ORG Auditores Independientes, S.A.
Last updated: August 24, 2026

1. Purpose

ORG Auditores Independientes, S.A. ("ORG Auditores") recognizes the importance of privacy and of protecting the personal data of its clients, prospective clients, website users, subscribers, and all other individuals who interact with the organization.

This Privacy and Personal Data Protection Policy sets out the general principles governing the collection, use, storage, protection, and deletion of personal data under the responsibility of ORG Auditores.

This Policy has been developed in accordance with Law No. 81 of March 26, 2019 on Personal Data Protection, Executive Decree No. 285 of May 28, 2021, and all other applicable laws and regulations in the Republic of Panama.

2. Data Controller

The data controller responsible for processing personal data is:

ORG Auditores Independientes, S.A.
Republic of Panama
Website: orgauditores.com.pa
Email for inquiries and the exercise of personal data rights: legaltax@orgauditores.com.pa

3. Scope

This Policy applies to personal data obtained through, among other means:

• The ORG Auditores website.

• Contact forms and requests for information or quotations.

• Subscriptions to newsletters and other communications requested by the user.

• Communications by email, telephone, or other channels provided by ORG Auditores.

• Business, contractual, or professional relationships, as applicable.

Certain professional, employment, contractual, or legal relationships may also be subject to specific notices, agreements, or provisions.

4. Personal Data We May Collect

Depending on how you interact with ORG Auditores, we may collect data such as:

• First and last name.

• Company or organization.

• Email address.

• Telephone or WhatsApp number.

• Information about how you learned about ORG Auditores.

• Information voluntarily included in inquiries, comments, or service requests.

• Information required to manage a newsletter subscription.

• Technical information related to use of the website, such as pages visited, date and time of access, referral source, browser, device, and other technical data used for statistical and security purposes.

ORG Auditores seeks to collect only data that is adequate, relevant, and necessary for the applicable purpose.

5. Purposes of Processing

Personal data may be used for the following purposes:

• To respond to inquiries and requests submitted through the website.

• To prepare or follow up on requests for information, proposals, or quotations.

• To establish and maintain communications related to requested services.

• To manage business or professional relationships.

• To comply with applicable contractual, accounting, tax, regulatory, or legal obligations.

• To manage subscriptions and send newsletters or communications when the data subject has requested or authorized them.

• To maintain the security and proper operation of the website.

• To compile general statistics on website use and performance in order to improve it.

ORG Auditores will not use the personal data it collects for purposes incompatible with those for which the data was obtained unless there is a lawful basis for doing so or, where applicable, the data subject provides a new authorization.

6. Legal Bases for Processing

Personal data may be processed, as applicable, on the basis of:

• The data subject's consent.

• A request made directly by the data subject.

• The performance or fulfillment of a contractual or business relationship.

• Compliance with legal or regulatory obligations applicable to ORG Auditores.

• A legitimate interest permitted by applicable law, provided that the data subject's rights and freedoms do not take precedence.

For newsletters and other promotional communications, information will be used for that purpose only when the individual has requested or authorized receipt of those communications.

7. Website Forms

When an individual uses the forms available at orgauditores.com.pa, the data provided is used to receive, respond to, and follow up on the relevant inquiry or request.

Information received through these forms is currently stored using technology infrastructure provided by Hostinger.

Users should avoid including sensitive information or third-party personal information that is not necessary for us to respond to their request.

8. Newsletters and Communications

When an individual voluntarily subscribes to the ORG Auditores newsletter, their contact information may be processed using EnvialoSimple, the platform used to manage and send those communications.

The individual may stop receiving these communications by using the available unsubscribe options or by directly requesting deletion of their data at:

legaltax@orgauditores.com.pa

Unsubscribing will not affect other processing that ORG Auditores may be required to continue for contractual or legal reasons, as applicable.

9. Web Analytics and Cookies

ORG Auditores uses web analytics tools to gain a general understanding of how its website is used and how it performs.

These tools include Matomo, which is configured to operate without tracking cookies. This information is used to generate statistical metrics such as visits, pages viewed, general traffic sources, and technical browsing characteristics.

ORG Auditores does not use these analytics for behavioral advertising or to create commercial profiles of website visitors.

