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This privacy policy (hereinafter, "Privacy Policy"has been drafted by Grupo Unicomer Corp., hereinafter, "UNICOMER" or the "Data Controller") in order to comply with the duty of transparency in the processing of personal data that it may carry out as the data controller, in accordance with the provisions of Law 81 of 2019 on the Protection of Personal Data of the Republic of Panama, published on the twenty-ninth day of March two thousand nineteen, which was sanctioned by the President of the Republic of Panama, Juan Carlos Varela R., and in turn by Executive Decree number 285 of May 18, 2021, which regulates Law 81 of 2019, sanctioned by the President of the Republic of Panama, Laurentino Cortizo Cohen. Both regulatory bodies are currently in force, relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter, "Law 81 of 2019 on the Protection of Personal Data" and "Executive Decree 285 that regulates Law 81 of 2019 on the Protection of Personal Data).
The information contained in this Privacy Policy allows you to consult the details of the different treatments of your personal data that may be carried out by UNICOMER by virtue of the relationship with the holders of personal data. This policy will apply to the processing of personal data contained in any type of support used by the data controller, automated or not, as well as to any subsequent use modality. The scope of application of this policy excludes the literals a), b), d), e), f), g) of art. 3 of Law 81 of 2019.
The purpose and objective of this policy is to guarantee the exercise of the right to the protection of personal data that are in databases within the territory of the Republic of Panama, which includes, among others, access and decision on information and data of this nature, as well as their corresponding protection. This policy regulates, provides for, and develops principles, rights, obligations, and protection mechanisms. The scope of application of this policy will be dictated by art. 2 of Executive Decree 285 that regulates Law 81 of 2019 on the Protection of Personal Data.
The exercise of the rights provided for in this policy will be channeled through the data controller (UNICOMER), likewise, this policy will comply with the criteria issued by the governing and supervisory entity that has been designated by virtue of Law 81 of 2019 on the Protection of Personal Data and Executive Decree 285 that regulates Law 81 of 2019 on the Protection of Personal Data.
Consent for the processing of personal data will exist when there is a manifestation of the will of the holder to do so, it will be considered valid when the manifestation of will is free, specific (concrete determination of the means and purposes of the processing), informed, and unequivocal. Legitimate interest in the processing of personal data by the controller, processor, or a third party cannot be alleged unless the processing is based on the cases listed in art. 17 of Executive Decree 285 that regulates Law 81 of 2019 on the Protection of Personal Data.
We inform you that mere access to the website, or any other platform (digital or in-person) used by UNICOMER does not imply the obligation to provide any personal information.
However, the use of some services or functionalities of the website does require you to provide certain personal data and implies its processing for the purposes and legal bases indicated in this Privacy Policy. The legitimacy and legality of the processing of personal data will be fulfilled if it meets any of the following conditions:
By consent of the holder for one or more specific purposes;
When the processing takes place within the framework of the contractual relationship in which the data holder is a party or is celebrated in their interest;
When the processing is necessary for the fulfillment of a legal obligation by the data controller, having to deliver to the law that collects the obligation as provided in numeral 3 of article 17 of Law 81 on the protection of personal data;
That the processing of personal data is authorized in a special law or the regulations that develop them;
When the processing is necessary to protect the vital interests of the data holder or another natural person;
When required by a public entity in the exercise of its legal functions, for the safeguarding of a public interest or by court order;
When the processing is necessary to satisfy the legitimate interest pursued by the data controller or by a third party, provided that the interests or fundamental rights and freedoms of the data holder prevail, especially when it is a minor;
When it comes to sensitive data, the conditions provided in article 13 of Law 81 of 2019 will be attended to proceed with its transfer to third parties.
The refusal to provide the required data in these cases may mean the impossibility of providing you with some services or functionalities, or of processing the requests or contracts made, especially in those cases where they are identified as mandatory completion.
As the holder of personal data, you will be responsible for ensuring that the data you provide to us through the website or any other platform (digital or in-person) used or made available to you by UNICOMER are accurate, complete, precise, verifiable, clear; and, if applicable, duly updated; in such a way that their veracity is not altered.For these purposes, you will be responsible for the veracity of all the data you communicate and must keep the information provided duly updated, so that it responds to your real situation.
Likewise, you will be responsible for the false or inaccurate information you provide and for the damages, direct or indirect, that this causes to the data controller or third parties.
