Privacy and Personal Data Protection Policy

This privacy and personal data protection policy, the "Privacy Policy" below, corresponds to that applicable to the matters indicated herein, and to the websites and related services published, promoted or provided by VMETRIX GROUP INC, 8 The Green Ste A, Num 15247, Zip 19901, DE, United States, (hereinafter "VMETRIX"), who is the controller, and the responsible for the use and protection of your personal data.

For the purposes of this Privacy Policy, the following affiliate entities of the VMETRIX group shall also be understood as "VMETRIX".

• VMetrix SRL de CV.

• VMetrix Brasil Tecnologia Ltda.

• VMetrix Chile SpA.

• VM Servicios y Tecnología Chile SpA.

This Privacy Policy shall also apply in all access to Services that contain a direct access link to the text of this document, and also apply in all cases where the relationship between VMETRIX and Users who access and use SaaS software or digital services (the "Services"), offered by VMETRIX is not already governed by contractual provisions between the parties or other document or clauses of privacy or personal data protection of specific application. Also, in everything that is not contrary to them, this Privacy Policy shall be understood to be part of all acts and agreements that are executed or entered into between Users and VMETRIX.

This Privacy Policy shall also apply to any contract or agreement that expressly refers to it.

In case of a discrepancy between this Privacy Policy and any other contract or written agreement and in force between the User and VMETRIX, or between VMETRIX and any other Party, what is indicated in such contract or written agreement and in force shall prevail.

This Privacy Policy describes in detail how VMETRIX collects, uses, protects and shares Personal Data and Personal Information of its Users and / or Visitors. VMETRIX will inform about this Privacy Policy to anyone accessing VMETRIX Services.

For all purposes of this document, "User" means the person who voluntarily registers and formally identifies himself/herself in the forms, records, communications and enabled sections of VMETRIX Services. "Visitor" means the person who, without formal identification, makes anonymous and free entry to the web pages included in or related to the Services.

This Privacy Policy comes into force upon acceptance by the User and/or Visitor and will remain in force until the User and/or Visitor revokes the authorization of the processing, or requests the deletion or suppression of their Personal Data. The request for revocation, cancellation, or deletion of personal data processing must always be made in writing and shall not have retroactive effect.

VMETRIX may modify this Privacy Policy at any time. Any change to this Privacy Policy will be published on the website www.vmetrix.com/privacy

Please read this Privacy Policy before accessing and/or using the Services or registering as a User.


SECTION ONE:
Collection of Personal Data and Personal Information

1.1 To be able to use the Services, the User and/or Visitor must complete a registration or contact form ("Registration Form") with Personal Data such as full name, national identity card or tax identification number, email address, business address, telephone number and other information that may be requested or necessary for the proper use of the Services.

1.2 In addition, when using the Services, the User and/or Visitor must provide VMETRIX with information about their specific requirements in relation to the Services, including the ability of VMETRIX to record or record the content of written and/or audiovisual communications that the User and/or Visitor may make at the time of requiring VMetrix Services.

1.3 The Users and/or Visitor undertake to provide their Personal Data in the Registration Form in an accurate, precise and reliable manner, and to update their Personal Data whenever these may be modified.

1.4 The Personal Data provided by the User in the Registration Form must be accurate, up to date and truthful at all times. VMETRIX reserves the right to request additional evidence and/or information to verify the Personal Data provided in the Registration Form, and to suspend, temporarily and/or permanently, any User whose data has not been validated within the period indicated by VMETRIX. However, VMETRIX is not responsible for the accuracy of the data entered in the Registration Form, since such data has been provided by the User and is the sole responsibility of the User. In this sense, the User guarantees and is responsible, under any circumstances, of the truthfulness, accuracy, validity and authenticity of their Personal Data.

1.5 VMETRIX will be responsible for collecting the Personal Data that the User and/or Visitor provides in a personal database. Similarly, the Personal Information of Users and / or Visitors will be collected and used in the manner described in this Privacy Policy.

1.6 VMETRIX will collect Personal Data always maintaining and respecting a criterion of proportionality, that is, only collecting those data necessary for the proper provision of the Services to the User and / or Visitor. In this sense, it is forewarned that VMETRIX does not seek to collect sensitive data, but only those personal contact and identification data.


SECTION TWO:
Personal Account

2.1 Once the User has completed the Registration Form, VMETRIX shall provide each User with a personal account ("Account") to access the Services using a password of the User's choice. The User shall access his or her Account by entering his or her username and personally chosen password.

2.2 The Account shall be personal, individual and non-transferable, and it is expressly prohibited for the same User to register more than once or to have more than one User Account. If VMETRIX detects or reasonably deduces that different Accounts contain matching user data, it may cancel, suspend or deactivate the linked Accounts without granting the Users holding such Accounts any right to claim.

