Our terms and conditions

Privacy Policy.

1. About this Privacy Policy.

Your privacy is important to us. This Privacy Policy outlines the basis on which we, NetForemost, and our affiliates (collectively “NetForemost,” “us,” or “we”) protect your privacy.

This Privacy Policy explains how we collect, use, process, share, disclose, and store your Personal Information gathered through interactions with us, including through our website, www.netforemost.com (the “Site”), our sales process, marketing activities, and other means as further detailed in Section 3.

The purpose of this Privacy Policy is to ensure that you understand the types of Personal Information we collect from you, the purposes for which we collect it, how we use it, and how we share it. In short, we aim to clarify how we protect your privacy and to explain your rights concerning the Personal Information we collect and process about you.

The Personal Information collected by us will be processed in accordance with (i) the practices described herein and (ii) any applicable data protection laws relevant to the geographical area where you are located, provided these laws also apply to us.

To learn more about your privacy rights and our compliance with specific laws applicable to your geographical area, please refer to the Appendixes. In the event of any conflict or inconsistency between the general terms of this Privacy Policy and any applicable Appendix, the terms of the Appendix shall take precedence.

For further clarifications on this Privacy Policy, questions, or concerns, please do not hesitate to contact us (see Section 18).

2. About us.

NetForemost is a Limited Liability Company headquartered in Panamá.

For the purpose of this Privacy Policy, we are the data controller of your Personal Information as described in this document, unless expressly specified otherwise.

3. Personal Information we collect about you.

3.1. Personal Information we collect.

As used in this Privacy Policy, “Personal Information” refers to any data relating to an identified or identifiable individual, including but not limited to: first and last name, company name, email address, phone number, and date of birth, among other details.

We collect Personal Information from you through interactions and services provided by us. Some of this data is provided directly by you, while other data is gathered from your interactions, usage, and experiences with our products. The Personal Information collected depends on the nature of your interactions with us and your choices.

We collect your Personal Information when you:

Register, complete, or submit information or forms on our Site
Download content from our Site
Register for webcasts, seminars, conferences, and other events we sponsor or co-sponsor with partners
Provide feedback and information via phone, email, social media, etc.
Respond to a survey
Subscribe to our newsletters or other content-related materials
Use our live chat to communicate with us. Our live chat is operated by a third-party provider, who has access to such information and uses it in compliance with this Privacy Policy to provide customer service and improve the service. Telephone calls or chat conversations may be monitored or recorded for quality assurance
Use forums or leave comments on our Site
Purchase or use our products and/or services
Interact with us during in-person meetings, events, conferences, workshops, or gatherings

Additionally, online information about you may be collected through cookies and similar technologies (such as pixel tags and device identifiers) on our Site or on third-party sites. For more details on cookies and similar technologies, please refer to Section 6 below.

Please note that we do not control content that you may post on our forums or social media. In some cases, this content may be publicly accessible on the internet. Carefully consider whether you wish to submit Personal Information on these forums or networks, as well as whether you want your profile to be available to other users.

3.2. Types of Personal Information and Specific Details We Collect From You

We have collected within the last twelve (12) months and may continue to collect in the future the following categories of Personal Information from consumers, for commercial and/or business purposes:

Identifiers and Contact Information: such as name, email address, postal address, phone number, account name, online identifier, Internet Protocol (IP) address, or other similar identifiers
Customer Records Information: including name, signature, social security number, physical characteristics or description, address, telephone number, passport number, bank account number, credit or debit card number, or other financial information
Protected Classification Characteristics: as defined by Panamanian or federal law, including age, gender, etc.
Commercial Information: such as delivery details and records of personal property, products or services purchased, obtained, or considered, as well as other purchasing or consuming histories, tendencies, and transactions with us
Internet or Other Electronic Network Activity: including device information and identifiers, browser type and language, browsing history, search history, data on your interactions with our website, applications, or advertisements, as well as data connection and usage details such as information you download
Geolocation Data: such as city, province, and postal code related to your IP address
Inferences: drawn about your preferences and characteristics
Other Information: any additional information you choose to provide directly through service use, survey responses, inquiries submitted via online forms, chats, email, phone, or post, as well as customer service summaries or voice recordings of interactions