In no case may personal data corresponding to third parties be included in the form, unless you have previously obtained their consent, personally responding to the breach of this obligation. You may be required to provide supporting documentation of this authorization at any time, which may be collected verbally if in any of the processes carried out by UNICOMER third parties are contacted to give reference to another. Likewise, if necessary, when the information related to know your client is outdated, it may be updated through the information provided by third parties who have served as a reference for the credit holder, or by a person who makes a payment on behalf of another, in this last case, if the consent of this is not available, it may be obtained physically at the cashier, or, at the place of delivery of the products acquired by the account holder.
Below we inform you of the details of the personal data processing that can be carried out once the data holder approves the processing:
In any case, you can request more information about the treatments carried out by writing to the data protection officer of UNICOMER at the email dpo@unicomer.com, responsible for ensuring the fair and transparent processing of your personal data.
USER SERVICE
In the event that you provide your personal data through the form, telephone, or contact email made available to you on the website or any other platform (digital or in-person) used by UNICOMER, your data will be processed for the purpose of managing your information requests, resolving your doubts, answering your queries, or processing your claims.
The legitimacy of the processing is the consent, expressly given by completing the contact form, calling us, or writing to us. In this way, the processing is necessary to allow the proper processing of your information requests, resolution of your doubts, answering your queries, or processing your claims communicated and verifying the operation of the service according to the established procedures, as well as to obtain evidence of the content of the requests received and the reason for the processing of the personal data you may provide.
You have the right to rectify or cancel your personal data by withdrawing your consent at any time by sending an email to dpo@unicomer.com .
Finally, we inform you that the withdrawal of consent will not affect the legality of the processing based on the consent prior to its withdrawal.
CV MANAGEMENT
In case you provide your resume through the form or contact email made available to you on the website or any other platform (digital or in-person) used by UNICOMER to participate in selection processes, your data will be processed for the purpose of evaluating and managing the job application and, if applicable, carrying out the necessary actions for selection and hiring when UNICOMER has a vacancy that fits your profile. Likewise, the data will be processed for the realization of those communications related to said selection processes and, if applicable, for your incorporation into the pool of candidates in order to consider the application in future processes.
The legitimacy of the processing is the consent, expressly given when you send your job application, either through the employment section enabled on the website or any other platform (digital or in-person) used by UNICOMER, including through email.
You have the right to rectify or cancel your personal data by withdrawing your consent at any time by sending an email to dpo@unicomer.com . Finally, we inform you that the withdrawal of consent will not affect the legality of the processing based on the consent prior to its withdrawal.
COMMERCIAL PROMOTION
In case you give consent for the processing of your data for commercial purposes through the form or contact email made available to you on the website or any other platform (digital or in-person) used by UNICOMER, the personal data collected will be processed for the purpose of sending you, by any communication channel: postal, telephone, or electronic (including WhatsApp, email, SMS, etc.), offers and commercial information related to the products and services offered on the website, digital platforms, or physically in own stores or authorized distributors, which may include the preparation and sending of a budget according to the information provided for its calculation, follow-up of the same and any communication related to the sent budget. The legitimacy of the described treatments is the consent, which you have the right to withdraw at any time or, to request the modification of your personal data by sending an email to dpo@unicomer.com .
Likewise, we inform you that the withdrawal of consent will not affect the legality of the processing based on the consent prior to its withdrawal.
Additionally, if you are already a customer, UNICOMER may send you commercial communications about products or services similar to those previously contracted, basing the legitimacy of the processing on the legitimate interest of UNICOMER, in promoting its image through commercial communications, always in accordance with the provisions of the Organic Law on the Protection of Personal Data, its regulations, and this personal data protection policy. In any case, we remind you that you can oppose at any time to the treatments covered by the legitimate interest, in accordance with the provisions of the "Rights of the data holder" section of this Privacy Policy.
CUSTOMER MANAGEMENT
When you sign a contract with UNICOMER, your personal data will be processed for the purpose of formalizing, managing, maintaining, developing, supervising, and controlling the provision of services and the operation of the contracted products, including, where appropriate, technical assistance and/or maintenance services. Likewise, UNICOMER may process your personal data for the purpose of analyzing your credit behavior if you request a credit with UNICOMER, likewise, your personal data may be processed if you give your consent by accessing the different social networks used by UNICOMER.
