As a fintech company regulated under the Bank Superintendency of Panama, we are dedicated to the protection of your personal information, handling it responsibly and in accordance with Law 81 of 2019 on Data Protection in Panama and the Bank Agreements issued by the Bank Superintendency of Panama related to data protection and use of channels in internet. This privacy policy explains how we collect, use, and safeguard your information when you interact with our chatbot services.

1. Information We Collect

To facilitate efficient and secure financial services through our chatbot, we collect information that includes, but is not limited to:

• Personal Identification Data: Name or registered name in case of company, email address, and other contact details registered in the process of wallet/card creation;
• Transaction Data: Specifics of transactions initiated or queried through the chatbot.
• Card Details: Card number (partially masked), expiry date, and status information necessary for blocking or unblocking services.
• Authentication Data: OTPs sent to your registered email for validating transactions and safeguarding against unauthorized access.

1. How We Use Your Information

We use the collected information for the following purposes:

• To provide you with detailed and accurate transaction history and card management services.
• To comply with legal and regulatory requirements imposed by the Bank Superintendency.
• To enhance the security of our services, including the authentication of user commands via OTP.

1. Legal Basis for Processing

According to Article 9 of Law 81 of 2019, the processing of your personal data is based on the necessity to fulfill our contractual obligations to you, our compliance with legal obligations, and our legitimate interests in maintaining the security and integrity of our financial services.

1. Data Protection and Security

In compliance with Articles 14 and 16 of Law 81 of 2019, we employ advanced security measures to prevent data breaches and unauthorized access to your personal information. These measures include encryption, secure software development practices, and regular security assessments. PayCaddy regulated and create process regarding data protection that are included in the Annex of the Contract that regulates the process of card issuing, processing and maintenance of the card, for any more information, please review the Contract.

1. Sharing of Information

As stipulated under Article 17 of Law 81 of 2019, we limit the sharing of your personal data to entities that are authorized under legal agreements, which include:

• Regulatory bodies and law enforcement agencies, as required by the Bank Superintendency regulations and other legal mandates.
• Trusted third-party service providers who assist us in managing the chatbot functionality, subject to stringent data protection clauses.

1. Your Rights

Under Law 81 of 2019 on Data Protection in Panama, you possess specific rights regarding the processing of your personal data. These rights include:

• Right to Access: You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and information regarding its processing.
• Right to Rectification: You have the right to obtain the rectification of inaccurate personal data concerning you. You can also have incomplete personal data completed, considering the purposes of the processing.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of personal data concerning you when it is no longer necessary for the purposes for which it was collected or otherwise processed, among other conditions.
• Right to Restriction of Processing: You have the right to restrict the processing of your personal data under certain circumstances, such as if you contest the accuracy of the data, or if the processing is unlawful.
• Right to Data Portability: Where the processing is based on consent or a contract, and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance.

To exercise any of these rights, you should utilize the communication channels provided in our contract with you. Our team is prepared to assist you in managing your data rights effectively.

1. Updates to This Policy

This privacy policy may be updated periodically to reflect changes in our personal data practices or relevant laws. Any significant changes to the policy will be communicated through our website and via the communication channels stipulated in the contractual agreement. Additionally, the policy may be modified to include new elements as outlined in the Annex of the original contract between PayCaddy and its clients.

1. Contact Us

For any inquiries or concerns about your personal data, please contact our Data Protection Officer using the contact details provided in our contract. This ensures that all communications are handled through the proper channels as outlined in the regulatory framework between you and PayCaddy.

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