Privacy Notice.

1. Identity of the data controller

DIGITAL RESET, a Reset Corp vertical (the "Firm"), is the controller responsible for the personal data collected through its website digitalreset.io and its associated institutional contact channels. The Firm complies with Law 81 of March 26, 2019 on the Protection of Personal Data of the Republic of Panama and its implementing Executive Decree 285 of 2021.

For inquiries related to this Privacy Notice, the data subject may contact:

• Institutional email: legal@digitalreset.io
• Physical address: C.C. Plaza Paitilla, P.B. Office 25. Panama City, Republic of Panama.
• Institutional phone: +507 310 9137

2. Personal data we collect

2.1 Data from the contact form

• Full name of the data subject.
• Job title or professional position.
• Organization the data subject works for.
• Industry and size of the organization.
• Professional email address.
• Professional phone number, when voluntarily provided.
• Country of the organization's primary operation.
• Free-text message provided by the data subject.

2.2 Data from the Perspectivas newsletter subscription

• Professional email address.
• Job title and organization, when voluntarily provided.

2.3 Data generated while browsing the site

• IP address of the accessing device.
• Browser type, operating system, and regional settings.
• Pages visited, time spent, and navigation paths.
• Traffic source, when a referring source is identified.
• Identifiers stored in cookies, as described in the Cookie Policy.

2.4 Data arising from the professional relationship with clients

When the data subject becomes a client of the Firm, additional data necessary for delivering the contracted service is collected, governed by the professional contract signed between the parties.

3. Purposes of processing

The personal data collected is processed exclusively for the following purposes:

• Handling commercial contact requests and responding to inquiries submitted through the site.
• Assessing whether the data subject's case fits the type of engagements the Firm handles, and communicating that assessment to them.
• Sending Perspectivas newsletter communications to subscribers who have expressly requested to receive it.
• Operating and improving the website through aggregate usage analysis.
• Complying with legal obligations applicable to the Firm.
• Managing the contractual relationship with active clients, when applicable.

The Firm does not use personal data for purposes other than those declared here. The Firm does not carry out advertising profiling, does not sell the data subject's data, and does not share it with third parties for marketing purposes.

4. Legal bases for processing

In accordance with Article 5 of Law 81 of 2019, the legal bases are:

• The data subject's express consent, given by completing the contact form, subscribing to the newsletter, or accepting non-essential cookies.
• Performance of a contractual or pre-contractual relationship, when the data is necessary to formalize or execute a professional service engagement.
• Compliance with legal obligations, when processing is required by applicable law.
• The Firm's legitimate interest in operating the site, maintaining the operational continuity of its professional activity, and protecting its technical security.

5. Data retention

The Firm retains personal data for the time strictly necessary to fulfill the purpose for which it was collected, except when the law requires a longer period:

• Contact form data where the request does not result in a contractual relationship: up to twenty-four (24) months, unless deletion is requested.
• Perspectivas newsletter data: until the subscriber exercises their right of withdrawal or unsubscribes.
• Data arising from site browsing: for the periods defined in the Cookie Policy.
• Contractual and financial data: for the legal period applicable to the Firm's commercial and tax records.

6. Data processors and international transfers

The Firm uses technology providers that act as data processors under contractual agreements that guarantee adequate levels of protection. The main processors are:

• The website's hosting and CDN provider.
• Zoho Corporation, for managing the contact form, the Perspectivas newsletter, CRM, and internal operational tools.
• The institutional email infrastructure provider.

Some providers may process data in jurisdictions other than the Republic of Panama, including the United States, the European Union, and India. The Firm requires guarantees equivalent to those established under Panamanian law.

7. Data subject rights

Under Law 81 of 2019, the data subject has the following rights:

• Access: request information about the personal data the Firm processes about them.
• Rectification: request correction of inaccurate, incomplete, or outdated data.
• Cancellation or erasure: request deletion of data when it is no longer necessary for the purpose for which it was collected.
• Objection: object to the processing of their data on legitimate grounds, including the sending of newsletter communications.
• Portability: receive their data in a structured, readable format, when processing is based on consent or contract.
• Not to be subject to automated decisions that produce significant legal effects without human intervention.

8. Procedure for exercising these rights

The data subject may exercise any of the above rights by submitting a written request to legal@digitalreset.io, identifying themselves with their full name, clearly indicating which right they are exercising, and providing, when relevant, a copy of an identification document.

The Firm will respond within fifteen (15) business days of receiving the complete request. If the data subject believes their request was not adequately addressed, they may file a complaint with the National Authority for Transparency and Access to Information (ANTAI) of the Republic of Panama.

9. Cookies

The site digitalreset.io uses cookies and similar technologies to function correctly and to analyze site usage. Full details on the types of cookies used, their purpose, and their duration are available in the Firm's Cookie Policy, accessible from the footer of every page on the site.

10. Data security

The Firm applies technical and organizational measures that are reasonable and proportionate to the risk, aimed at protecting personal data against unauthorized access, alteration, loss, or improper disclosure. These measures include: system access controls, encryption of communications, periodic backups, activity monitoring, and team training.

In the event of a security incident that poses a significant risk to the data subject's rights, the Firm will notify the supervisory authority and the affected data subjects in accordance with applicable law.

11. Changes to this Notice

The Firm may update this Privacy Notice when necessary for legal, technical, or operational reasons. When changes are substantial, the data subject will be notified through a notice on the website or through direct communication when possible.

12. Effective date and contact

This Privacy Notice takes effect on the date indicated on the document's cover and remains in effect until replaced by a duly published later version.

For any communication related to the processing of personal data: legal@digitalreset.io.