The Management of BRB Finanz A.G. (hereinafter, the data controller), assumes the maximum responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller with the aim of achieving excellence in relation to compliance with Law 81 of 2019 on the Protection of Personal Data of Panama, Executive Decree 285 that regulates it and other regulations applicable locally and internationally.
 
The Data Protection Policy of BRB Finanz A.G., is based on the principle of proactive responsibility, which means that the data controller is responsible for compliance with the regulatory framework and is able to demonstrate such compliance before the competent control authorities.
 
In this sense, the data controller will be governed by the following principles that should serve all its staff as a guide and reference framework in the processing of personal data:

1. Data protection from the design: The data controller will apply, both at the time of determining the means of treatment and at the time of the treatment itself, appropriate technical and organizational measures, such as pseudonymization, designed to effectively apply the principles of data protection, such as data minimization, and integrate the necessary guarantees in the treatment.

2. Data protection by default: The data controller will apply the appropriate technical and organizational measures to ensure that, by default, only the personal data that are necessary for each of the specific purposes of the treatment are processed.

3. Data protection in the information life cycle: Measures that guarantee the protection of personal data will be applicable during the entire information life cycle.

4. Lawfulness, loyalty and transparency: Personal data will be treated in a lawful, loyal and transparent manner in relation to the interested party.

5. Limitation of the purpose: Personal data will be collected for specific, explicit and legitimate purposes, and will not be subsequently processed in a manner incompatible with such purposes.

6. Data minimization: Personal data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

7. Accuracy: Personal data will be accurate and, if necessary, updated; all reasonable measures will be taken to delete or rectify personal data that is inaccurate with respect to the purposes for which it is processed without delay.

8. Limitation of the retention period: Personal data will be kept in such a way that the identification of the interested parties is allowed for no longer than necessary for the purposes of the processing of personal data.

9. Integrity and confidentiality: Personal data will be processed in such a way that adequate security of personal data is guaranteed, including protection against unauthorized or illicit processing and against accidental loss, destruction or damage, through the application of appropriate technical or organizational measures.

10. Information and training: One of the keys to guaranteeing the protection of personal data is the training and information provided to the personnel involved in their processing. During the information life cycle, all personnel with access to the data will be properly trained and informed about their obligations in relation to compliance with data protection regulations.

 
The Data Protection Policy of BRB FINANZ A.G., is communicated to all the staff of the data controller and made available to all interested parties.
 
Consequently, this Data Protection Policy involves all the staff of the data controller, who must know it and assume it, considering it as their own. Each member is responsible for applying it and verifying the data protection rules applicable to its activity, as well as identifying and proposing the opportunities for improvement it deems appropriate with the aim of achieving excellence in its compliance.
 
This Policy will be reviewed by the Management of BRB FINANZ A.G., as many times as deemed necessary, to adapt, at all times, to the current provisions on the protection of personal data.