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This site is owned and controlled by PBA Holding Group, Inc. (“PBA Holding Group” or “we,” “our,” or “us”). This Web Privacy Policy describes the types of personal information we collect on www.pba-panama.com (“the Website”), how we may use the information and the purposes for which we may use it, with whom we may share it, and the measures we take to safeguard your information.

Unless indicated otherwise, this Web Privacy Policy applies only to information collected through the Website. Please read this entire Web Privacy Policy before using the Website. If you are a Panamá consumer, for more information about your privacy rights, please see the section of this Web Privacy Policy called “Panamá Consumer Privacy Statement.”

Information We Obtain

We may obtain personal information through the Website, including contact information (such as your name, email address, and phone number) and other information you submit to us.

In addition, as you navigate through the Website, we may obtain certain information using various automated technologies, such as cookies. A “cookie” is a small piece of data (a text file) that a website—when visited by a user—asks your browser to store on your device in order to remember information about you.

The Website may use cookies or similar automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your device, web browser characteristics, device characteristics, language preferences, referring/exit pages, dates and times of visits to the Website, and clickstream data. The Website is not designed to respond to “do not track” signals received from browsers. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that certain features of the Website may not work without use of automated information collection technologies.

Use and Disclosure of Information

We may use the information we obtain about you to:

• Provide the Website and other services to you.
• Communicate with you.
• Operate, evaluate, develop, manage, and improve the Website and our business (including operating, administering, analyzing, and improving our services; developing new services; managing and evaluating the effectiveness of our communications; managing our professional relationships with vendors and other business partners; and performing accounting and other internal functions).
• Perform analytics (including market research and trend analysis).
• Increase and maintain the safety and security of our services and prevent misuse.
• Protect against, identify, and prevent fraud and other criminal activity, claims, and other liabilities.
• Comply with and enforce applicable legal requirements, relevant industry standards, and policies, including this Web Privacy Policy and our Terms & Conditions.

We also may use the information we obtain about you for other purposes disclosed at the time your information is collected.

Information We Share

We may share the information we obtain about you with third-party vendors to perform certain services on our behalf, such as to assist us with Website hosting and operations, data analytics, and other services designed to assist us with our business. We also may share your information with our affiliates and subsidiaries for the purposes described in this Web Privacy Policy.

In addition, we may disclose information about you: (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise, or defend our legal rights; (iv) to protect, defend, or enforce our policies, terms, or agreements; (v) when we believe disclosure is necessary or appropriate to address security or to prevent physical or other harm or financial loss; (vi) in connection with an investigation of suspected or actual illegal activity; or (vii) otherwise with your consent.

In addition, we also reserve the right to transfer information we have about you in the event we sell or transfer all or a portion of our business or assets (such as in the event of a merger, acquisition, joint venture, consolidation, restructuring, divestiture, dissolution liquidation, or other corporate change), including during the course of any due diligence process.

Third-Party Analytics

We may use third-party analytics services on the Website, such as Google Analytics. The analytics providers that administer these services use automated technologies such as cookies to help us analyze your use of the Website. The information collected through these means (including IP address) may be disclosed to these analytics providers who use the information, for example, to evaluate use of the Website. To learn more about Google Analytics and how to opt-out, please visit https://tools.google.com/dlpage/gaoptout.

Security

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Children’s Privacy

We recognize the importance of protecting children’s online privacy. The Website is intended for a general audience and is not directed to children. We do not knowingly collect personal information online from children under the age of 13.

Other Online Services

For your convenience and information, the Website may contain content, links, or references to other third-party websites, apps, or services. Please be aware that this Web Privacy Policy does not apply to those websites. These companies may have their own privacy policies, which we encourage you to review. In addition, when you are on the Website you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any non-PBA Holding Group websites, apps, or services.

Changes to this Web Privacy Policy

This Web Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a notice on our Website to notify you of significant changes to our Web Privacy Policy and indicate at the top of the notice when it was most recently updated.

How to Contact Us

If you have any questions, comments, or concerns about this Web Privacy Policy, please contact us at pba@pba-panama.com.

Panamá Consumer Privacy Statement

Last Updated: 01/11/24

This Panamá Consumer Privacy Statement (“Statement”) supplements our PRIVACY POLICY. This Statement applies solely to Panamá consumers, including personnel working on behalf of our business partners (e.g., vendors) (collectively, “B2B individuals”). This Statement does not apply to PBA Holding Group personnel. For clarity, this Statement applies to personal information we collect about Panamá consumers both on the Website and offline. This Statement uses certain terms that have the meaning given to them in the Panamá Consumer Privacy Act of 2018, as amended by the Panamá Privacy Rights Act of 2020, and its implementing regulations.

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, Social Security number, driver’s license number, passport number, email address, or other similar identifier.
• Additional Data Subject to local law: signature, address, state identification card number, bank account number.
• Protected Classifications: characteristics of protected classifications under Panamá or federal law, such as race, color, national origin, age, sex, gender, disability, citizenship status, and military and veteran status.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, information regarding your interaction with our websites or advertisements.
• Sensory Information: audio, electronic, visual, and similar information.
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information.
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the Last Updated date of this Statement) your personal information for the purposes described in our PRIVACY POLICY and for the following business purposes:

• Providing advertising and marketing services to you, except for cross-context behavioral advertising.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us.
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
• Managing career opportunities with us.
• Managing our relationships with current or prospective partners, corporate customers and vendors, and other business partner personnel.

We do not collect or process sensitive personal information with the purpose of

inferring characteristics about Panamá consumers covered by this Statement.

To the extent we process de-identified information, we will maintain and use the information in de-identified form and will not attempt to re-identify the information unless permitted by applicable law.

2. Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

3. Sources of Personal Information

During the 12-month period prior to the Last Updated date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you or your devices, for example, through your use of the Website.
• Our affiliates or subsidiaries.
• Your employer, if you are a representative of a vendor or other business partner.
• Other individuals, such as in connection with a business referral.
• Vendors who provide services on our behalf.
• Data analytics providers.
• Government entities.
• Recruiting and talent agencies.
• Job references, such as your employers.
• Internet service providers.
• Operating systems and platforms.

1. Sale or Sharing of Personal Information

We do not sell your personal information. We do not share your personal information with third parties for cross-context behavioral advertising purposes.

5. Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this Statement, we may have disclosed personal information about you to government entities, such as in response to a request from law enforcement authorities or in connection with actual or proposed corporate transactions, such as mergers, acquisitions, or divestitures.

6. Panamá Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom we disclose personal information; and the specific pieces of personal information collected about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access, correction, or deletion request, email us at pba@pba-panama.com. To submit a request as an authorized agent on behalf of a consumer, please email us and provide a copy of the signed permission from the Panamá consumer authorizing you to act on their behalf. For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Web Privacy Policy.

Verification: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.

Additional Information: If you choose to exercise any of your rights under local law, you have the right to not receive discriminatory treatment by us.

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