3.3. Personal Information we collect automatically.

Our Site automatically collects certain information through automatic data collection tools such as cookies and beacons, among others. These tools automatically gather the following information:

Technical Information: including, but not limited to, browser type, operating system, device information, online identifiers (including cookie data and Internet Protocol address (IP)), domain name, referral URL, time zone settings, and/or time-stamp for your visit, along with information about your devices.
Usage Information: including, but not limited to, geographic location data (such as your country and/or province), the date and time you visited our Site, the number and frequency of visitors to our Site, page views, search queries, and clickstream behaviors. It may also include details about your use of third-party applications in connection with our service.

3.4. Personal Information we collect from third parties.

We work closely with various third parties and may receive Personal Information from them. We protect the Personal Information obtained from these sources in accordance with the practices and policies described herein, along with any additional obligations imposed by the third-party source of your Personal Information. The third-party sources may vary depending on the context but may include the following:

Data Brokers: from which we purchase data to complement the Personal Information we collect.
Partners:
- (i) Authentication Partners: if you register or log in to our services using third-party credentials (e.g., Facebook), we will import your Personal Information from such a source to help you create an account on our Site.
- (ii) Technical Services Partners: that assist us with our technology and may provide us with certain Personal Information (e.g., mapping IP addresses to location data) to help us deliver our services.
- (iii) Advertising Partners: that provide us with services on our Site (analytics, marketing, etc.) and may provide us with insights about your preferences and interests to enhance our service and customize offerings.
- (iv) Payment Partners: if you choose to pay for a service and/or product, we may receive data from them to enable us to send you invoices and process your payment.
- (v) Resellers and Distributors: that deliver the product and/or service you have contracted and may supply us with data to help improve our services, among others.
- Social Media Sites.

During the past twelve (12) months, we have disclosed the categories of Personal Information about you listed above to our affiliates, group companies, and service providers for business and commercial purposes. However, we have not sold your Personal Information to third parties.

4. How do we use your Personal Information.

We use your Personal Information for the following purposes:

We use your Personal Information to fulfill certain business/commercial purposes (collectively the “Purposes”). These purposes include:

To fulfill the purpose for which the Personal Information is provided.
To provide you with information, products, and/or services that you request from us.
To communicate and respond to your requests and inquiries to us.
To operate our business and provide you with our products and services: engage in transactions with clients, and process orders from our services.
To follow up with our products and/or services after delivering them (live chat, email, or phone inquiries).
To provide consumers with e-mail alerts, product announcements, software updates, upcoming events, event registrations, and other notices concerning our products and/or services, or events or news that might be of interest to the consumer.
To customize the content and advertising you see on our Site, personalizing your experience and allowing us to deliver the type of content and product offerings you are most interested in and to send periodic emails regarding our products and/or services.
To administer and improve the functionality of our Site and its technical and functional management and present its content to our clients or others.
To analyze, develop and improve the use and performance of our Site.
To modify, enhance, or improve our services and/or provision of such services to our clients and/or for quality assurance.
As necessary and appropriate to protect our rights or property, or those of our clients or others.
To carry our obligations and enforce our rights arising from any agreement entered by and between us and our clients or other contractual third party, including billing and collections.
For testing, research, analysis, and product and services development.
To manage the security of our Site.
To comply with applicable laws and regulations to operate our business.
To respond to law enforcement requests as required by applicable law, court order, or governmental regulations.
As described to the consumer when collecting their Personal Information.
To market our products and/or services and/or related products and services, and to tailor our marketing and sales activities to our clients’ interests.

We do not collect additional categories of Personal Information, nor process the collected Personal Information for a different purpose than the ones described in this Privacy Policy and Appendixes.

