Procedures for the attention of Rights

This document contains 3 sections:

In case of doubts with any of these procedures, we can advise you free of charge by email, through info@novus.law.

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SECTION I. PROCEDURE TO EXERCISE ARCO RIGHTS

1. The procedure for the exercise of ARCO rights will begin, at the request of the interested party, by means of a written request that must contain, at least, the following requirements:

The full name of the owner and his legal representative, if applicable;
Email for the purpose of communicating the response to the request.
Clear and precise description of the personal data with respect to which one seeks to exercise any of the ARCO rights;
Clear and precise description of the right to be exercised;
In the case of requests for rectification of personal data, the modifications to be made must be indicated with all precision and;
The number that identifies you as a customer of our products or services, if you have one.

1.1 A digitized color copy of the following must be added to said request:

Official identification that proves the identity of the interested party and their legal representative (eg voting credential, passport, driver's license, professional card, citizen identity card, SMN card);
Document stating the representation and personality of the legal representative, if applicable;
In case of requests for rectification of personal data, the documentation that supports the request and;
Any documentation that the applicant considers necessary to support his application.

2 The request may be submitted by any of the means established in our comprehensive privacy notice under which the personal data was obtained.

3 Once the request is received, the Department of Personal Data may prevent it, accept it or reject it.

3.1 Prevention: In the event that the submitted request does not comply with any of the requirements established in the previous paragraphs, or in the event that the information contained in the request is erroneous or insufficient to attend to it, our Department of Personal Data (hereinafter DDP ) will prevent the applicant, within 5 business days after the date of receipt of the request, to correct any errors, inaccuracies or omissions that it contains. If, within a period of 10 business days from the date on which the required prevention is notified, the applicant does not relieve or resolve the prevention required by our DDP, their request will be rejected, a situation of which our DDP will record.

3.2 Disposal: Disposal will proceed in the event that any of the grounds for this purpose established in the Federal Law on Protection of Personal Data Held by Private Parties, its regulations or related regulations, are updated.

3.3 Admission: Admission will proceed as long as the request complies with each and every one of the requirements demanded by the Federal Law on Protection of Personal Data Held by Private Parties, its regulations or related regulations and by point 1 and 1.1 of this document.

Four. Once the application is accepted, our DDP will notify the holder about the admission of the same, sending him an acknowledgment of receipt within 5 business days after the date of presentation of the respective application. Said acknowledgment will be sent to you by the same means by which you submitted your request. Then, our DDP will analyze the request and issue the resolution that is applicable in accordance with the law.

5. The resolution issued on the occasion of the ARCO rights application in question may grant or deny the applicant's claims. In both cases, the resolution must be fully and absolutely justified in accordance with the applicable and current law and in accordance with our privacy codes, policies and practices. The resolution issued must be notified to the applicant within a maximum time of 20 business days following the date on which our DDP received the request to exercise rights.

6. If the final resolution is favorable to the interests of the applicant, our DDP will make said resolution effective within 15 business days following the date on which the response is communicated to the applicant. If the final resolution is unfavorable to the interests of the applicant, it may be combated through our internal complaint procedure in accordance with the provisions of this document or, the owner may initiate the procedures for the protection of rights that he considers conducive to the INAI.

7. Our DDP will notify the applicant of the execution of the resolution, within the 15 business days referred to in the first paragraph of point 6 hereof. In the case of requests for access to personal data, the delivery of the same will be made after accreditation of the applicant's personality. In the notification of the resolution, the form and terms in which the resolution will be executed will be established.

8. Any notification that our DDP must make to the applicant will be made by email sent to the address that the applicant provides in his application. In the event that the applicant does not provide an email address in their application, the notification will be sent to any other email of the owner of the data on which the ARCO right in question is exercised, that our DDP has registered in our databases. In the event that we do not have an email address in our databases, our DDP may contact the applicant or the owner of the data on which ARCO rights are exercised by any other means available to them in our databases. of data, to expressly request the appointment of an email address. In the event that, having exhausted all the aforementioned reasonable efforts, it is not possible to identify or contact the applicant, the application will be rejected outright by our personal data protection department.