Additionally, to satisfy the legitimate interests of UNICOMER, your data may be processed to evaluate your satisfaction, so you may be asked for your opinion on their products and services. This processing also contributes to the improvement of the quality of the products and services offered by the data controller. Although opinions will be collected individually, their analysis will be carried out generally, through statistics, without identifying specific users. In any case, you can refuse to give your opinion, as well as communicate your opposition to being contacted for this purpose, in accordance with the provisions of the "Rights of the data holder" section of this Privacy Policy.
However, the use of some services or functionalities of the website does require you to provide certain personal data and implies its processing for the purposes and legal bases indicated in this Privacy Policy.
In each form, you will be informed which fields are mandatory. The refusal to provide these data implies the impossibility of processing the requests made.
As a general rule, the categories of data subject to processing for suppliers, customers (users), job applicants, and employees will be the following:
COMMERCIAL PROMOTION
The data processed for sending commercial communications are:
CUSTOMER MANAGEMENT
By virtue of the contractual relationship, UNICOMER may process the following types of personal data:
The following are considered special categories of personal data: Sensitive data, Data of children, adolescents, Data of health; and, Data of people with disabilities and their substitutes, related to disability.
UNICOMER will not process sensitive personal data unless any of the circumstances established in art. 18 of Law 81 on the Protection of Personal Data occur, such as:
In the case of processing data of minors and persons with disabilities, it will be the parents, guardians, or those exercising guardianship and custody of these who will exercise on their behalf and representation the rights of access, rectification, cancellation, opposition, portability, or any other that corresponds to them under Law 81 of 2019 and the decree on the protection of personal data.
In compliance with the provisions of article 28 of Law 81 of 2019 on the Protection of Personal Data, the personal data subject to processing will be retained for the time provided and communicated to users to fulfill the informed purposes, obliging the data controller not to transfer or communicate identifiable personal data of a person after SEVEN YEARS have elapsed since the legal obligation to retain the information was extinguished.
In case of deletion, the data controller will communicate any cancellation to each of the recipients to whom the personal data have been communicated, unless it is impossible or requires a disproportionate effort.
USER SERVICE
The personal data provided through the contact form will be retained for the time necessary for the proper management of your information request, resolution of your doubts, answering your queries, or processing your claim, or until you withdraw your consent.
CV MANAGEMENT
The personal data you provide as a result of sending your resume for a vacancy will be processed until you revoke your consent, for a maximum period of 1 year from the date you applied for the vacancy.
COMMERCIAL PROMOTION
The personal data provided for sending commercial communications will be kept until you withdraw your consent or object to receiving such commercial communications, provided that the data controller has not decided to delete them earlier for any other reason.
CUSTOMER MANAGEMENT
Personal data related to customers will be kept for the duration of the contractual relationship and, at most, for the statute of limitations for the corresponding legal actions, unless you authorize their processing for a longer period.
In the case of processing based on legitimate interest, they will be kept for the time necessary to fulfill the informed purpose or until you object to their processing (unless the interests of the data controller prevail).
As a general rule, the personal data processed will not be communicated to third parties, except in the case of third parties involved in the provision of services and to the extent that such communication is necessary to fulfill the aforementioned purposes or, where appropriate, to the relevant Organizations and Authorities, when legally required.
Likewise, the personal data processed may be communicated or shared with third parties for reasons of compliance with information security policies (SI), for the following purposes:
When it is essential to hire a third party, UNICOMER will ensure that they comply with the applicable regulations and will sign the corresponding database custodian contract, complying with the provisions of Article 47 of Executive Decree 285, which regulates Law 81 of 2019 regarding the Transfer or Communication and Access to Personal Data by Third Parties. Data may be shared with third parties that provide a derivative or after-sales service of products purchased in stores, platforms, or authorized distributors of UNICOMER.
In the event that the involvement of any of the data controller's suppliers involved in the provision of services may involve an international data transfer, it will be adequately regularized and informed in this Privacy Policy, adopting the appropriate guarantees for its realization, and in accordance with the provisions of the fourth section of Executive Decree 285, which regulates Law 81 of 2019 on the Protection of Personal Data.
Personal data may be transferred or communicated to countries, organizations, and legal entities in general that provide adequate levels of protection and comply with the obligation to comply with and guarantee internationally recognized standards in accordance with the criteria or resolutions issued by the competent authority and established in Law 81 of 2019 and Executive Decree 285, which regulates said law on data protection.
