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PRIVACY STATEMENT

























This Data Privacy Statement explains how Spyderbat and the legal entities/subsidiaries of the AGT NETWORKS Group of Companies (hereinafter “Company”, “we”, “us” or “our”) processes personal data acting as the “data controller”, for the proper development of its social object and business purposes, AGT performs the activities of collection, exchange, updating, processing, reproduction, compilation, storage, use, systematization, and organization (hereinafter referred to as “processing”) of personal data. Because of the above, Spyderbat, as the data controller, has a Personal Data Protection Policy, which guides its actions regarding this information.

1. ABOUT THE PERSONAL DATA

For Spyderbat, “Personal Data” means all the information related to an identified or an identifiable natural person. The Data may be collected by different means, including:


CV, resume, labor or personal references.



Spyderbat Website Contact Form.



Public social media, databases of risk, judicial or security records legitimately constituted national or foreign nature.



Interview reports, tests and/or assessments.



Electronic devices such as surveillance cameras and biometric systems installed at the offices.



Third parties such as recruitment agencies, assessment partners, Suppliers, customers, our employees.


2. USE OF THE PERSONAL DATA

The processing of personal information is carried out for the following purposes:

2.1 CUSTOMERS

(i) To carry out all the activities and administrative procedures related to the services provided by Spyderbat; (ii) Carry out surveys and/or research studies to evaluate the process of attention and satisfaction of the service provided; (iii) Send information (e.g. to e-mails and contact numbers) of customers about the products, services, events and/or promotions of Spyderbat; (iv) Transfer and/or transmit corporate contact information to other entities of the Spyderbat group and to third parties for the purposes described above for the purposes described above; (v) Transfer the personal data of customers in the framework of the definition, structuring and execution of strategic transactions, such as the sale of assets or shares The Company or parts of its business are sold, merged or acquired by third parties; (vi) Control and prevention of fraud, bribery, corruption and Money Laundering / Financing of Terrorism or proliferation of mass destruction weapons. The possibility of reporting data on non-compliance with obligations, as well as unusual or suspicious operations, is included. As well as investigation, verification and validation of the information provided, with any information legitimately acquired by Spyderbat, and international lists on the commission of crimes and money laundering for the purpose of initiating, executing, developing and terminating the contractual relationship; (vii) Storing the information in databases, as well as the custody or maintenance of these by AGT NETWORKS or a third party; (viii) To stablish efficient communication in compliance with the provisions of the contractual obligations and for any matters concerning the administrative management of the relationship; (ix) following up on complaints, grievances and suggestions; (x) Communicating your personal data to judicial and/or administrative authorities and/or other control entities, when required.

2.2 CANDIDATES

(i) Request the supports and related information on the resume; (ii) Send and receive by email communications and requests related to the selection process; (iii) Verify and consult with third parties the information on the resume (authenticity of documents, work and academic certifications, safety studies, home visit). ; (iv) Record in the Sypderbat database the selection process in order to have support with internal and external authorities; (v) Communicate to the contact phones in order to schedule the interviews and tests required for Spyderbat workers or third parties to perform the validations of the information indicated in the resume and evaluations of all tests advanced in the process (vi) Retain for at leastten years the personal data for possible selection processes; (vii) Assess the suitability of the candidate, taking into account the characteristics of the vacancy that is required to hire; (vii) Carry out the necessary checks and consultations in different restrictive lists; (ix) Consult and access at any time the databases of risk, credit, financial, judicial or security records legitimately constituted, of a state or private, national or foreign nature; (x) Carry out the relevant steps for the development of the pre-contractual, contractual and post-contractual stage; (xi) Contact them in compliance with the provisions of the contract and for the administrative management thereof; (xii) To ensure security in the facilities where appropriate; (xiii) To be invited to training, instructions, reinforcement, or the development of institutional activities; (xiv) To conduct satisfaction surveys; (xv) To transfer the personal data of candidates in the framework of the definition, structuring and execution of strategic transactions, such as the sale of assets or shares in case The Company or parts of its business are sold, merged or acquired by third parties; (xv) Storing the information in databases, as well as the custody or maintenance of these by AGT NETWORKS or a third party.

