Privacy Policy

Protection of Personal Information – Data Privacy Policy

Express acceptance of this Policy in accordance with its terms shall occur when the owner of the information provides his or her personal data through any channel or means established by Huenei IT Services, when he or her acquires or uses any of its products and services, and/or when Huenei IT Services acquires services or products from said owner or enters into any type of contract with him or her.

If you do not want Huenei IT Services to collect your Personal Information and Data, please refrain from providing it. Also, remember that you may, at any time, request the withdrawal or blocking of the Information and Personal Data referred to in this Policy, in accordance with the provisions of Law 25,326 on the Protection of Personal Data and its regulatory decrees.

Keep in mind that the Personal Information and Data are recorded when, among other things, you communicate with our staff by any means, such as, for example, phone, email, face-to-face meetings for inquiries, information requests, quote requests, when using our website www.huenei.com, or when applying for an open position in Huenei IT Services.

 

Definitions

The terms contained in this Policy shall have the following meanings:

“Authorization”: Prior, express and informed consent of the Owner for the Processing of his or her Personal Data.

The Owner’s authorization will not be necessary in the following cases:

  1. Information required by a public or administrative agency in the exercise of its legal functions or by court order
  2. Public information.
  3. Medical or health emergencies.
  4. Data Processing authorized by law for historical, statistical or scientific purposes.

“Privacy Notice”​: Verbal or written communication created by the Responsible Party, addressed to the Owner for the Processing of his or her Personal Data, through which the Owner is informed about the existence of the applicable policies for data processing, the way to access them and the purposes of said intended use, as well as the way to access his or her rights.

“Database”: Organized set of personal data that is subject to Processing, in accordance with the applicable provisions from Dec. 1558/2001.

“Public Information”​: Any information that is not semi-private, private or sensitive. Public information includes, but is not limited to, information related to an individual’s marital status, his or her profession or trade and his or her status as a salesperson or public officer. Based on its nature, public information may be contained in public records, public documents, gazettes, official journals, and duly enforceable judicial decisions that are not subject to reservation, among others.

“Sensitive Information”​: Sensitive Information is any information that affects the privacy of its Owner or which if improperly used may result in discrimination, such as information revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social or human rights organizations that promote the interests of any political party or that guarantee the rights of opposing political parties, as well as information related to health, sexual life, and biometric data.

“Sub-processor”​: Natural or legal person, public or private, that independently or in association with others carries out the Processing of personal information on behalf of the Processor; person outside the organization. For this specific case, they are the individuals hired by HUENEI IT SERVICES acting on behalf of HUENEI IT SERVICES (i) in the management of administrative and/or accounting processes that involve the processing of personal information, or (ii) in the hired service provision or product sales.

“Personal Information and Data”​: Any information actually or potentially linked to one or more specific or identifiable natural persons.

“Processor”​: Natural or legal person, public or private, who independently or in association with others, decides on the use of databases and/or Data Processing. In this specific case, this shall be HUENEI IT SERVICES.

“Owner”: Natural person whose personal information is being processed.

“Transfer”​: The data transfer takes place when the Processor and/or Sub-processor, located in Argentina, sends the information or personal data to a receiver, who in turn is another Processor and who may be inside or outside the country .

“Transmission”​: Personal data processing that involves sharing information within or outside Argentine territory with the intention to handle data on behalf of the Processor.

“Processing”​: Any operation or set of operations on personal data, such as the collection, storage, use, circulation or disposal.

 

Consequences of Accepting the Policy – Purposes for Personal Information and Data Processing

By accepting this Policy, the Owner expressly authorizes HUENEI IT SERVICES to process his or her Personal Information and Data, partially or totally, including the collection, storage, recording, use, circulation, processing, disposal, transmission in the terms of this Policy and/or transfer of the data provided for the purposes described in the Data Processing Policies of any third parties to whom the Personal Information and Data are transferred.