The website's current analytics configuration does not use tracking cookies to identify visitors on a persistent basis.

If technologies requiring non-essential cookies or additional consent mechanisms are introduced in the future, this Policy and the relevant notices will be updated as necessary.

10. Technology Service Providers and Third Parties

ORG Auditores may use technology service providers only to the extent necessary to operate its services and fulfill the purposes described in this Policy.

Technology providers currently involved in website-related activities include:

• Hostinger, for website hosting, storage related to forms, and associated technical services.

• EnvialoSimple, for managing and sending requested newsletters and communications.

• Matomo, for statistical measurement and analysis of website use.

The use of these providers does not involve the sale or other commercial exploitation of personal data databases.

ORG Auditores seeks to ensure that providers with access to personal data, or that process such data, do so only for the applicable purposes and subject to reasonable confidentiality and security measures.

Some technology providers may operate infrastructure located outside the Republic of Panama. Where personal data is processed or transferred internationally, ORG Auditores will seek to ensure that such processing or transfer complies with the requirements and levels of protection established by applicable law.

11. Data Retention

ORG Auditores does not apply a single retention period to all personal data.

Data will be retained only for as long as reasonably necessary to fulfill the purpose for which it was collected and, where applicable, for the period required to meet legal, tax, accounting, contractual, or regulatory obligations.

In particular:

• Data associated with an inquiry or contact request may be retained for as long as necessary to respond to and follow up on that request.

• Data used to send the newsletter may be retained for as long as the individual remains subscribed.

• When data is no longer necessary and there is no legal obligation justifying its retention, it may be deleted, blocked, or anonymized, as applicable.

The data subject may also request deletion of their data in accordance with the rights established under applicable law.

12. Security and Confidentiality

ORG Auditores implements reasonable administrative, organizational, and technical measures designed to protect personal data against unauthorized access, loss, alteration, disclosure, or misuse.

Access to personal information must be limited to individuals and service providers who need it to perform their duties or provide the relevant services.

Anyone with access to personal data must maintain the confidentiality of that information in accordance with applicable legal and professional obligations.

No technology system can guarantee absolute security. Nevertheless, ORG Auditores seeks to maintain safeguards proportionate to the nature of the information processed and the associated risks.

13. Data Subject Rights

Under Panamanian personal data protection law, the data subject may exercise, as applicable, the following rights:

• Access: to learn whether ORG Auditores holds or processes personal data relating to the data subject and to obtain information about such processing.

• Rectification: to request the correction or updating of data that is incorrect, incomplete, outdated, or inaccurate.

• Cancellation (erasure): to request the deletion of personal data where permitted by law.

• Objection: to object to certain processing of personal data or withdraw consent when consent is the basis for processing.

• Portability: where legally applicable, to request a copy of personal data in a structured, commonly used format.

These rights may be exercised free of charge, and requests will be handled within the time limits established by applicable law.

14. How to Exercise Your Rights

To submit a request concerning personal data, the data subject may write to:

legaltax@orgauditores.com.pa

The request must provide sufficient information, including:

• The requester's name.

• A means of receiving a response.

• The right or action the requester wishes to exercise.

• The information needed to identify the data covered by the request.

ORG Auditores may request reasonable information to verify the requester's identity and prevent personal data from being disclosed, modified, or deleted at the request of an unauthorized person.

If the request is submitted through a representative, ORG Auditores may require appropriate documentation establishing that representative's authority.

15. Competent Authority

The National Authority for Transparency and Access to Information (ANTAI) is the competent authority for personal data protection matters in the Republic of Panama.

A data subject who believes that their personal data protection rights have been violated may bring the matter before ANTAI in accordance with the procedures established by applicable law.

16. Updates to This Policy

ORG Auditores may update this Privacy and Personal Data Protection Policy in response to legal, regulatory, technological, or operational changes.

The current version will be available at orgauditores.com.pa and will state the date on which it was last updated.

17. Contact

For questions about this Policy, the processing of personal data, or the exercise of the corresponding rights, please contact:

ORG Auditores Independientes, S.A.
Email: legaltax@orgauditores.com.pa
Website: orgauditores.com.pa

Privacy and Personal Data
Protection Policy