PRIVACY AND PERSONAL DATA POLICY

Governing Principles

• The owner of a personal data bank or, where applicable, the party responsible for processing must comply with the governing principles applicable to the protection of personal data, in accordance with the Law.

Consent Principle

• The processing of personal data is lawful where the data subject has given free, prior, express, informed and unequivocal consent. Forms of consent that do not constitute a direct expression of the data subject's wishes, including those requiring consent to be presumed or inferred, will not be accepted. Even where consent is given together with other statements, it must be expressed clearly and explicitly.

Purpose Limitation Principle

• Under the purpose limitation principle, a processing purpose is considered sufficiently defined when it has been stated clearly and without ambiguity, and the intended purpose of the processing of personal data has been objectively specified.
• Where a personal data bank contains sensitive data, its creation may only be justified where its purpose is legitimate, specific and consistent with the activities or stated purposes of the owner of the personal data bank.
• Professionals who process personal data are subject not only to the purpose for which their services are provided, but also to applicable duties of professional confidentiality.

Data Quality Principle

• Personal data subject to processing must be truthful, accurate and, where possible, kept up to date, as well as necessary, relevant and appropriate for the purpose for which it was collected.

Security Principle

• In accordance with the security principle, appropriate security measures must be implemented in connection with the processing of personal data to prevent processing that is contrary to the Law, including alteration, loss, unauthorized disclosure, diversion or misuse of information, whether intentional or accidental and whether arising from human action or the technical environment used.

Processing by Service Providers

• MINE PRECISION may entrust part of the processing of personal data for which it is responsible, or which forms part of personal data banks under its ownership, to service providers that have been duly assessed and authorized by MINE PRECISION.

Data Subject's Right to Information

• The data subject has the right to receive, before their personal data is collected, detailed, clear, straightforward and unequivocal information regarding the purpose for which their personal data will be processed.

Data Subject's Right of Access

• The data subject has the right to obtain information relating to their personal data that is being processed in public or private personal data banks, including information regarding the manner in which such data was collected.

Right to Update, Inclusion, Rectification and Erasure

• The data subject has the right to request the updating, inclusion, rectification and erasure of personal data being processed where such data is wholly or partially inaccurate or incomplete, where an omission, error or false statement has been identified, where the data is no longer necessary or relevant to the purpose for which it was collected, or where the applicable processing period has expired.

Right to Prevent Disclosure

• The data subject has the right to prevent personal data from being disclosed, particularly where such disclosure could affect their fundamental rights. This right does not apply to disclosures between the owner of a personal data bank and the data processor where such disclosure is required for the processing of the data.

Right to Object

• Unless otherwise provided by law, and where consent has not been given, the data subject may object to the processing of their personal data where there are well-founded and legitimate grounds relating to their particular circumstances. Where the objection is justified, the owner or processor of the personal data bank, as applicable, must take the corresponding action in accordance with the Law.

Right to Seek Legal Protection

• Where the owner or processor of a personal data bank wholly or partially denies the exercise of the rights established by law, the data subject may submit a claim before the National Authority for Personal Data Protection or seek relief before the Judiciary through the corresponding habeas data action.

Right to Compensation

• A data subject who suffers harm as a result of non-compliance with the Law by the owner or processor of a personal data bank, or by third parties, is entitled to seek the corresponding compensation in accordance with the Law.

Fees

• Any fee payable by the data subject for exercising the rights provided for in Articles 19, 20, 21, 22 and 23 before publicly administered personal data banks is subject to the provisions of Law No. 27444.

Limitations

• Owners and processors of publicly administered personal data banks may deny the exercise of the rights of access, erasure and objection where justified by the protection of the rights and interests of third parties, or where exercising those rights could obstruct ongoing judicial or administrative proceedings relating to investigations into compliance with tax or social security obligations, criminal investigations, or the exercise of oversight functions concerning offenses or crimes.

Consent

• MINE PRECISION requires the free, prior, express, unequivocal and informed consent of the data subject for the processing of personal data, except where an exemption is expressly provided by law.
• MINE PRECISION does not require consent to process personal data obtained from publicly accessible sources, whether free of charge or otherwise. It may also process personal data obtained from non-public sources provided that those sources have the data subject's consent to process and transfer such personal data.

Personal Data Retention Period

• Personal data processed by MINE PRECISION will be retained for as long as necessary to fulfill the purposes set out in this Policy.

Personal Data Security

• In compliance with applicable regulations, MINE PRECISION implements appropriate legal, organizational and technical measures to safeguard personal data against alteration, loss, improper processing or unauthorized access.
• For this purpose, MINE PRECISION makes available the human and technological resources reasonably required, applying them in proportion to the nature of the data stored and the risks to which such data may be exposed.
• MINE PRECISION will only process personal data stored in repositories that meet the security requirements established under the Personal Data Protection Law.

Communication and Continuous Improvement Commitment

• This Policy will be communicated to MINE PRECISION personnel involved in the management of personal data banks.
• MINE PRECISION is committed to the continuous improvement of its management of personal data banks.