PRIVACY POLICIES
When users provide their data and personal information on the website, it is understood that they do so voluntarily and knowingly. In such circumstances, the aforementioned data may only be used by the company for the purposes indicated above.
If the user consents, the company may share this information with affiliates of WIT, Inc., who in turn will provide details about their own products.
In any situation, those users who wish to stop receiving information and messages from the company or any of its associated companies, WIT, Inc., through their email address will have the possibility to cancel their subscription and stop receiving said information. If they express their desire to do so, the company will immediately remove the user from its email contact list and will refrain from sending them any information by email in the future.
The company will establish confidentiality agreements with third parties in charge of providing services related to its website, such as the design, administration and updating of the page, and who have access to the information provided by users. These agreements will ensure that third parties treat such information with the same confidentiality as the company. By granting your authorization for the processing of personal data, the user also grants authorization for this data to be known and processed by the aforementioned third parties. However, these third parties may only do so for the purpose of carrying out the services for which they were contracted by the company, and will be subject to the corresponding legal regulations at all times.
At the request of the user, the company will proceed to eliminate or modify part or all of the information provided by him. This request can be made through the Site or through the toll- free contact line at wit@wit-network.com
In situations where there is a legal or judicial mandate, or when necessary to protect the company’s intellectual or industrial property rights, the company reserves the right to disclose any type of information provided by users.
Personal information collected on this website is stored in secure operating environments that are not accessible to the public.
INTELLECTUAL AND INDUSTRIAL PROPERTY
The elements of intellectual or industrial property, such as trademarks, trade names, logos, graphics, designs and any other protected element, present on this website, are legally protected in favor of the company. Therefore, its use, modification, copying, reproduction, transmission or distribution in any way or by any means is not permitted without the prior, express and written authorization of the Company. The protected contents include texts, images, illustrations, designs, software, music, sound, photographs, videos and any other means or form of dissemination of said contents.
Any ideas, opinions, suggestions or comments that users send to the site spontaneously and without prior request by the company, related to products, services, marketing plans or other topics, may be freely used by the company at its discretion for the development of new products, investments, businesses or marketing plans. These communications are considered non-confidential and are not protected by any intellectual or industrial property regulation.
Consequently, the user who sends said information may not claim compensation or any participation for the use that the company makes of it. It is noted that the aforementioned information may be copied, distributed and disclosed by the company for commercial or non- commercial purposes.
Posting on this website of information that is defamatory, threatening, or otherwise in violation of the law is prohibited.
LIABILITY EXCLUSIONS
The Company makes a careful selection of the links («links») to other Internet sites that can be accessed through its website. However, it is not responsible for the content or technical aspects of such sites, as it does not and cannot control them, especially considering that their content may change over time. Therefore, access to these links through the company’s website is carried out at the risk and sole responsibility of the user. It should be noted that once the linked site is accessed, it is understood that the user has left the company’s page.
The company warns users that the information provided on the site may contain errors, inaccuracies, be incomplete or out of date. Therefore, it reserves the right to correct any errors, omissions or inaccuracies, as well as to make changes or updates at any time and without prior notice. These actions will not affect the rights acquired by users.
Site users are prohibited from engaging in the following behaviors:
Use the websites, their contents, technical elements and applications for illegal purposes.
Violating, destroying, modifying or using third-party information without the proper authorization of the owner of said information.
Use the name of the company or the technological platforms provided by it to send commercial messages or unsolicited emails (spam).
It is strictly prohibited under United States law to use the company’s name or company-provided technology platforms to transmit or disseminate any unlawful, threatening, defamatory, obscene, scandalous, pornographic, racist, or harassing material that violates the moral integrity of people.
Likewise, the dissemination of any other type of statement or material that may generate civil or criminal liability, as established by law or that violates current legislation in the United States, is prohibited.
Upload to the Internet portals of the company documents that may threaten the integrity of the information hosted on said sites, the devices (computers) or the assets of third parties, such as malware in general, unauthorized remote access programs and malicious programs, among others. In addition, any behavior that results in errors, damages,
interruptions or the suspension of the operation of the site, either directly or indirectly, is not allowed.
The action of trying to enter restricted areas and/or impersonating another user or any third party.
The company is not obligated to keep the sites and means of communication active at all times, despite their availability. Likewise, it reserves the right to admit people and suspend the service without prior notice, regardless of the reason. The company complies with current regulations and therefore reserves the right to disclose any information it deems harmful. However, it will reveal any information requested by the competent authorities.
Personal Data Treatment Policy
WIT, Inc
In compliance with the provisions of the United States Privacy Act (US Privacy Act) of 1974, WIT, Inc. adopts the following Policy for the Treatment of Personal Data (hereinafter «The Policy»), which will be communicated to all holders of the data collected or obtained in the future.
In this sense, WIT, Inc. states that it guarantees the rights of privacy, intimacy and good name in the processing of personal data, and therefore, all its actions will be governed by the principles of legality, limitation of purpose, consent, accuracy , transparency, access and restricted circulation, security and confidentiality.
All persons who provide personal data to WIT, Inc. will have the right to know, update, rectify, delete or revoke the authorization previously granted.
