Privacy Policies These privacy policies (hereinafter, the “Privacy Policies”) complement the “Terms and Conditions” (together, the “Terms and Conditions”), corresponding to the Application or Platform managed by ZENTRALY. Capitalized terms not defined herein are defined in the Terms and Conditions. These Privacy Policies will be effective upon acceptance by the Data Subject (as defined below) and will be effective for the term arising from the Terms and Conditions and the provisions herein. Additionally, these Privacy Policies are subject to modifications and updates, so we urge you to stay up to date. As a normal part of our general activities, we collect and, in some cases, disclose information about our Users, Partner Merchants and other merchants (hereinafter, “Data Subject”). These Privacy Policies describe the information that ZENTRALY collects about Data Subjects and what can be done with that information. This policy is very detailed because it is important that all Data Subjects who access our Application are aware of ZENTRALY's practices as accurately as possible. By registering on the Application and linking with ZENTRALY, the Data Subject consents to the use of his or her personal information (hereinafter, the “Personal Information”) in accordance with the policies described below. The privacy of the information of Data Subjects is very important to ZENTRALY. For this reason, precautions and measures are taken to safeguard your information, using the most complete and effective information protection computer security mechanisms. FIRST: Rights of access, cancellation and rectification of Personal Information 1.1. Data Subjects may exercise their rights to access, cancel and update their Personal Information, including their email address, as well as to oppose the processing of the same and to be informed of the assignments and/or international transfers of the Personal Information carried out, all in accordance with the provisions of the applicable regulations. Likewise, the Data Subject has the right to have the personal data of which they are the owner rectified, updated and, where appropriate, deleted or made confidential, within 5 (five) business days of their identity being proven and the measure in question being requested. Please note that the request for withdrawal or deletion will not proceed when there is a legal obligation to retain the data. Occasionally, it may take us longer if the request is particularly complex or if you have made several requests. In this case, we will send you a notice and keep you updated. 1.2. The Data Holders guarantee and are responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the Personal Information provided, and undertake to keep it duly updated. ZENTRALY does not guarantee the Data Holders the certainty of the data provided by the other Data Holders. This does not prevent ZENTRALY from rectifying, updating or deleting incorrect data and other obligations established in the current regulations and the provisions herein. 1.3. Once registered with ZENTRALY, the Data Holder may review and change the information that he/she has sent to ZENTRALY during the registration process, including: • The user name and email address. Without prejudice to the changes made, ZENTRALY will retain the previous Personal Information for security and fraud control reasons. • Registration information such as: address, city, region, postal code, main telephone number, secondary telephone number, email, etc. • the password. 1.4. ZENTRALY will retain the Personal Information of the Data Holders for a period of ten (10) years in order to resolve disputes or claims, detect problems or incidents and solve them, and comply with the provisions of the Terms and Conditions, as well as to comply with its legal obligations. SECOND: Personal Information 2.1. In order to use the Application, Data Subjects must register, providing certain complete and accurate personal data. ZENTRALY may request, collect and store the following personal information: name and surname, valid identification or document number, physical contact information (such as telephone number, address, e-mail address, etc.). ZENTRALY may confirm the Personal Information provided by contacting public entities, specialized companies or credit bureaus, for which the Data Subject hereby expressly authorizes it. The information that ZENTRALY obtains from these entities will be treated confidentially. 2.2. The Data Subject who registers in the Application expressly consents that ZENTRALY may access, at any time, all the information contained in his/her Account, including in particular, but without limitation, his/her Personal Information, information about his/her interests, tastes, contacts and any other content stored in his/her Account. It is expressly established that the data collected by ZENTRALY will never exceed the scope and purpose for which it was obtained, in accordance with current regulations. 