2.3 CONTRIBUTORS

(i) Identify the staff as Spyderbat collaborators; (ii) Communicate to the staff and make their knowledge relevant information in accordance with the quality of Spyderbat collaborator; (iii) Verify the fulfillment of the employee’s employment and contractual obligations; (iv) Review the criminal, contractual and fiscal records of the holders before the relevant authorities; (v) Full identification of the holders, by archiving and handling their contact data, professional and academic information, among others; (vi) Conclude the contract of work, apprenticeship, service provision or any other that applies; (vii) Fulfill the obligations of Spyderbat membership, such as: affiliation to the social security system, payment of contributions, to the compensation fund, holidays, delivery of vouchers, payments to the tax authority, to issue certificates of income and withholding and employment certificates requested by the holders, and / or any national entity or authority that requires personal data, in accordance with current rules; (viii) To comply with any other benefit that derives from the contractual relationship between the collaborators and Spyderbat To provide instructions on the occasion of the contract with the collaborators, if applicable; (ix) To evaluate the performance of the collaborators; (x) To manage the payroll, the payment of financial support, among others, by the Company or a third party; to manage and make the necessary payments in the bank account indicated by the collaborators; (xi) To contract life insurance and medical expenses with Spyderbat or a third party; (xii) To notify the relatives of the collaborators in cases of emergency during working hours or during the development of the contract; (xiii) The communication, reproduction and publication of photographs of the collaborators by Spyderbat for marketing, advertising, internal Spyderbat or other purposes; (xiv) Maintain the safety and health of employees in the workplace directly by the Company or by a third party, in accordance with the rules applicable to the “Management of Safety and Health at Work System” and keep the documents as indicated in law; (xv) Collect information and evidence for the purpose of carrying out disciplinary proceedings, if applicable; (xvi) Store the personal data of employees in the internal physical and computer file of AGT NETWORKS, the other companies of the group and / or third parties in charge of storage; (xvii) Transfer and / or to other entities of the AGT NETWORKS Group, to public entities and to third parties for the purposes described above; (xviii) to transfer the personal data of the partners in the framework of the definition, structuring and execution of strategic transactions, such as the sale of assets or shares in case The Company or parts of its business are sold, merged or acquired by third parties; (xix) to carry out epidemiological surveillance activities framed in the Occupational Health program; (xx) Carry out the control of entry or exit records, as well as other events that may arise for security reasons in the physical and virtual facilities of Spyderbat; (xxi) As evidence in administrative procedures that Spyderbat carries out in compliance of the Labor agreements, the internal labor regulations, Code of Ethics, as well as other internal policies defined by the company. Likewise, it may be used in compliance of regulations on workplace harassment, disciplinary procedures or contract’s termination.

2.4 PROVIDERS

(i) To carry out the relevant steps for the development of the pre-contractual, contractual and post contractual phase with Spyderbat, regarding the commercial relationship with the supplier; (ii) Report to credit risk centers legally constituted in the respective countries, under the proper terms of law; (iii) Request information to suppliers and contractors for the purpose of concluding the applicable contract with Spyderbat; (iv) Compliance with Spyderbat obligations under the contractual relationship; (v) Investigation, verification and validation of information provided by suppliers and contractors, with any information from Spyderbat that legitimately has and lists; (vi) Management of information of suppliers and contractors for the authorization and sending of purchase orders and payment of invoices; (vii) Contact, meetings and visits with suppliers and contractors, their collaborators, shareholders and/or any person representing them in the framework of the contractual relationship; (viii) Communication, consolidation, organization, updating, control, accreditation, statistics, reporting, maintenance, interaction and management of the actions, information and activities in which suppliers and contractors are related or linked to Spyderbat; (ix) Other purposes necessary and provided in the environment of the contract; (x) Storing the information in databases, as well as the custody or maintenance of these by Spyderbat or a third party (xi)Transfer and/or transmit the personal information of suppliers to other entities of the AGT NETWORKS Group and to third parties for the purposes described above; (xi) Transfer the personal data of suppliers in the framework of the definition, structuring and execution of strategic transactions, such as the sale of assets or shares in case the Company or parts of its business are sold, merged or acquired by third parties.