The Personal Information we collect allows us to keep you posted on our latest product announcements, software updates, and upcoming events. Also, to customize the content and advertising you see on our Site, personalizing your experience and allowing us to deliver the type of content and product offerings you are most interested in and to send periodic emails regarding our products and/or services. If you don’t want to be on our mailing list, you can opt out anytime by contacting us at the following email address: martin.castellon@netforemost.com.

5. Legal basis we follow to process your Personal Information.

We rely on the following legal bases to collect and process your Personal Information under applicable data protection laws:

Consent: where you have provided your consent for the processing of your Personal Information for a specific purpose.
Performance of a contract: where processing is necessary for the performance of a contract with you or taking steps prior to entering a contract with you.
Legal obligation: where we have a legal obligation to process your Personal Information, for example, when responding to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law.
Legitimate interest: to satisfy a legitimate interest, for example, when it is not required by law but it clearly benefits you.

6. Cookies and other technologies.

To enable our systems to recognize your browser or device and to provide and improve our products and services, we use cookies and other technologies.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow it) that enable the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we may use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

6.1 Categories of Cookies.

We classify cookies in the following categories:

Strictly Necessary Cookies	These cookies are fundamentally necessary for our Site to work and allow you to use the functions of our services. Without this type of cookies, you couldn’t receive the requested services. These cookies enable services that you have specifically requested and allow you to use our services (e.g., logging in). We need these cookies to provide you with our services.
Performance Cookies	These cookies collect information about the use that visitors make of our services, such as the frequency of the visits and traffic, allowing us to improve the performance of our Site. These cookies collect anonymous information about the visits to our Site. This information is used exclusively to improve the performance of our services.
Functional Cookies	These cookies allow our Site to remember certain types of information, such as your username, language, etc. They provide functionality and personalization. This information is also anonymous. These cookies remember the options you have selected to improve your experience. They allow us to adapt our services based on the provided information.
Targeting Cookies	These cookies may be set through our Site to offer you relevant advertisements on other sites, based on your interests. These cookies collect information on your browsing habits with the purpose of adapting advertisements to your activities. In general, this information is shared with other advertisers and third parties, who may combine it with other information that you have provided to them or that they have collected from your use of their services. We may also use this information to record the number of times you have seen a particular ad and avoid showing you the same ads repeatedly.

We use cookies to:

Understand and save your preferences for future visits.
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
Personalize content and ads.

6.2 Web Beacons.

We may use web beacons (which are very small graphic images or objects embedded in our Site or e-mail) to collect information about your online actions, visits to our Site, and other activity. The information we obtain in this manner enables us to customize the services we offer to users of our Site, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming, or other activities.

6.3 How to manage Cookies.

In your browser: Please be aware that you may modify or withdraw your consent for the use of cookies at any time. If you do not want to allow cookies anymore, you may use your web browser either to accept them or reject them. For such purposes, follow the instructions on your web browser. Please bear in mind that if you set your browser to reject cookies, you may not be able to use all our functions on the web.

In your device: In your mobile device, your operating system (OS) offers options for avoiding personalized advertising -both in iOS and Android- to limit the use of information with the use of apps to generate advertisements based on your interests and tastes. Please be aware that advertisers and our partners may also use their own cookies and beacons, and we do not hold control of the information they collect. You will need to refer to their Privacy Policies. These third parties may use the information collected to serve more relevant advertisements. To configure your cookie controls and reject advertising cookies, follow the instructions on your device.