2.3. In addition to the above, it is also reported that when the Data Holder uses the Application, data is stored on our servers to enable the connection and for security reasons. ZENTRALY uses technologies to analyze trends, manage the Application and, in general, to collect demographic information about the Data Holders. THIRD: Use of Personal Information 3.1. For efficient operation of the Application and so that the Data Holders can use it quickly and easily, ZENTRALY requires certain personal information, including email address. The collection of information allows us to offer the Data Holders functionalities that best suit their needs. The Personal Information collected has the following purposes: (i) To conduct internal studies on the interests, behaviors, and demographics of Data Subjects in order to better understand their needs and interests and offer better services or provide them with related information. (ii) To send information or messages by e-mail about advertising or promotions, notifications of interest to our Data Subjects, news about ZENTRALY. If the Data Subject prefers, he/she may request to be excluded from the lists for sending promotional or advertising information, using the option offered in the e-mail itself. Likewise, he/she may access his/her user profile and request exclusion from notifications through the Application. (iii) To send information or notices by short text messages (SMS) to the cell phone provided by the Data Subject to ZENTRALY. Short text messages may contain (but are not limited to): information about the functionalities of the Application, which may include personal keys for using the Application and reminders of payment due dates and other obligations acquired in this context. 3.2. ZENTRALY may share Personal Information (including email address) with service providers or outsourcing companies or with companies with whom ZENTRALY has a collaboration or alliance relationship, which contribute to improving or facilitating operations through ZENTRALY. ZENTRALY will ensure compliance with regulatory standards by signing agreements or conventions whose purpose is the privacy of the personal data of the Data Subjects. 3.3. The Data Subject acknowledges and accepts that ZENTRALY may disclose, transmit or share Personal Information with third parties that are service providers or companies allied, affiliated or related to ZENTRALY. That is, ZENTRALY may transmit data nationally or internationally to clients and/or suppliers with whom ZENTRALY carries out activities in compliance with its corporate purpose. Likewise, a transfer may be made to the company's strategic allies to carry out marketing, advertising and promotion activities associated with its corporate purpose. All of this in accordance with the provisions of Argentine legislation. FOURTH: Confidentiality of Personal Information 4.1. Once registered in the Application, ZENTRALY will not sell, rent or share the Personal Information except in the ways established in these Privacy Policies. Without prejudice to this, the Data Owner expressly consents to ZENTRALY transferring all or part of the Personal Information to any of the companies controlled by, controlling and/or affiliated with ZENTRALY, for any reason and at the time, in the manner and under the conditions it deems appropriate. Likewise, you authorize ZENTRALY from now on to transfer your Personal Information in the event of the sale or transfer of all or part of our company or our assets (including cases of restructuring, dissolution or liquidation). 4.2. ZENTRALY will do everything possible to protect the privacy of the Personal Information. Notwithstanding the foregoing, as set forth in clause 7 hereof, it may happen that, pursuant to judicial or administrative orders, or legal regulations, ZENTRALY is obliged to disclose Personal Information to the competent authorities or third parties under certain circumstances. FIFTH: Personal Key 5.1. In order to access the services reserved solely for duly registered Data Subjects, Data Subjects will have a personal key. Data Subjects must keep this key in absolute confidentiality and, under no circumstances, must they disclose it or share it with other persons. 5.2. The Data Subject shall be responsible for all acts that occur through the use of his/her Data Subject name and key, which includes taking charge of the payment of any fees that may be incurred or for any damages that other Data Subjects may suffer for this reason. If for any reason a Data Holder believes that someone may know his/her password, he/she must change it by accessing the change option provided for this purpose in the Application. SIXTH: Minors 6.1. The Application is aimed exclusively at natural persons with legal capacity to contract, and therefore the entry, stay and/or use of minors under 18 (eighteen) years of age is restricted. Without prejudice to the foregoing, ZENTRALY reserves the right to verify, by the means it deems most appropriate, the real age of any Data Holder. 6.2. Under suspicion that a Data Holder of the Application is under 18 (eighteen) years of age, and that he/she has falsified the data required for access, ZENTRALY may deny the aforementioned access to the Application. SEVENTH: Legal Requirements 7.1. ZENTRALY will cooperate with the competent authorities and other third parties to ensure compliance with the laws, for example, in matters of protection of industrial and intellectual property rights, fraud prevention, prevention of money laundering and terrorist financing and other matters. 7.2. ZENTRALY may disclose the Personal Information of Data Subjects due to legal obligation or at the request of the competent judicial or governmental authorities for the purposes of investigations conducted by them and in the event of any activity that may be illegal or that may expose ZENTRALY or the Data Subjects to any legal liability. In such situations, ZENTRALY will collaborate with the competent authorities in order to safeguard the integrity and security of the community and its Data Subjects. In all cases, in the event of a request for information requested by the authorities, ZENTRALY will require the corresponding notification duly signed by a judge and/or competent authority. In no event will ZENTRALY provide Personal Information of Data Subjects pursuant to information requests that are excessive and/or do not comply with the corresponding legal requirements. 