SECTION II. PROCEDURE TO REVOKE CONSENT.

9. The procedure to revoke consent may be initiated at the request of the interested party by means of a written request that must contain, at least, the following requirements:

Full name of the owner and his legal representative, if applicable;
Email for the purpose of communicating the response to the revocation of consent procedure and;
Express mention that it is the will of the owner to revoke their consent for the processing of their personal data.

9.1 To said request, a digitized color copy of the following must be added:

Official identification that proves the identity of the interested party and their legal representative (eg voting credential, passport, driver's license, professional card, citizen identity card, SMN card);
Document stating the representation and personality of the legal representative, if applicable and;
Any documentation that the applicant considers suitable to support or substantiate his request.

10. The request may be submitted by any of the means established in the comprehensive privacy notice under which the personal data was obtained.

eleven. Each and every one of the procedural rules applicable to the ARCO rights protection procedure established in Section shall be applicable to the procedure for the revocation of consent. I above in everything that does not oppose this section.

12. Our DDP may resolve the request for revocation of consent (i) granting the revocation of consent or (ii) denying the revocation of consent. In the event that our DDP denies the revocation of consent, it must fully justify the resolution.

13. Our DDP may deny the revocation of consent for any of the following reasons:

In the event that any Law, Treaty, rule, regulation, provision or any other of a similar or analogous nature prohibits the revocation of consent to the processing of personal data;
If the consent of the owner is not necessary to carry out the processing of the personal data in question in accordance with the Federal Law on Protection of Personal Data Held by Private Parties and its related regulation and;
In the event that there are pending compliance obligations at the time of filing the request for revocation of consent for the processing of the personal data of the interested party, unless our DDP provides otherwise.

14. If the resolution of the consent revocation procedure is favorable to the interests of the applicant, our DDP must stop processing said personal data immediately and will immediately proceed to cancel them, in accordance with the Federal Law on Protection of Personal Data in Possession of the Individuals.

fifteen. If the final resolution is unfavorable to the interests of the applicant, it may be combated through our internal complaint procedure in accordance with the provisions of this document, or may file any other remedy made available by the Federal Law on Protection of Personal Data in Possession of Individuals or its related provision.

SECTION III. COMPLAINT PROCEDURE.

16. The internal complaint procedure is a challenge that aims to confirm or revoke the resolutions of our DDP regarding the procedure to exercise ARCO rights, the procedure for the revocation of consent and / or the procedure to limit the use of personal data.

17. When an applicant considers that any resolution issued by the DDP causes them harm or that it is unfounded or contrary to law, they may initiate the internal complaint procedure by filing a letter sent by email to our DDP by any of the means established in the privacy notice to initiate the procedure for the exercise of ARCO rights. Said writing must contain:

Identification data of the procedure whose resolution is disputed;
Full name of the applicant or their legal representative, if applicable, and;
A clear and precise description where you base and list the reasons why you consider that the resolution issued by the DPDP is incorrect, illegal or causes harm.

18. The DDP will turn over the complaint, within 5 business days following the date of receipt, to the Company's Management Body, with a copy to its oversight body, if any.

19. Our Administrative Body will resolve the complaint made no later than 7 business days after the date it receives the complaint in accordance with the previous paragraph.

twenty. Each and every one of the shipments and receptions referred to in the 2 previous paragraphs will be recorded.

twenty-one. The resolution of the complaint may (i) confirm the resolution of the DDP or (ii) revoke the resolution of the DPDP. In the event of revocation of the resolution, the Administrative Body will indicate to the DDP the meaning that must be indicated in the resolution, so that it may be issued again.

22. Whatever the direction of the resolution of the complaint filed, the interested party will be notified by the DDP in accordance with the procedural rules established in point 8.

2. 3. Any holder may initiate this complaint procedure without prejudice to initiating, even simultaneously, a procedure for the protection of rights before the INAI, in terms of the Federal Law on Protection of Personal Data Held by Private Parties.

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