Policy Politics

With the aim of complying with the highest standards of data protection, the following outlines the relevant aspects related to the processing of personal data carried out by Santa Giulia S.A. (hereinafter, “Santa Giulia” or the “Data Controller”), under the authorization granted by you, as well as the way in which such data is managed.

This personal data processing policy (the “Policy”) establishes the corporate and legal guidelines under which Santa Giulia processes your data, the purposes of such processing, the rights of data subjects, and the procedures to exercise those rights.

In accordance with applicable regulations in the Republic of Argentina (Law No. 25.326 and supplementary rules), Santa Giulia maintains a clear privacy policy: we do not collect personal information from third parties —including clients, suppliers, employees, or users— without them voluntarily providing it through prior, express, and informed consent.

1. DEFINITIONS

For the purposes of this Policy, the following definitions apply:

“Personal data”: Any information linked or that can be associated with a specific or identifiable natural person.

“Sensitive data”: Data that affects the data subject’s privacy or whose misuse may lead to discrimination.

“Data Processor”: A natural or legal person who processes personal data on behalf of the Data Controller.

“Data Controller”: A legal entity that decides on the database and/or the processing of such data. In this case, Santa Giulia.

“Data Subject”: A natural person whose personal data is subject to processing.

“Transfer”: The sending of personal data by Santa Giulia to a third party (public or private), either within or outside the national territory.

“Transmission”: The communication of personal data from the Controller to the Processor so that the latter, on behalf of the Controller, processes them.

“Processing”: Any operation on personal data, such as collection, storage, use, circulation, or deletion.

2. PURPOSE OF DATA PROCESSING

Santa Giulia recognizes the right of every data subject to maintain a reasonable expectation of privacy, always considering their rights, responsibilities, and obligations.

In the context of the relationship established between the Data Subject and Santa Giulia, personal data will be collected, stored, used, transmitted, transferred, deleted, and, in general, processed in accordance with the purposes described below:

4.1. General Purposes

Inform about substantial changes to this Policy.
Respond to requests, inquiries, complaints, and/or claims submitted through the Website or other contact channels enabled by Santa Giulia.
Comply with legal, regulatory, or contractual obligations applicable to Santa Giulia.
Ensure Website security and prevent fraud.

4.2. Suppliers and Contractors

Properly manage the contractual relationship.
Fulfill billing, payment, and audit obligations.
Analyze financial, technical, and compliance-related aspects.
Prevent fraud and comply with legal and regulatory obligations.

3. DATA COLLECTED

Through the Website, Santa Giulia may collect certain personal data that enables the identification of the user.

Among others, and without limitation:

Contact information (name, surname, phone number, email address).
Identification data (ID, tax ID).
Information provided by the User through forms, contact channels, inquiries, or comments.
Technical information related to Website browsing (such as IP address, browser type, device used, cookies, or similar technologies).

The User is responsible for the truthfulness, accuracy, completeness, validity, and authenticity of the information provided and undertakes to keep it duly updated.

4. DATA SUBJECT RIGHTS

The Data Subject may exercise at any time the rights recognized by Law No. 25.326:

Access their personal data.
Request correction, update, or deletion of such data.
Withdraw the consent granted for processing.
Object to processing in justified cases.
Be informed about the use of their data.

To exercise these rights, a request must be sent to info@santagiulia.com.ar, duly proving identity and providing a clear description of the data or requested action, along with a contact method to receive notifications.

Santa Giulia will respond within 10 business days for access requests, and within 5 business days for requests for correction, update, or deletion, in accordance with current regulations.

The Agency for Access to Public Information, the controlling authority of Law No. 25.326, is authorized to handle complaints related to non-compliance with personal data protection regulations.

5. INFORMATION WE SHARE

Personal data collected may be shared with third parties only in the following cases:

With service providers acting on behalf of Santa Giulia and under our instructions (e.g., hosting services, cloud storage, technical support).
With administrative or judicial authorities, when required by applicable regulations or a court order.
In the event of reorganization, merger, spin-off, dissolution, or any other form of corporate restructuring, the data may be transferred to the successor or acquiring entities, always in compliance with applicable regulations.

Santa Giulia requires all third parties to ensure the confidentiality and security of the data they access.

6. PERSONAL DATA SECURITY

The data collected will be kept in strict confidentiality. Santa Giulia applies administrative, technical, and physical security measures designed to protect the personal data provided to us against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

However, the User acknowledges that no data transmission or storage system is completely invulnerable.

7. DATA RETENTION PERIOD

Personal data will be processed only for the time reasonably necessary to fulfill the purposes for which they were collected, and in accordance with applicable legal timeframes.

8. LINKS TO OTHER WEBSITES

The Website may contain links to third-party websites. Santa Giulia assumes no responsibility for the content, privacy practices, or operation of such sites. Users are encouraged to review the privacy policies of each website they access.

9. MODIFICATIONS

Santa Giulia may modify or update this Policy at any time to reflect changes in its personal data processing practices or in applicable regulations.

The current version will be published on the Website, indicating the date of the last update.

10. CONTACT

If you wish to update your data, exercise your rights, or if you have any questions regarding the scope of this Policy and/or the privacy of the information provided to Santa Giulia, you may contact us directly via email at: info@santagiulia.com.ar

Last updated: 08/28/2025