7.3. In addition, ZENTRALY reserves the right (and Data Subjects expressly authorize it to do so) to communicate information to entities or third parties when there are sufficient reasons to consider that the activity of a Data Subject is suspected of attempting or committing a crime or attempting to harm other people. This right will be used by ZENTRALY to maintain the integrity and security of the community and its Data Subjects, to enforce the Terms and Conditions and other site policies and for the purposes of cooperating with the execution and compliance of the law. This right will be exercised by ZENTRALY regardless of whether there is no judicial or administrative order to this effect. 7.4. ZENTRALY will make every effort to protect the privacy of Personal Information, and will share such information in the cases referred to in this clause only when appropriate or necessary. EIGHTH: Security and Storage of Personal Information 8.1. ZENTRALY is obliged to comply with all applicable regulations regarding security measures applicable to Personal Information. In addition, ZENTRALY will use industry standards in matters of protecting the confidentiality of your Personal Information, including, among other measures, firewalls and Secure Socket Layers (SSL). ZENTRALY considers the Personal Information of Data Subjects as an asset that must be protected from any loss or unauthorized access. To this end, ZENTRALY employs various security techniques to protect such data from unauthorized access by Data Subjects inside or outside the company. Notwithstanding the foregoing, considering that the Internet is an open system, publicly accessible, ZENTRALY cannot guarantee that unauthorized third parties will eventually be able to overcome security measures and use Personal Information improperly. 8.2. All information we receive about you is stored on secure servers and we have implemented appropriate and necessary technical and organizational measures to protect your personal data. ZENTRALY continually evaluates the security of its network and the adequacy of its internal information security program designed to (a) help keep your data safe in the event of accidental or unlawful loss, access or disclosure; (b) identify reasonably foreseeable risks to the security of ZENTRALY's network; and (c) minimize security risks through risk assessments and regular verifications. 8.3. The Data Owner expressly acknowledges and accepts that ZENTRALY, at its sole discretion, may collect, store and eventually monitor the exchange of messages and emails between its Data Owners, carried out within the ZENTRALY Application, in order to contribute to the security of the relationships and communications that are developed through the Application. 8.4. Therefore, ZENTRALY is not responsible for illegal interceptions or violations of its systems or databases by unauthorized persons. ZENTRALY is also not responsible for the improper use of the information obtained by these means. 8.5. All personal data of the Data Owners will be stored in an automated personal data file or medium. The ZENTRALY Data Owners' personal data file or medium resides in the United States of America. NINTH: Change in email preferences 9.1. Without prejudice to the fact that ZENTRALY wishes to keep Data Subjects updated at all times regarding promotions, news, changes, etc., Data Subjects may select the emails and promotional information they would like to receive from ZENTRALY. 9.2. If the Data Subject does not wish to receive such emails, he or she may cancel his or her subscription by changing his or her preferences in the email following the instructions that ZENTRALY provides in its communications or by accessing his or her Account. TENTH: Linked Sites 10.1. The Application may contain links and/or references to other applications or websites, which does not indicate that they are owned or operated by ZENTRALY. The installation of these links or references in the Application is limited to facilitating the Data Subject's search and access to the information available there. Since ZENTRALY has no control over such sites, it will NOT be liable for the content, materials, actions and/or services provided by them, nor for damages or losses caused to Data Owners or third parties due to the use of the same. The presence of links to other applications or websites does not imply a partnership, relationship, approval and/or endorsement by ZENTRALY of said platforms or sites and their content. ELEVENTH: Modification of the Privacy Policies 11.1. ZENTRALY may modify these Privacy Policies at any time by making the modified Privacy Policies public on the Application. All modified terms will enter into force 10 (ten) calendar days after their publication. In the event of disagreement regarding such modifications, the Owner must notify ZENTRALY of their NON-acceptance by sending an e-mail to [info@peisa.com.ar] from their e-mail address registered in the Application within 10 (ten) calendar days following the publication of the modifications introduced, in which case their Account will be cancelled and their relationship with ZENTRALY will be considered terminated, and said Owner must previously comply with any pending obligation. Once the aforementioned period has expired without expressing their disagreement with the new Privacy Policies, it will be considered that the Owner accepts them and the parties will continue to be bound according to said terms. TWELFTH: Contact 12.1. To make any query, claim and/or request regarding your Personal Information, you may do so by accessing the Application; or by sending us an email to [info@peisa.com.ar] from the email address registered in your Account.