3 PROCESSING OF SENSITIVE DATA

Spyderbat informs that it processes personal data of members of the family group of the human resource, including that of children and adolescents who integrate it, in order to grant the benefits offered by Spyderbat or for the registration of members of the family group in the events and welfare activities organized by Spyderbat. In the event of processing of personal data of children and/or adolescents, Spyderbat shall ensure that: (a) The processing responds to and respects the best interests of children and adolescents. (b) Treatment should ensure respect for the fundamental rights of children and adolescents. (c) Assess the child’s opinion when the child has the maturity, autonomy and ability to understand the matter.

In addition, the information processed may contain sensitive data, such as: the image, or any other physical trait that may be recorded in audio recordings, photographs and videos, the print and the signature. Similarly, health-related data may be required. In the processing of sensitive data, Spyderbat shall obtain the express consent of the data controller and inform the data controller that because sensitive data are not required to authorize their processing. Spyderbat will only collect information of a sensitive nature that is necessary and relevant to the fulfillment of the following purposes: (i) To verify whether the holders meet the physical requirements necessary to perform the position and/or obligations for which they are applying or were hired; (ii) To have the information necessary to attend any medical emergency that arises during the provision of services in the facilities of Spyderbat; (iii) To comply with occupational safety and health standards and implement the SG-SST, and any other program, system and/or plan that seeks to protect the health of the worker, holders and persons in the workplace; (iv) To carry out epidemiological surveillance activities within the framework of the Occupational Health program; (v) Compliance with the legal obligations arising from the employment and/or contractual relationship, such as, carrying out all the necessary formalities for the registration of beneficiaries with the Social Security System, or any other activity derived from the applicable legislation; (vi) Providing the respective security in the training and activities carried out by Spyderbat; (vii) Identifying the personnel who access the facilities of Spyderbat.

4 INTERNATIONAL TRANSFERS OF PERSONAL DATA

As AGT NETWORKS Group operates at a global level, we may need to transfer Personal Data to other AGT NETWORKS companies, their final clients or third-parties services providers located in countries other than the ones in which your Personal Data was originally collected.

Spyderbat will implement appropriate safeguards to ensure that an adequate level of protection for any Personal Data transferred. We will review that the party which will receive the Data is in a country or the Party adopts by its own an adequate level of protection for your personal information.

5 YOUR RIGHTS

In accordance with Law, the rights that you have as holder of the information are:


Know, update, and rectify your personal data



Revoke the authorization granted for the processing of your personal data.



Request the deletion of your personal data.



Request proof of the authorization granted.



Be informed of the use of your data.



File complaints with the competent data protection authority for violations of the provisions of the Law on Protection of Personal Data once you have exhausted the consultation or complaint procedure before AGT NETWORKS.



Access free of charge to your personal data that has been subject to Processing.


6 DATA CONTROLLER AND CONTACT DETAILS

Spyderbat is responsible for processing your personal information as described in this Privacy Notice, its subsidiaries could be also responsible if you share directly your data with its representatives.

If you have any questions about this Notice or if you would like to communicate with our specialized Team, please contact us at the following email address: info@spyderbat.com



Information we collect

We may collect a variety of information from or about you or your devices from various sources, as described below.



A. Information you provide to us

Registration. When you register for an account to use the Community Edition of our Services, we ask you for your Personal Information, which may include your name, email address, and password. If you register for an account to use the Professional or Enterprise Edition of our Services, we will ask you for additional Personal Information, including your phone number and business name.

Communications. If you contact us directly, we may receive additional Personal Information about you. For example, when you contact us for more information about Spyderbat, we will receive your name, email address, and any other information you choose to provide to us. If you subscribe to our newsletter, we will receive your email address.

Your use of our services. When you use our Services, we may collect Personal Information you provide or otherwise make available via our Services. For example, when you install an agent on your local machine, we will collect any Personal Information transmitted via the agent.

Careers. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect the Personal Information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform (such as Glassdoor or LinkedIn), we will collect any information you make available to us through such third-party platforms.



B. Information we collect when you use our services

Location information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, operating system version, and device identifiers.

Usage information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, such as date and time of visits, the pages viewed, links to/from any page, and time spent in a session.
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