7. Your rights as a Data Subject.

Under applicable laws, you are granted certain rights in relation to your Personal Information. Accordingly, we offer you security, transparency, control, and access to your Personal Information as available, and with the exceptions set forth in applicable laws. We recognize the following rights (which you can exercise in accordance with Section 8):

Right to know what information is being collected. Right to access personal information. You have the right to request us to disclose:
- The categories of Personal Information we have collected about you.
- The categories of sources from which the Personal Information was collected.
- The business or commercial purpose for which the Personal Information was collected, sold, or shared.
- The categories of third parties to whom we disclose Personal Information.
- The specific pieces of your Personal Information we have collected.
To make a verifiable consumer request for information about the Personal Information we have collected about you, please use our Contact Form or email us at martin.castellon@netforemost.com.
Right to delete your personal information. You have the right to request us to delete any Personal Information that we have collected from you, subject to certain exceptions according to applicable law.
Right to no retaliation following opt-out or exercise of other rights. You have the right not to be discriminated against by us as a result of your exercise of any of your rights under applicable law. If you exercise any of your rights hereunder, we won’t deny you our goods or services, charge you a different price or rate for our goods or services, provide you a different level or quality of goods or services, or take any other retaliatory action against you.
Right to opt-out of the sale or sharing of your personal information. You have the right to opt-out of the sale or sharing of your Personal Information in accordance with Section 14.
Right to correct inaccurate personal information. You have the right to request us to correct any inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes for which such Personal Information was collected, processed, or used.
Right to know what information is sold or shared and to whom. You have the right to request us to disclose:
- The categories of Personal Information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared.
- The categories of Personal Information that we have disclosed about you for a business purpose and the categories of persons to whom we have made such disclosure.
Right to limit use and disclosure of sensitive Personal Information. You have the right to request us to use your Sensitive Personal Information only to the extent necessary to perform the services or provide the goods, as would be reasonably expected by an average consumer who requests such goods or services.

Under this Privacy Policy, Personal Information is considered sensitive if it reveals:

Racial or ethnic origin.
Political opinions.
Religious or philosophical beliefs.
Trade union membership.
Genetic or biometric data for the purpose of uniquely identifying a natural person.
Data concerning health or data concerning a natural person’s sex life or sexual orientation.

8. How to exercise your rights.

When receiving a verifiable consumer request, we will confirm that the person making the request is the consumer about whom we have collected the Personal Information. We will generally avoid requesting additional information for such purpose. However, if we cannot verify the identity of the consumer from the information already maintained by us, we may request certain additional information that will be only used for the purposes of verifying the consumer’s identity.

We will address your verifiable consumer request in an appropriate manner, and we will respond to your request in the term that is applicable pursuant to the Appendixes set forth in this Privacy Policy or, if none is applicable, within 45 (forty-five) days from the date on which your request was received.

Provided you have a password-protected account with us, we may verify your identity by authenticating you through that account.

However, please note that some of your rights may be subject to certain limitations or exemptions, as provided under applicable law.

8.1. Requests made through authorized agents.

Please note that you also may designate an authorized agent to make the request on your behalf and exercise your right to opt-out of the sale or sharing of your Personal Information. Before accepting your agent’s request, we will take all steps necessary to verify you have duly authorized such agent to act on your behalf, for which they must provide us a signed written authorization or a copy of a power of attorney.

Please note that the parents and/or legal guardians of a child may exercise the rights on behalf of such child.

9. How we share your Personal Information.

We may share your Personal Information globally with our affiliates and group companies to carry out our activities, as specified in this Privacy Policy. Also, we may share Personal Information with third parties located in different countries which may differ from your location or country of origin. Therefore, the Personal Information we collect may be collected, transferred to, processed, and/or stored, in the United States or anywhere where we, our affiliates, our partners, our vendors, agents, suppliers, or service providers maintain facilities. As such, your Personal Information may be subject to privacy laws from different countries.

In this regard, we may share your Personal Information with:

Our affiliates: to provide our services and/or products.
Our vendors, agents, suppliers, or service providers: that help us conduct our business and/or support our infrastructure (such as payment processors when you purchase our products and/or services, live chat services provider, etc.).
Advertising partners.
Channel partners.
For business transfers: we share your Personal Information in those cases where we sell or negotiate to sell our business to a buyer or potential buyer, or in the event of a change in corporate structure by merger, consolidation, liquidation, transfer of substantial assets, or in the unlikely event of bankruptcy. In this case, we will continue to ensure the security and confidentiality of your Personal Information, and give you notice before your Personal Information is transferred to a buyer or becomes subject to a different privacy policy.
Others: for example, to regulators or law enforcement authorities as required by applicable law, court order, or governmental regulations.