I.Definitions
Database: Ordered set of personal information that is submitted to processing.
Personal information: Any data related or that can be associated to one or more identified or identifiable natural persons.
Processor: Individual or entity, whether public or private, that carries out the processing of personal data on behalf of the controller.
Data Controller: Individual or entity, whether public or private, that makes decisions about the database and/or data processing, in this case WIT, Inc., and its affiliated companies.
Authorization: Prior, clear and informed approval of the Owner to carry out the Processing of personal information.
Holder: Individual whose personal data is subject to Processing.
Processing: Any action or set of actions related to personal data, such as collection, storage, use, disclosure or deletion.
Individual: Human being who exercises rights and fulfills responsibilities individually.
Additionally, those companies in which WIT, Inc. exercises control, has a unity of purpose and direction will be considered as subsidiaries.
Third Party: Any legal or natural person other than those who are directly members of WIT, Inc.
Confidential information: Information that affects the owner’s privacy or whose misuse may result in discrimination.
Public information: Refers to data that is not semi-private, private or confidential, and that can be found in publicly accessible records and documents, official gazettes and bulletins, as well as court rulings.
Private information: It is the information that, due to its intimate or reserved nature, is only relevant to the Owner.
Semi-private data: refers to data that is not of an intimate, reserved or public nature, but whose knowledge or disclosure may be of interest not only to the owner, but also to a certain sector or to society in general.
II.Purpose
The purpose of this policy is to define the general guidelines for compliance with the privacy laws of the United States, including the US Privacy Act of 1974, which regulate the handling of personal databases.
By virtue of this regulation, the guidelines for the collection, storage, use, disclosure and elimination of personal data processed by WIT, Inc. and its subsidiaries will be established.
III.Alcance
This policy is applicable to all personal information stored in the databases of WIT, Inc. and its subsidiary companies, who will act as controllers of personal data.
IV.Obligation
Compliance with this policy is mandatory for WIT, Inc. and its subsidiaries.
V.General Conditions
To comply with the privacy laws of the United States, including the US
Privacy Act of 1974, on the protection of personal data, the following considerations must be taken into account:
- WIT, Inc. is the entity in charge of processing personal data bases.
- Third parties that have access to the databases will be considered Data Processors and, therefore, must comply with the privacy laws of the United States, including the US Privacy Act of 1974, as well as with any other regulations that complement , modify or relate to
this Policy. - The law is mandatory throughout the United States, and to transfer personal data to other countries, the laws of those countries must include security measures that are equal to or better than those established in the aforementioned privacy laws.
- At WIT, Inc., personal databases are considered to be all those that contain information on natural persons, whether they are suppliers, members of Mutual Funds, clients, consumers, volunteers or other persons whose information is processed by us.
It is not required to apply the policy in exceptional cases by legal provision when:
- The purpose of the databases and files is national security and defense, as well as the prevention, detection, monitoring and control of money laundering and terrorist financing, in accordance with the provisions of the law.
- The databases are aimed at and contain intelligence and counterintelligence information, as provided by law.
- The databases and files are for journalistic information and other editorial content, in compliance with the corresponding legal provisions.
SAW. Specific conditions
It is necessary to take into account the following specific conditions:
As of this date, any employee who begins a labor relationship with a company of the WIT Inc. Business Group in the United States must have a clause in their employment contract that expresses the commitment to comply with the privacy laws of the United States, including the US Privacy Act of 1974.
In addition, a text that establishes the obligation to comply with the privacy laws of the United States, including the US
Privacy Act of 1974, to cover all current employees.
For any third party that needs to access the personal databases related to the areas or companies of WIT, Inc, a contractual clause must be requested in which knowledge of the regulations and the responsibility to comply with them are established. In addition, the prior authorization of the Owner will be required for the processing of their personal data by said third party.
It is necessary to request authorization in writing from all suppliers, members of the Mutual Funds, clients, consumers, volunteers or other persons linked in any way to the WIT Inc Business Group, as well as employees whose data is processed by our part. This authorization must allow the processing of the data without restrictions and must be valid for all the actions that we carry out in the exercise of our functions.
In the authorization mentioned in the previous paragraph, the responsibility of the Holders to keep the information updated and truthful must also be made clear, and timely notify the companies of the WIT Inc. Business Group to which they granted their authorization any related modification.
All personal databases that are processed by the areas and companies of the WIT, Inc. Business Group must have recovery guarantees (Back up).
Access to personal databases must be limited. When they are sent through mass media, they must have passwords or restricted access mechanisms.
Databases should not be published on the intranet or the internet without access restrictions.
WIT, Inc. companies must periodically carry out campaigns to promote the updating of their personal databases.
For the treatment of personal databases in the United States, all areas that require it must have a written procedure that guarantees compliance with the privacy policy and laws of the United States, including the US Privacy Act of 1974. This will ensure the proper management and protection of personal data in accordance with current legislation in the country.
All WIT, Inc. companies must implement a procedure for handling queries and claims, ensuring legal compliance in relation to this matter.