2.3 The User shall be solely responsible for the care and proper use of his or her Account, as well as for the safekeeping of his or her protected password. If for any reason the User considers that your password has been breached, you must change it by entering the password modification option provided for these purposes in the Services.

2.4 The User registered in VMETRIX and holder of an Account expressly authorizes VMETRIX to access at any time to all information contained in that Account, including, specifically and without limitation, your Personal Data and Personal Information about their interests, content preferences, contacts and / or any other content stored in your Account and Registration Form.


SECTION THREE:
Use of Personal Data and Personal Information

3.1 By accepting the Privacy Policies, the User and/or Visitor declares that:

• VMETRIX is authorized to verify, collect, collect, process, use and share the User's and/or Visitor's Personal Data in accordance with these Privacy Policies and the Law.

• VMETRIX, may treat, process, or transmit Personal Data to its affiliated companies, as well as entrust third parties contractually related and located within or outside the territories of the United States, Argentina, Brazil, Colombia, Mexico, Chile, Paraguay, Peru, the sub-processing of this Personal Data within the scope of the Services.

• VMETRIX, is authorized to collect and process the Personal Data for the creation and administration of a VMETRIX single sign-on (SSO) account, and offer Services on our wesites, and for the technical, commercial and functional management of these Services.

• VMETRIX is authorized to collect and process the Personal Data of the User and / or Visitor and Personal Information to develop internal studies on the interests, behavior and demographic composition of the User and / or Visitor for better development of its Services.

• VMETRIX is authorized to send to the User's email information or announcements related to the services provided by VMETRIX. This could include personal passwords to be used in the Services, reminders of payment due dates and other obligations acquired by the use of the Services. The User and/or Visitor may at any time request to be excluded from the list of recipients who receive promotional and/or advertising information, by sending an email to privacy@vmetrix.com.

• Calls made to VMETRIX technical support service may be recorded in order to monitor the Service offered by VMETRIX; any questions, suggestions or complaints may be referred to the appropriate agency; any serious situations that are reported will be investigated in depth; and to improve the operational efficiency of this service to the User.

• VMETRIX is authorized to deliver the Personal Information and Personal Data of the User and/or Visitor, always in compliance with applicable regulations, for the purposes of cooperating with judicial and/or governmental authorities, to the extent that VMETRIX deems necessary and appropriate in the context of the investigation of a crime or fraud, infringement of industrial or intellectual property rights, or any other activity that is considered unlawful or that may make VMETRIX or its Users and/or Visitors legally liable. VMETRIX may exercise this right for the purpose of cooperating in compliance with or enforcement of the law, regardless of the existence of a judicial or administrative order in this regard.

• The User and/or Visitor agrees to be solely responsible for all actions taken in the use of the Account, including responsibility for the payment of any fees subsequently incurred or damages that other Users and/or Visitors and/or third parties may suffer as a result thereof.

3.2 VMETRIX will collect, use and share the Personal Data and Personal Information of the User and/or Visitor in order to safeguard Users and/or Visitors and ensure the proper provision of the Services.

Thus, VMETRIX may use the information collected to:

• Create and update the User Account.

• Verify the identity of the User.

• Verify the accuracy of the Personal Data of Users.

• Process and/or facilitate the payment of the Services (Price, and/or Fee).

• Allow VMETRIX and the User and/or Visitor to communicate with each other about any issues that may arise during the provision of the Service.

• Allow the technical support service of the Platform to contact the User so that the provision of the Service is efficient and fast.

• Conduct tests, research and analysis in relation to the provision of the Services and on the Services provided to Users.

• Send to the Users information about new Services and their updates.

• Use the Personal Information contained in the accounts of Users in order to prevent and identify fraud, risk situations or dangerous activities, ie practices that VMETRIX and / or Users believe pose a threat to the security of the Platform. In such situations, VMETRIX is entitled to disable such accounts.

SECTION FOUR:
Security and Storage of Personal Data

4.1 VMETRIX will manage the Personal Data of its Users and/or Visitors in accordance with the provisions of the Law, always seeking the broadest respect for the fundamental rights of Users and/or Visitors.

4.2 VMETRIX considers Personal Data and other Personal Information of its Users and / or Visitors as an asset that must be protected against any loss or unauthorized access: therefore, take all necessary measures to safeguard them by implementing efficient data protection mechanisms, such as firewalls and Secure Socket Layers (SSL). VMETRIX is obliged to comply with all applicable regulations regarding security measures for Personal Data, applying industry standards for the protection and confidentiality of Personal Information.

4.3 Notwithstanding the foregoing, considering that the Internet is a system open to public access, VMETRIX can not guarantee that unauthorized third parties may not possibly breach the security barriers and make improper use of Personal Information and / or Personal Data of the User.