For notifications to data subjects, when the breach may constitute a risk to their fundamental rights, the Data Controller must notify the data subject of the breach within a maximum of seventy-two hours from becoming aware of the risk, in compliance with the provisions of Articles 37 and 38 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection.If the international data transfer is made to a country, organization, or economic territory that has not been qualified by the Data Protection Authority as having an adequate level of protection, the data controller or processor must offer protection guarantees in the processing included in Article 53 of Executive Decree 285, which regulates Law 81 of 2019 on the Protection of Personal Data.
The Data Controller must conduct an impact assessment on the processing at the request of the control authority when the conditions established in Article 41 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection are met. The Personal Data Protection Directorate may also establish other types of operations that require impact studies, but in any case, these must be carried out at the beginning of the personal data processing.
As the data subject, you have the right to contact the data controller at any time and free of charge, by writing to the addresses indicated in this Privacy Policy, to exercise the following rights:
All exceptions expressed in Article 31 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection apply regarding the rights of rectification, updating, deletion, objection, cancellation, and portability.
In any case, for any questions or additional issues about exercising your rights or, in general, about the processing of your personal data, you can contact our Data Protection Officer at dpo@unicomer.com.
Additionally, if you believe any of your rights in personal data protection have been violated, you can file a complaint with the personal data protection authority.
Your personal data will be treated with absolute confidentiality and maintaining the necessary duty of secrecy regarding it, in accordance with the provisions of Articles 34 and 36 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection, adopting the necessary technical and organizational measures from the conception and design of the project to ensure the security of the data and prevent their alteration, loss, processing, or unauthorized access, considering the state of technology, the nature of the stored data, and the risks to which they are exposed.
The Data Controller or Processor must implement a continuous and permanent process of verification, evaluation, and assessment of the efficiency, effectiveness, and effectiveness of the technical, organizational, and any other measures implemented to ensure and improve the security of personal data processing, to demonstrate compliance with the principles and obligations established in Law 81 of 2019 and its decree.
The Data Controller or Processor must demonstrate that the adopted and implemented measures adequately mitigate the identified risks.
The Data Controller must notify the Personal Data Protection Directorate and the affected data subjects of any personal data security breach immediately, and no later than seventy-two hours after becoming aware of the incident.
Para el caso de las notificaciones a los titulares de los datos, cuando la vulneración pueda constituir un riesgo a sus derechos fundamentales el responsable del tratamiento deberá de notificar al titular sobre la vulneración en un plazo máximo de setenta y dos horas contados a partir de que se haya tenido conocimiento del riesgo, cumpliendo con lo establecido en el art. 37 y 38 del decreto ejecutivo 285 que reglamenta la ley 81 del 2019 sobre la Protección de Datos Personales.
Personal data may be transferred or communicated to countries, organizations, and legal entities in general that provide adequate levels of protection and comply with the obligation to comply with and guarantee internationally recognized standards in accordance with the criteria or resolutions issued by the competent authority and established in Law 81 of 2019 and Executive Decree 285, which regulates said law on data protection.
For notifications to data subjects, when the breach may constitute a risk to their fundamental rights, the Data Controller must notify the data subject of the breach within a maximum of seventy-two hours from becoming aware of the risk, in compliance with the provisions of Articles 37 and 38 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection.If the international data transfer is made to a country, organization, or economic territory that has not been qualified by the Data Protection Authority as having an adequate level of protection, the data controller or processor must offer protection guarantees in the processing included in Article 53 of Executive Decree 285, which regulates Law 81 of 2019 on the Protection of Personal Data.
Personal Data Processing Impact Assessment
The Data Controller must conduct an impact assessment on the processing at the request of the control authority when the conditions established in Article 41 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection are met. The Personal Data Protection Directorate may also establish other types of operations that require impact studies, but in any case, these must be carried out at the beginning of the personal data processing.
The Data Controller must conduct an impact assessment on the processing at the request of the control authority when the conditions established in Article 41 of Executive Decree 285 regulating Law 81 of 2019 on Personal Data Protection are met. The Personal Data Protection Directorate may also establish other types of operations that require impact studies, but in any case, these must be carried out at the beginning of the personal data processing.
The Data Controller reserves the right to modify this Privacy Policy to adapt it to its needs or to any applicable legislative changes. In such cases, it will announce the changes made and publish them on this website, so you can access them at any time and easily.
