likewise, the Data Subjects accept and give their free, express and informed consent for said Personal Data to be processed by Atanor for the purposes reported herein.

4.2. By way of example, Atanor may require Personal Data from employees, contractors, suppliers and/or clients to: evaluate job applications; manage all aspects of the employment relationship with the employee; develop personnel plans; maintain records of illnesses and occupational health programs; protect the safety of Atanor's clients, staff, and property; investigate and respond to complaints against Atanor and its clients; conduct employee opinion surveys; administer termination of employment; maintain data on emergency contacts and beneficiaries; and comply with applicable laws, including court or administrative orders regarding individual employees.

4.3. In the same sense, Atanor may require Personal Data from clients and suppliers to: execute a contract between Atanor and the client/supplier; contacts for negotiations and meetings with the client/supplier; provision of services and sending information about events, new products, and training; conducting business, including development, operation, and maintenance of systems commissioned by clients; responses to inquiries from clients/suppliers; and analysis based on questionnaires to improve products and services.

4.4. Direct Advertising: When collecting Personal Data for advertising or direct sales and other similar activities, Atanor will treat them accordingly as prescribed by art. 21 of the LPDP.

5. Sharing your Personal Data.

5.1. General. In order to implement the purposes described above, Personal Data will be disclosed only for the purposes set forth above.

5.2. Outsourcing of services. Like many companies, Atanor occasionally subcontracts third parties to process certain functions or information. Please note that when the Owner provides Personal Data, the aforementioned information may be processed by third parties contracted for this purpose. In these cases, Atanor requires such third parties to protect the Personal Data with appropriate security measures, and prohibits them from using the sames Personal Data for their own purposes or prevents them from disclosing the Personal Data to others, obliging such third parties to destroy the Personal Data after the completion of the provision to Atanor as prescribed by art. 25 of the LPDP.

5.3. International transfer of Personal Data. The nature of our activity and operations does not require international transfer of personal data. If the need to make international data transfers occasionally arises, we will take measures to ensure that there is a legal basis for such transfer and that adequate protection is provided to the Personal Data as required by the LPDP, for example, by using International Data Transfer contracts as prescribed by the LPDP or by requesting the prior, express and informed consent of the Owner of the Personal Data. Appropriate security measures will be maintained for the transferred information, so that the importers of such data comply with the LPDP and use the data for the sole purpose for which it was transferred.

5.4. Legal requirements. Atanor reserves the right to disclose any Personal Data it holds about a Data Subject if compelled to do so by a court or at the request of a government entity, or if Atanor believes it is necessary or appropriate to comply with the law or to protect or defend the rights or property of Atanor. Atanor also reserves the right to retain Personal Data and process such information to comply with applicable accounting and tax regulations.

6. Protecting Personal Data.

6.1. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personal Data, Atanor has put in place certain physical, electronic, administrative and security procedures to safeguard and secure the Personal Data collected. Atanor safeguards Personal Data in accordance with the principles of data security and confidentiality imposed by arts. 10 and 11 of the LPDP.

6.2. However, the Data Subjects acknowledge that the existing technical means that provide security are not impregnable, and that, even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information.

6.3. Atanor employees who misuse Personal Data and violate this Privacy Policy may be subject to disciplinary sanctions in accordance with the LPDP, labor laws and other applicable regulations.

7. Keeping Personal Data accurate.

7.1. If the Personal Data provided by the Data Subject changes, the Data Subject may request Atanor in writing to review, modify, delete and update his/her Personal Data, in accordance with the procedure provided for this purpose by the LPDP.

7.2. The right of access to the data may be exercised free of charge by the interested party as long as the corresponding information is requested at intervals of no less than 6 (six) months, unless a new legitimate interest is proven for this purpose, in accordance with art. 14 inc. 2 of the LPDP.