4.4 The User and / or Visitor is aware and expressly agrees that VMETRIX, at its own discretion, collate, store and possibly monitor the exchange of messages and emails between Users and / or Visitors carried out on the Platform, in order to contribute to the security of relations and communications developed through the Platform.

4.5 VMETRIX is not responsible for illegal interceptions or violations of its systems or databases by unauthorized third parties. VMETRIX also not be responsible for the misuse of information obtained by these means.

4.6 VMETRIX not sell, rent or share Personal Data or other Personal Information of its Users and / or Visitors, except as expressly provided in this Privacy Policy.

4.7 VMETRIX may store Personal Data and Personal Information of Users and / or Visitors for a period of five (5) years, in order to safeguard and allow the resolution of any disputes or complaints, detect problems or incidents and resolve them, and comply with the provisions of this Privacy Policy and the Terms and Conditions.


SECTION FIVE:
Policy regarding Cookies

5.1 Cookies (hereinafter "Cookies") are small files that are stored on the User's and/or Visitor's computer terminals and are designed to store a quantity of data specific to a User and/or Visitor and online media. This makes it possible for the Platform to function properly.
5.2 The User and/or Visitor may accept or reject the use of Cookies; however, the functionality of VMETRIX services depends to a large extent on their use. Therefore, if the User and/or Visitor rejects them, the functionality and availability of the Services may be affected.

5.3 The User and/or Visitor who decides to delete Cookies must configure his or her Account for this purpose through the configuration mechanisms of his or her device.

5.4 It should be noted that in the event that VMETRIX or its associated or affiliated companies make use of Cookies and other similar identification technologies, its main objective will be to understand the behavior of its Users and / or Visitors in order to offer a comprehensive, personalized and secure service.

5.5 You can block cookies directly in your browser, and/or prevent them from being created. You can also delete those that have already been saved in the settings of the browser you use. However, should you disable, reject or block cookies, some parts of our website may not work properly.

5.6 For this purpose, VMETRIX will use the following Cookies:

• Behavioral Cookies: these facilitate the operation and functionality of the Platform, such as, for example, allowing the User to access their Account.

• Security and integrity Cookies: these are those that allow the company to offer Users and/or Visitors a safe and secure site according to the preferences registered in their Account. This prevents anyone other than the specific User and/or Visitor from accessing it.

• Research and analysis cookies: are those that improve the service provided to Users and/or Visitors in their access to the Services. They allow maintaining a personalized record for each User and/or Visitor through the configuration established by him/her in his/her Account; once this information is obtained, the traffic on the Platform can be analyzed to know his/her tastes and preferences. This allows us to improve our products and services.

• Marketing Cookies: are those used to present relevant advertising and analyze the efficiency and effectiveness of advertising campaigns.

The complete List of each Cookie can be found here.

SECTION SIXTH:
Rights of Access, Modification, Rectification, and Elimination of Personal Data

6.1 The User and/or Visitor may exercise his/her right to access, modify, rectify and delete his/her own Personal Data, including his/her e-mail address, as well as to refuse the processing of his/her data and to be informed of the delivery and/or international transfer of his/her Personal Data, in accordance with the provisions of the Law.

6.2 The User and/or Visitor, holder of the Personal Data, upon proof of identity may exercise the right of access, modification, rectification and/or deletion of their Personal Data, free of charge, which must be resolved by VMETRIX within two (2) days from the date of the request.

6.3 The request for access, modification, rectification and/or deletion of Personal Data must be sent by email to privacy@vmetrix.com, and include the full name, national identity card number or tax identity number, and cell phone number.


SECTION SEVENTH:
Minors

7.1 The Services may only be used by persons over 18 years of age, being prohibited access by persons under 18 years of age.

7.2 VMETRIX reserves the right to verify, by the means it deems most appropriate, the actual age of any User and / or Visitor.

7.3 Upon suspicion that a User and / or Visitor may be under 18 years and has entered false information in the Registration Form, VMETRIX may reject the Registration Form and / or cancel the Account, without right to claim by the User and / or Visitor affected.


SECTION EIGHTH:
Legal Requirements. Petitions. Procedures

8.1 VMETRIX will cooperate with the competent authorities and third parties to ensure compliance with current regulations, for example, in matters such as the protection of industrial and intellectual property rights and fraud prevention, among others.

8.2 In this context, VMETRIX may disclose Personal Information and Personal Data of its Users and/or Visitors in the event that it is requested by the competent judicial or governmental authorities in order to carry out their inquiries, even if there is no court order or judicial or executive subpoena, as well as in the case of an investigation of a criminal nature or of a fraudulent nature or associated with hacking or copyright infringement. In these situations, VMETRIX will cooperate with the competent authorities in order to safeguard the integrity and security of the community and its Users and/or Visitors.