By accepting this Policy, in your capacity as Owner of the Personal Information and Data collected, you authorize the processing of said information for all purposes set forth in this Policy and especially for:

  1. Using the Personal Information and Data provided to establish and maintain the commercial relationship; sending information regarding the legal, commercial, contractual or mandatory relationship; processing the collection of accounts receivable; processing the payment of accounts payable; and for any other purpose that results in the development of the relationship that arises.
  2. Using the Personal Information and Data provided to send commercial information or communications that Huenei IT Services considers may be of interest to the Owner.
  3. Use the Personal Information and Data provided to make it available to the personnel in charge of the corresponding work, within the company, without excluding the possibility of being transferred to managers, consultants, advisors, external individuals and offices as necessary.
  4. When appropriate based on the reason for sharing the information, Using the Personal Information and Data provided for the marketing of Huenei IT Services products and services, as well as products and services of third parties with whom Huenei IT Services maintains a business relationship.
  5. Use the Personal Information and Data provided to request surveys and post-sale follow-up in order to measure customer satisfaction with the goods or services provided by Huenei IT Services; this may be done for statistical and continuous improvement purposes, or for qualitative and quantitative evaluations of goods or services received by Huenei IT Services.
  6. Transferring data to third parties in the same sector or sectors related to Huenei IT Services, so that the owners can learn about and have access to alternative products and services.
  7. Using the Personal Information and Data provided to maintain the records indicated by law.
  8. Using the Personal Information and Data provided to issue certifications requested by the Owner.
  9. Using the Personal Information and Data provided to maintain accounting records.
  10. Sharing the Personal Information and Data with national and international control and surveillance, administrative, police and legal authorities, as demanded by a legal or regulatory requirement.
  11. Allowing access to Personal Information and Data to auditors or third parties hired to carry out internal or external audit processes of the commercial carried out by HUENEI IT SERVICES.
  12. Consulting and updating the Personal Information and Data.
  13. Hiring third parties for the storage and/or processing of Personal Information and Data for the correct execution of the contracts signed with HUENEI IT SERVICES under the security and confidentiality standards to which HUENEI IT SERVICES is bound

HUENEI IT SERVICES shall not sell or transfer the Owner’s Personal Information and Data to third parties for any price.

 

Protecting your Personal Information.

HUENEI IT SERVICES respects the privacy of all Owners. For the purpose of HUENEI IT SERVICES business, the Owners’ Personal Information and Data will be collected and used, taking the applicable security measures and allowing them access their information and exercise all their rights at all times.

The processing of Personal Information and Data by the Sub-processor and the Processor is covered under the guarantee and respect for the processing principles defined by law 25,326. Thus, we guarantee legality, adequate processing based on the purpose, freedom, truthfulness or quality, transparency, access and restricted circulation, security and confidentiality of your Personal Data.

To prevent unauthorized access, maintain the accuracy of the data and ensure the correct use of your Personal Information and Data, we have physical, electronic, administrative processes and security procedures designed to protect and secure all Personal Information and Data collected. HUENEI IT SERVICES has internal processes for handling databases in accordance with the legal obligations of security and confidentiality set forth by Law 25,326 on the Protection of Personal Data. The aforementioned allows to reduce the risks of malicious handling of the Personal Information and Data.

Every HUENEI IT SERVICES contract with employees and contractor suppliers, external consultants, temporary collaborators, etc., that involves the processing of Personal Information and Data of the Owners included in the Huenei IT Services databases, includes an agreement of confidentiality that details our commitment with the protection, care, security and preservation of the confidentiality, integrity and privacy of the information, even after the end of the contractual relationship with Huenei IT Services.

 

Owners’ Personal Information and Data held by Huenei IT Services

Whenever you share personal information, and in accordance with current legislation, you declare that the Personal Information and Data provided are true.