7.3. If the data is incorrect, or must be rectified, updated and/or deleted, Atanor will correct, update and/or delete this information at the request of the Owner at no cost, as provided for in art. 15 of the LPDP. To do so, the Owner must send an email to: infoweb@albaugh.com.ar. This, detailing his or her name and surname, identity document number, his or her request and, if applicable, reasons for exercising his or her right. Once the aforementioned details have been fulfilled and if it is appropriate to grant the request, Atanor will inform the Owner whether it has proceeded to grant the request or whether it rejects the request. Alternatively, the Data Subject may contact Atanor at its registered address at Juncal 1327 D esc. 1004, Montevideo, Uruguay. Atanor will have 5 business days from receipt of the request for access, rectification, update or deletion to send a response.

7.4. Likewise, if the Data Subject subscribes to any of the services or communications offered by Atanor, such as advertisements or newsletters, he/she may cancel his/her subscription at any time, following the instructions included in each communication. Atanor will make all reasonable efforts to ensure that the Data Subjects' requests are fulfilled. However, it may require additional information before being able to process each request.

7.5. It is hereby notified that the Personal Data Control and Regulatory Unit (URCDP), the control body of the LPDP, has the authority to address complaints and claims filed in relation to non-compliance with the rules on personal data protection.

8. Implementation of the Privacy Policy. Training of Atanor staff.

8.1. Atanor will make its best efforts to disseminate this Privacy Policy - as well as other rules and/or procedures it may establish to protect Personal Data - among its employees. In addition, Atanor will take measures to make the Privacy Policy easily accessible to the general public.

8.2. Atanor will ensure that its executive staff recognise the importance of protecting Personal Data, training them and establishing rules for handling such information so that it is used and protected appropriately and ensuring that such handling system is implemented.

8.3. In the event of incidents in the security and/or maintenance of the databases it maintains, Atanor will seek to identify the causes in order to adopt corrective measures, in accordance with the provisions of the Albaugh Group's “Data Security Policy”.

9. Children.

Our website, products and services are directed to persons over 18 years of age. Given the importance of protecting the privacy of children, we do not knowingly collect, process or use on our website any information relating to a person we know to be under 18 years of age without the prior and verifiable consent of his or her legal representative. Said legal representative has the right, upon request, to see the information provided by the minor and/or to demand that it be deleted.

10. Confidentiality.

Atanor will not sell, rent or share Personal Data except in the ways established in these policies and as provided for by art. 11 of the LPDP. We will do everything in our power to protect the privacy of the information. It may happen that by virtue of court orders or legal regulations, we are compelled to disclose information to government authorities, in which case Atanor cannot be held responsible for such disclosure of information.

11. Data retention.

We will only retain personal data for as long as necessary to provide a service that the data subjects have requested or for which they have given us their consent, unless otherwise provided by court order, law or regulation.

12. Use of cookies.

The Site may use a tracking system using "cookies" to make access to information, when moving from page to page, faster. It also helps in some cases to identify Users, without having to ask them for the access code again and again.
These cookies are small files sent by the page visited and are stored on the computer's hard drive, taking up little space.
Users are informed that by using the options of their browser they can limit or restrict the storage of these "cookies" according to their will, although it is not advisable to restrict them completely.
The system may collect information about your preferences and interests. In the event that this occurs, the information will be used exclusively for statistical purposes to improve the services provided on the Site. Atanor will apply, to the greatest extent possible, procedures for dissociating information so that the data owners are unidentifiable and will comply with the LPDP.
For more information on the use of your Personal Data, we suggest you read the Cookies Policy posted on this Site.

13. Change of control.

If we are the subject of a merger or acquisition with/by another company, we may share information with them in accordance with our privacy rules. In such case, we will require that the new combined entity follow this privacy policy with respect to your Personal Data. If we intend to process your Personal Data for purposes not contemplated in this privacy notice, you will receive prior notification of the processing of your Personal Data for the new purposes.

14. Contact with Atanor.

In case of questions about this Privacy Policy, Data Owners should contact the email address infoweb@albaugh.com.ar.

15. Changes to the Privacy Policy.

Atanor reserves the right to modify this Privacy Policy periodically.

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