8.3 For these purposes, VMETRIX may provide all Personal Information and / or Personal Data of its Users and / or Visitors, in order to comply with current regulations and cooperate with the competent authorities, to the extent that they deem necessary and appropriate in connection with any investigation of an illegal or fraudulent activity, violation of industrial or intellectual property rights, or other activity considered illegal or for which VMETRIX or its Users and / or Visitors may be held legally responsible. VMETRIX exercise this right for the purpose of cooperating in compliance with and enforcement of the law, regardless of whether there is no court or administrative order issued for this purpose.

8.4 Additionally, VMETRIX reserves the right (and Users and / or Visitors expressly authorize it) to disclose information to organizations or third parties when there are sufficient grounds to believe that the activity of a User and / or Visitor is suspected of attempting to commit a crime, administrative offense, or harm others. VMETRIX exercises this right in its sole discretion, when it deems appropriate or necessary to maintain the integrity and safety of the community and its Users; to comply with the Terms and Conditions and Privacy Policies of its Platform; and for the purpose of cooperating in the implementation and enforcement of the law. VMETRIX will exercise this right to cooperate in law enforcement and compliance, regardless of whether there is no judicial or administrative order to this effect.


SECTION NINE:
Changes in email and SMS preferences

9.1 Notwithstanding that VMETRIX aims to keep its Users and / or Visitors permanently informed about their offers, news, products on sale, etc., Users and / or Visitors may at any time choose which emails and promotional material they wish to receive from VMETRIX.

9.2 In the event that the User and / or Visitor does not wish to receive such material, you may request it by modifying your email preferences in accordance with the instructions provided by VMETRIX in such correspondence, or through your Account, selecting the information you actually want to receive.


SECTION TEN:
Special and Local Regulations

10.1 Processing of Personal Data of Workers, Employees, and candidates for employment positions in VMETRIX.

This Privacy Policy shall also apply, in all that is not expressly contrary thereto, and without limitation to the rights of the holder of Personal Data, the treatment or processing of Personal Data that performs VMETRIX for purposes of its labor relations with workers, employees, current, future and / or past, and persons applying for employment positions in VMETRIX.

Thus, VMetrix may process, process, order, transfer across borders the sub-processing of Personal Data of Workers, Employees, and candidates for employment positions at VMETRIX under the terms and limitations set forth in this Privacy Policy.

For the purposes of this section, the Personal Data processed or collected will correspond to those of identification, contact, aspects of professional history, and those necessary for the proper fulfillment of any contractual obligation between the holder of such Personal Data and VMETRIX.

For this matter, the purposes of processing of personal data are related exclusively to:

• Search and selection of professional profiles for possible hiring of workers.

• Registration of information for recruitment and selection metrics.

• Management of labor aspects, contractual, tax and social security obligations of workers.

In case of discrepancy between this Privacy Policy and the contents of any contract or agreement between VMETRIX and the employee, the contract or agreement shall prevail.


10.2 Processing of Personal Data of suppliers, consultants and independent contractors.

This Privacy Policy shall also apply, to the extent not expressly contrary thereto, to VMetrix's processing of Personal Data of data of right holders who provide products or services to VMETRIX as suppliers, independent contractors, or consultants.

Thus, VMetrix may handle, process, commission, transfer across borders the sub-processing of Personal Data for the exclusive purposes of managing the performance of any contract existing between VMETRIX and the supplier, consultant and/or independent contractors.

In case of discrepancy between this Privacy Policy and the contents of any contract or agreement between VMETRIX and the supplier, independent contractor, or consultant, the contract or agreement between the parties shall prevail.


10.3 Video and automated survaillance recordings.

VMETRIX uses technological means of surveillance at the physical access points to its offices. These include video surveillance, sensors, and other security measures, hereinafter "Security Surveillance Logs".

VMETRIX may process personal data and information through its Security Surveillance Logs for purposes of legitimate interest and as a mechanism of compliance with regulations and current contracts with suppliers and customers.

We may process, transfer, commission the sub-processing of Personal Data contained in Security Surveillance Logs to our security service providers, IT providers and other business partners providing services on our behalf, to the extent necessary for them to perform their tasks.

The processing of Security Surveillance Logs is carried out under strict principles of minimization of use of Personal Data, privacy by design, and with full respect for the applicable legal standards in each territory where these activities are carried out.


10.4. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

If you are a California resident, you may request that we disclose to you the categories of personal information we collect about you.
If you are a California resident, you may obtain information about exercising your rights by emailing privacy@vmetrix.com.


10.4. PERSONAL DATA PROTECTION OFFICER

Mr. Diego Maldonado Rosas
privacy@vmetrix.com


This version of the Privacy Policy (ESEN240110) was published on January 19th 2024.