10. Advertising.

We may display advertisements from third parties and other content on our Site that may link you to third parties’ websites and/or apps. We cannot control nor be liable or be held responsible for such content and the third-party’s privacy policies. If you click and access a third-party advertisement or link, please understand that you are leaving our Site, and any personal information you provide thereunder will not be covered by this Privacy Policy.

Please refer to the third-party privacy policy to find out how they collect and process your personal information.

11. Data retention and deletion.

We will keep your Personal Information as long as necessary to fulfill the purposes described herein. Upon your request, we will delete your Personal Information, unless we are allowed or required to keep certain Personal Information, for example, to fulfill a legal obligation or to resolve a dispute, etc.

12. How secure is your Personal Information.

We design our systems with your security and privacy in mind. We are firmly committed to the security of your Personal Information. We will make our best efforts to protect your Personal Information by implementing adequate technical, physical, administrative, and organizational measures, in order to guarantee the security of your information. We have implemented several measures such as encryption, and pseudonymization, among others to protect your information. However, please be advised that no system is ever completely secure, and you can decide not to use our products and/or services.

We also encourage you to take all possible measures to secure your Personal Information by using a safe strong password that is not used on other online services, never sharing your password with others, signing off the account immediately after having used the account, being sure you have signed off when using a shared computer, among others.

13. Data Breaches.

Despite our best efforts to guarantee the maximum possible level of security of your information by adopting technical and organizational measures to contribute to the security of your data, there may be data breaches. Provided we suffer a data breach, we will take all necessary measures to reduce its effects and we will comply with applicable laws.

14. Right to Opt-Out of Personal Information Sales and Sharing

You have the right to opt-out of the sale or sharing of your Personal Information as described in Section 7.

We share information with third parties who work with us, as explained in Section 9, for the purposes described therein. Information about our customers is an important part of our business, and we do not sell information about you. We do not exchange information about you with third parties in exchange for money or other consideration. If you do not want us to share your Personal Information or sell it in the future, please opt-out of the sharing and/or sale of your Personal Information by contacting us at martin.castellon@netforemost.com.

Please be aware that if you choose to exercise your right to opt-out, we may not be able to provide you with some or all of our services and/or products.

15. Use of our services by children.

Our services are not directed to individuals under the age of 18 years or the equivalent minimum age in the relevant jurisdiction. If you are underage, please do not use our services and do not provide us with any Personal Information.

We will not collect, use, process, share, store, or sell the Personal Information of underage users if we have actual knowledge that a certain user is underage. Should we become aware that a user under the age of 13 has registered without verifiable parental consent, any such information will be deleted.

16. Where we store your Personal Information.

Your Personal Information will be stored in our databases or in secured servers.

17. Do Not Track settings.

Our Site does not recognize Do Not Track signals. Some third parties may collect aggregate information about the users’ online activities over time and across websites when they use the Site. While this information does not include personally identifiable information, certain processing activities that combine aggregate information with other information in possession of such third parties could result in the identification of users.

18. Update this Privacy Policy.

We may make changes to this Privacy Policy from time to time. We encourage you to review it regularly to learn how we are protecting your privacy. Unless stated otherwise, our Privacy Policy applies to all the Personal Information we have about you. We will post any changes to this policy on this page, and we may also contact you via your contact information, for example by email. Each version of this policy is identified at the bottom of the page by its effective date.

19. How to contact us.

Thanks for reading our Privacy Policy. If you have any questions, requests, comments, and/or concerns regarding this Privacy Policy, please contact us at the following e-mails: martin.castellon@netforemost.com, jorge.lanzas@netforemost.com.

Last updated: October [31]th, 2024.

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