PRIVACY POLICY
(pursuant to Law No. 81 of March 26, 2019 of the Republic of Panama and Execu%ve Decree No.
285 of May 28, 2021)
1. DATA CONTROLLER
The Data Controller is: BULL DIGITAL ASSET Inc.
Registered office: Republic of Panama, Panama city, 55st, Street East, SL55 Building, 21 ST floor, Office 3
IT infrastructure: Server located in Mexico
Email: info@calandridiamond.com
Website: www.calandridiamond.com
The Data Controller determines the purposes and means of processing personal data in accordance with applicable Panamanian legisla%on.
______________________________________________________________________________
2. PURPOSE OF PROCESSING AND LEGAL BASIS
Personal data is processed for specific, explicit, and legi%mate purposes, in accordance with Law No. 81/2019.
2.1 Main purposes
• Execu%on of contracts and provision of requested services
• Management of customer and user rela%onships
• Fulfillment of legal, tax, and administra%ve obliga%ons
• Management of requests for assistance and informa%on
2.2 Addi%onal purposes (subject to consent)
• Sending commercial and promo%onal communica%ons
• Direct marke%ng ac%vi%es
• Sta%s%cal analysis and improvement of services
Legal basis
The processing is based on:
• prior, free, express, and informed consent of the data subject
• performance of contractual or pre-contractual obliga%ons
• fulfillment of legal obliga%ons
• legi%mate interest of the Data Controller, within the limits established by law
3. CATEGORIES OF DATA PROCESSED
The Data Controller may process the following categories of data:
• Iden%fica%on data: name, surname, date of birth, personal iden%fica%on number
• Contact details: address, email, telephone number
• Contractual data: informa%on rela%ng to the services requested
• Financial data: payment informa%on and bank details
• Browsing data: IP address, logs, cookies
Sensi%ve data (e.g., health, religion, poli%cal opinions) are not processed, except where permiCed by law and with explicit consent.
4. PROCESSING METHODS AND SECURITY
Processing is carried out using electronic and, where necessary, paper-based tools, in compliance with the principles of:
• lawfulness
• fairness
• transparency
• propor%onality
• security
Security measures
The Data Controller adopts appropriate technical and organiza%onal measures, including:
• data encryp%on
• access controls and authen%ca%on
• monitoring and protec%on systems
• backup and disaster recovery
• training of authorized personnel
5. DATA COMMUNICATION AND TRANSFER
5.1 Recipients
The data may be communicated to:
• authorized personnel of the Data Controller
• technology and hos%ng service providers
• professional consultants
• financial ins%tu%ons
• public authori%es, in the cases provided for by law
5.2 Interna%onal Data Transfer
Personal data is processed and stored on servers located in Mexico.
Pursuant to Law No. 81/2019, interna%onal data transfer is permiCed when:
• the recipient country guarantees an adequate level of protec%on, or
• adequate contractual and technical guarantees are adopted
Safeguards Adopted
The Data Controller has implemented:
• Binding contractual agreements with hos%ng providers
• Security obliga%ons equivalent to Panamanian law
• Limita%ons on further data dissemina%on
• Right to audit and verifica%on
Technical measures
• Data encryp%on in transit and at rest
• Strong authen%ca%on
• Intrusion detec%on systems
• Secure backup
The data subject may:
• Request informa%on on the transfer
• Obtain a copy of the safeguards adopted
• Object to the processing within the limits established by law
6. RETENTION PERIOD
The data is retained for the %me necessary for the purposes of the processing:
• Contractual data: for the dura%on of the rela%onship and subsequently in accordance with legal obliga%ons
• Marke%ng data: un%l consent is revoked or for a maximum of 24 months
• Technical/log data: for a maximum of 12 months
Subsequently, the data will be deleted or anonymized.
7. RIGHTS OF THE INTERESTED PARTY
Pursuant to Law No. 81/2019, the interested party may exercise the ARCO rights:
• Access to personal data
• Rec%fica%on of inaccurate data
• Erasure of data • Objec%on to processing
Addi%onally:
• Right to restric%on of processing
• Right to withdraw consent
• Right to lodge a complaint with the competent authority
Supervisory Authority:
Na%onal Transparency and Informa%on Access Authority (ANTAI)
8. EXERCISE OF RIGHTS
Requests can be sent to:
Email: info@calandridiamond.com
Address: Republic of Panama, Panama city, 55st, Street East, SL55 Building, 21 ST floor, Office 3
The request must include:
• iden%fica%on data
• descrip%on of the right being exercised
The Data Controller will respond within 15 business days, which may be extended by law.
9. NATURE OF THE PROVISION
The provision of data is:
• Mandatory for contractual or legal obliga%ons
• Op%onal for marke%ng purposes
Failure to provide data may prevent the provision of services.
10. AUTOMATED DECISION-MAKING PROCESSES
The Data Controller:
uses automated decision-making processes, including profiling.
11. COOKIES
The site uses cookies and similar technologies.
For more informa%on, please consult the Cookie Policy: [link]
12. CHANGES TO THE POLICY
This policy may be updated. Changes will be communicated via the site or other appropriate channels.