Huenei IT Services assumes the veracity of the information provided and does not verify, nor does it assume the obligation to verify the identity of the Owners or the veracity, validity, sufficiency and authenticity of the data provided by them. Therefore, we shall not be held responsible any harm and/or damages of any nature that could arise from the lack of veracity, validity, sufficiency or authenticity of the Personal Information and Data provided, including damages due to homonymy or impersonation of identity. The Personal Information and Data collected and processed by Huenei IT shall be the following:

  • Tradenames.
  • Fiscal and tax identification information.
  • Bank information for payments via transfer.
  • Contacts.
  • Copy of supporting documents for tax and banking information.
  • First and last name.
  • Type and identification number.
  • Date of birth.
  • Gender.
  • Blood type.
  • Nationality and country of residence.
  • Landlines and contact cell phones (personal and/or work).
  • Postal and electronic addresses (personal and/or work).
  • Credit and debit card information (number, bank entity, expiration date).
  • Biometric data, including images, photographs, videos, voices and/or sounds, fingerprints.
  • Profession or occupation.
  • Company where the Owner works and position.
  • Salary.
  • Role.
  • Health insurance, affiliation data and/or prepaid medicine.
  • All data that can legally be collected through A.F.I.P.
  • All data that can legally be collected through A.N.S.E.S.
  • Information on Pre and Post-occupational exams
  • Academic profile.
  • Professional profile.
  • Marital status and/or kinship in relation to other people, among whom may be minors or disabled individuals.
  • Address information.
  • Companies of which the Owner is a shareholder or in which he or she has some type of participation or link.
  • Any other Personal Information or Data to which HUENEI IT SERVICES has access in the course of its legal, commercial, contractual or mandatory relationship with the Owner.

Owners shall not be obligated to authorize the processing of sensitive data under any circumstance. Notwithstanding the foregoing, when the Owners are required to provide any sensitive personal data to receive a service, they shall expressly consent to the processing of the sensitive Personal Information and Data in accordance with this Policy.

 

Protection of personal data in video surveillance systems in accordance with the provisions of Disp. 10/2015 (conf. Law 25.326)

HUENEI IT SERVICES shall notify the Owners of personal data who appear in a video surveillance area and shall obtain their authorization for the Processing of said information. For this, distinctive signs or notices can be used in the video surveillance areas, mainly in the entrance areas and inside places being monitored.

The Owners shall also be notified when audio is recorded. The signs or notices implemented shall at least comply with the content of a privacy notice, which shall: include information about the Processor and their contact information, ii) Indicate how data will be processed and the purpose thereof, iii) Include the rights of the Owners, iv) Indicate where the Data Processing Policy is published.

Additionally, the notice shall be visible and legible taking into account the area where the Surveillance System operates.

 

Access to images by the owners of personal data

The Owners of the data are empowered to exercise their right of access to the images processed by SV. As such, when an Owner exercises this right, HUENEI IT SERVICES shall adopt the procedures and measures necessary to protect the rights of the other Owners whose personal data have been processed together with those of the person requesting access.

Some of the measures that can be adopted are: i) Establishing a procedure to access images, which allows Huenei IT Services to verify whether the person requesting access to the information is in fact its Owner. ii) Requiring the requesting Owner information such as date, time, and place, among others, to help locate the image and limit the exposure of third-party images as much as possible. iii) If third party Owner(s) of personal data appear in the image, he or she shall provide separate authorization for sharing the tape or recording. Iv) If no authorization is obtained from the third parties to share the information contained in the required tape or recording, Huenei IT Services shall guarantee the anonymization of the data pertaining to the third party, taking the corresponding action, such as blurring or fragmenting the image of said third party.

 

Validity Period for Personal Information and Data Processing

The information provided by the Owners may remain stored for a period of ten (10) years from the date of the last Processing, so that Huenei IT Services

May comply with all applicable legal and/or contractual obligations, especially in commercial, accounting and tax matters or any event provided by law.

 

Information pertaining to underage children and adolescents

Huenei IT Services shall ensure the proper use of the personal data pertaining to underage children and adolescents, guaranteeing that all applicable laws are respected in the processing of their data, as well as caring for their best interests and fundamental rights and, where possible, taking into account their opinion as Owners.

 

General Procedure for the Exercise of Personal Information and Data Owners’ Rights

The procedures for the exercise of the Owners’ rights shall be provided for under Law 25,326 and its regulatory decrees. In compliance with law 25,326, HUENEI IT SERVICES requests your authorization to continue with the processing of your personal information and data, in accordance with this Policy.

Owners have the right to consult and know exactly how their Personal Information and Data are being processed, as well as to rectify them if they are inaccurate or incomplete and to cancel them when they are not being used in accordance with legal or contractual purposes and terms or according to the purposes and terms contemplated in this Policy.

