Basic Concepts

Pursuant to our Values and our Code of Conduct, at Bruchou, Fernández Madero & Lombardi (hereinafter, “Bruchou”), we have pledged to respect the privacy of any person who visits or signs in to www.bruchou.com or any other extranet managed by Bruchou in connection with the provision of our services (hereinafter the “Site”). Furthermore, we undertake to ensure a safe online experience, under the provisions of Law No. 25, 326 on Personal Data Protection and other related regulations in effect in Argentina.

We remind our visitors from the European Union that Argentina is an adequate and safe country in terms of personal data protection, according to 2003/490/EC Decision from the European Commission. This means that there is free data flow between both territories and that Argentine regulations provide a protection level equivalent to that of the European Union.

The Site is not intended for individuals under the age of 18. If you are under 18 years of age, you should not use the Site or provide us with your personal data, except with the express authorization and consent of your parents and/or legal guardians.

BY ACCESSING, LOGING IN TO OR USING THE SITE IN ANY OTHER WAY, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD AND ACCEPTED THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IN CASE YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITE OR OUR COMMUNICATION CHANNELS.

Contents

This Privacy Policy (hereinafter, “Policy”) describes:

• Who we are and what we do.
• How to contact us.
• Which personal data we gather.
• How we process personal data and for what purpose.
• The legal bases that allow us to process your data.
• Under which circumstances we share your personal data.
• How long we keep your personal data.
• The measures we take in order to guarantee the security and confidentiality of your data.
• Countries to which we may transfer your personal data.
• Rights over your personal data.
• The possibility of filing complaints.
• Policy updates.

Who we are and what we do

Bruchou is a limited liability company that operates under the corporate name BFMYL S.R.L., with domicile at Ing. Butty 275, Piso 11, Ciudad de Buenos Aires, Argentina, and is the responsible party for your personal data processing.

How to contact us

Should you have any inquire about this Policy or wish to exercise any of your personal data-related rights, you may get in touch with us by sending an e-mail to estudio@bruchou.com

Which personal data we gather

The personal data we gather depend on the relationship you have with us (applicant for current job searches, user of the website, subscriber to the newsletter, etc.). Among the personal data we process, we can list the following:

• Contact details, such as name, position, postal addresses, e-mail addresses and telephone numbers.
• Technical information, such as information gathered from your visits to our website or related to invitations to events, updates, marketing material and other communications sent by e-mail.
• Your communication preferences regarding marketing material.
• Any other personal information you provide us during your relationship with us.

How we gather and process personal data and for what purpose

We gather and manage personal data in the context of the following activities and processes:

• During the provision of our legal services or otherwise.
• Through the use of our website and the forms to fill in personal data requested therein.
• Through your responses to our e-mails requesting that you confirm or update information we maintain about you, or that you give your consent for us to get in touch with you.
• Through the information you provide to our firm’s representatives in conferences and similar events.
• Through your job application to Bruchou.

We may use your personal data for the following purposes:

• To manage, control and improve our provision of legal and other services to clients.
• To provide information requested by you.
• To provide, manage and monitor the use of our website and to improve our website.
• To promote our services, including sending customized events invitations, updates, and other marketing material.
• To follow up your job application.

In accordance with Law No. 25,326 and supplementary regulations, we inform you that the gathered data belong to a database of Bruchou, with domicile at Ing. Enrique Butty 275, Piso 11, CABA, duly registered with the Agencia de Acceso a la Información Pública (AAIP, for its acronym in Spanish) (Agency for Access to Public Information).

LEGAL BASES

We process your personal data pursuant to the following legal bases, under Law No.  25,326 and supplementary regulations:

• Free, explicit, and informed consent from data subjects.
• Compliance with any agreement with data subjects.
• Compliance with our legal obligations.
• Legitimate interests according to law.

With whom and under which circumstances we share your personal data

We shall never sell your personal data or disclose them to third parties without your consent, except as provided in this Policy.

We may share your personal data with the following third parties under the circumstances listed below, always in accordance with the provisions of Section 11 of Law No. 25,326:

• With related entities, in order to provide clients with legal services or otherwise and pursuant to our administrative and business practices.
• With our services providers, including our professional advisors, such as our auditors, our suppliers of information technology services, third parties who provide us with support services such as translation, photocopying and review of documents, and third parties who receive instructions from us regarding our services provision to clients.
• With governmental or regulatory authorities, courts or other public entities or offices, should we deem it appropriate or mandatory under applicable law or regulation.
• Any new entity of Bruchou or other third party, under the provisions above, should we decide to reorganize or transfer our business in full or in part.

How long we keep personal data

We keep the data for as long as it is necessary to fulfil the purposes for which they were collected, as provided by Section 4 of Law No. 25,326. Certain categories of personal data may be kept after the main purpose of the processing has been fulfilled:

• For a legal term under any applicable regulation.
• For the period before the time limit for bringing civil, administrative, or criminal claims expires, with the purpose of ensuring Bruchou’s right of defence.

Which measures we take in order to ensure the security and confidentiality of your data

We take all necessary technical and organizational measures to protect your personal data from unauthorized, improper, or illegal access, use, disclosure, modification, or destruction, in compliance with Law No. 25,326 and Resolution by AAIP No. 47/2018 on Recommended Security Measures.

In that sense, we inform you that Cyber Essentials certification, issued by United Kingdom’s National Cyber Security Centre, is being processed. For further information, please click on this link: https://www.ncsc.gov.uk/cyberessentials/overview

Countries to which we may transfer your personal data

The data gathered may be disclosed or transferred to third parties, for the purposes and in the manner described herein, and pursuant to the services we provide to you.

Your personal data may be transferred to countries or jurisdictions with regulations that may not provide the same level of protection to personal data as they do in Argentina and, therefore, your personal data may be less protected, fact that you understand and consent to when you log in to our website or provide us with your information.  When we transfer your personal data to other countries, we shall protect them in the manner described herein, by implementing safeguards intended to ensure an adequate protection level of the data transferred outside Argentina.

Rights over your personal data

According to Sections 14, 15 and 16 of Law No. 25,326, you have the following rights regarding your personal data:

• To request access to your data. This enables you to receive a copy of the personal data related to you and verify that we are processing them according to law.
• To rectify incomplete or incorrect data about you.
• To request us to delete or remove your data from our systems when there are no legal grounds for us to continue to process them.
• To request us to stop processing your personal data, for example, if you want us to establish their accuracy or the reason for processing them.
• To withdraw any consent that you have provided to us for the processing of your personal data.
• To file a claim with the AAIP, national authority of personal data protection, in the event that our response to your request is not satisfactory.

It is possible that, in certain cases, we reject your requests if we need to preserve your data to provide a service, protect the security and functionality of our operations, fulfil a legal or regulatory obligation or for other legitimate interests.

If you wish to exercise any of the rights related to your personal information, you may contact us by sending an e-mail to estudio@bruchou.com.

Complaints

In compliance with Resolution by AAIP No. 14/2018, we inform you that the Agency for Access to Public Information, as Enforcement Authority of Law No. 25,326, is empowered to handle complaints and claims filed by those whose rights are affected by non-compliance with current regulations in personal data protection matters.

UPDATES OF THIS POLICY

This Policy is subject to amendments and updates. Please, review this Policy on a regular basis to make sure you are aware of its contents. Last update: December 29^th, 2021.