By accepting this Policy, the Owner freely and expressly certifies that he or she has been previously informed about the rights granted by the applicable laws as Owners of their Personal Information and Data, which are set forth below:

  1. Know, update and rectify your Personal Information and Data before the Processor or Sub-processor. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or data for which Processing is expressly prohibited or has not been authorized.
  2. Request proof of the authorization granted to the Processor, except when expressly waived as a requirement for Processing.
  3. Be informed by the Processor or Sub-processor about the use of your Personal Information and Data upon request.
  4. Submit complaints about violations of the personal data protection regime to the National Directorate for the Protection of Personal Data dependent on the Agency for Access to Public Information.
  5. Revoke the authorization and/or request the deletion of data when the principles, rights and constitutional and legal guarantees are not respected during the Processing. The revocation and/or deletion will be effecting when the National Directorate for the Protection of Personal Data has resolved by firm provision that the Processor or Sub-processor incurred in conduct contrary to current regulations when processing data.
  6. Access his or her processed Personal Information and Data upon request to ​HUENEI IT SERVICES under the terms of the applicable regulations. For inquiries where frequency is greater than once every calendar month, HUENEI IT SERVICES will charge the Owner requesting said information for the costs of shipping, reproduction and, where appropriate, document certification.

 

Exercise of the Owner’s Rights

Query The Owners, the authorized persons or successors in title (when the Law so authorizes), may query their Personal Information and Data present in the databases of HUENEI IT SERVICES, In which case HUENEI IT SERVICES shall provide the requested information, upon verification of the legitimacy to comply with the request. The query will be answered within a maximum of ten (10) business days from the date of receipt. When it is not possible to respond to the query within this term, HUENEI IT SERVICES shall inform the reasons for the delay, indicating the date on which the query will be complied with, which in no case may exceed five (5) business days following the expiration of the first term.

Claims: If the Owners, the authorized people or the successors consider that the personal information and data contained in Huenei IT Services databases should be subject to correction, updating or deletion, or when they notice an alleged breach of any of the duties contained in the regulations, they may file a claim with Huenei IT Services, which will be processed under the following rules.

  1. The claim shall be made through a request addressed to Huenei IT Services with your identification, a description of the facts that gave rise to the claim, your address, and the accompanying documents you wish to validate. If the claim is incomplete, Huenei IT Services will request amendment of the faults it within five (5) days of receipt of the claim. If the requested information is not provided after two (2) months from the date of request, Huenei IT Services will assume that the claim has been withdrawn.
  2. If Huenei IT Services is not competent to resolve the claim, it will be transferred to the corresponding person within a maximum period of two (2) business days and the person involved will be notified in a timely manner.
  3. The maximum term to respond to the claim will be fifteen (15) business days from the day following the date of duly supported receipt. If the claim cannot be resolved within said term, you will be informed of the reasons for the delay and the date on which your claim will be responded, which in no case may exceed eight (8) business days following the expiration of the first term.

To make their rights effective, the Owners may exercise their rights to know, update, rectify and delete their personal information and data by sending their request to: compliance@huenei.com .

The Owner shall include the following information in the request:

  1. First names
  2. Last names
  3. ID number
  4. Email address
  5. Subject
  6. ID type
  7. Phone number
  8. Country
  9. City
  10. Reason for the contact

The request to delete Personal Information and Data and the revocation of the authorization or the request for limitation of use and disclosure shall not proceed if the Owner has a legal or contractual duty to remain in the database, under the terms set forth by the applicable laws.

 

IMPORTANT: Modifications to the Privacy Policy

Huenei IT Services retains the right to make modifications or updates to this Policy at any time, in order to adjust to new legislation, internal policies or new requirements for the provision or offering of products or services.

These modifications will be available to the public through visible advertisements on the company website or through the last email address provided.

Subject to applicable laws, the Spanish version of this Policy shall prevail for the Argentine Republic over any version published in another language. If there is any inconsistency between the Spanish version and any translation of this Policy in another language, the Spanish version shall prevail.

 

Validity

This Policy is effective from the day of its publication. The last published revision is from December 1st, 2020.