VII.Data Controllers
The following is the information of the companies responsible for the processing of personal data, currently in the WIT Inc Business Group:
WIT, Inc. with principal address at 3735 Straigthfork Dr Houston TX, 77082 , . website https://wit-network.com/ Phone : 832 820 2400
VIII.Treatment and Purpose
The treatment carried out by those responsible for the databases in the United States will be carried out in accordance with the provisions of the privacy laws of the United States, including the US Privacy Act of 1974, as well as with any other regulations that complement, modify or is related to said laws, and in accordance with the provisions of this Policy. This will guarantee that the handling of personal data is carried out adequately and in accordance with current legislation in the country.
The personal data collected will be used exclusively for the purposes established in the respective privacy notices or data processing authorizations made available to the Holders so that they authorize their processing.
However, the databases may also be used for the following purposes:
Carry out the necessary steps for the development of the company’s corporate purpose, in relation to the fulfillment of the contracts entered into with the owners of the
information.
Send invitations to events and offer new products or services.
Manage procedures related to requests, complaints or claims.
Treatment of Sensitive Data
In the event that those responsible carry out the Processing of Sensitive Data, it will be guaranteed that prior and express authorization is obtained for the treatment of said data.
data, complying with the following obligations:
The Owner of the data will be informed that, as it is Sensitive Data, he is not obliged to authorize its treatment.
The Owner will be previously and expressly informed about what the sensitive data is and what will be the purpose of the treatment that will be given to them.
No activity will be conditioned to the Owner providing Sensitive Data.
IX.Rights of the Holders
As Holders of personal data, you have the following rights:
Free access to the data provided that has been subject to Processing.
Know, update and rectify your information in the event that there are partial, inaccurate, incomplete, divided, misleading data, or those whose treatment is prohibited or has not been authorized.
Request proof of the authorization granted for the processing of your data.
Submit complaints to the Superintendence of Industry and Commerce for violations of the provisions of current regulations.
Revoke the authorization granted or request the deletion of your data, as long as there is no legal or contractual duty that prevents its deletion.
Refrain from answering questions related to sensitive data. The answers about sensitive data or data of minors will be optional.
X.Attention to Petitions, Queries and Claims
To make inquiries, claims, obtain more information or request the consultation, modification, update, rectification, deletion or revocation of the authorization for the Processing of your personal data, we invite you to contact us through the telephone lines and web pages mentioned. previously.
The area responsible for dealing with the aforementioned requests is Customer Service for consumers and customers. In the case of suppliers, the area in charge is WIT, Inc. Services Purchases. If you are an affiliate or supplier of the Funds, we recommend that you contact them directly to receive attention regarding your requests.
WIT, Inc. with principal address at 3735 Straigthfork Dr Houston TX, 77082 , . website https://wit-network.com/ Phone : 832 820 2400
XI.Procedure for the Exercise of the Right of Habeas Data
In compliance with the regulations on protection of personal data, WIT, Inc. and its affiliated companies, as data controllers, establish the following procedure and minimum requirements for the exercise of their rights. For the attention of your request, complaint or claim, we ask you to provide the following information:
Full name and surname of the Owner of the personal data. Contact details of the Owner of the personal data:
Physical address and/or email address.
Contact telephone numbers.
Reasons or facts that support the claim, request or query, together with a brief description of the right you wish to exercise (such as knowing, updating, rectifying, requesting proof of authorization granted, revoking it, deleting, accessing information, among others).
Signature (if possible). Identification number.
These requirements will allow us to provide you with adequate care and process your request efficiently.
Once all the required information has been received, the Responsible Party will have a maximum period of fifteen (15) business days, from the day following the date of your request, query or claim, to attend to it. In the event that it is not possible to resolve the request within this term, the Responsible Party will inform the Owner or interested party of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) days. business days after the expiration of the first term mentioned.
Once the terms established by the privacy laws of the United States have been fulfilled, including the US Privacy Act of 1974, and other regulations that regulate or complement them, if a Holder who is totally or partially denied the exercise of access rights , update, rectification, deletion and revocation, you may present your case before the competent authority, such as the Federal Trade Commission (FTC) or another entity that has jurisdiction over the protection of personal data. This will allow any disagreement related to the processing of your personal data to be adequately resolved.
XII.International Transfer or Transmission of Personal Data
WIT, Inc. and its subsidiaries may carry out the transfer and transmission, even internationally, of the personal data found in its databases, as long as the applicable legal requirements are met and the owners of the personal data expressly authorize such transfer and transmission.
In the case of the transfer of personal data of the holders, WIT, Inc. and its subsidiaries will take the necessary measures to guarantee that the third parties involved are aware of and agree to comply with this policy. It will be understood that the personal information they receive may only be used for matters directly related to WIT, Inc. or for the purposes expressly authorized by the data owner, and only while said authorization is in force. It may not be used or intended for any another purpose or end.
XIII.Validity
This Policy for the Treatment of Personal Data is effective as of June 24, 2023 in the United States.
The databases in which the personal data are recorded will be kept as long as there is a current contractual relationship with the Owner of the information, or until the interested party requests its deletion, as long as there is no legal duty that requires its conservation.
XIV.Processing of personal data
The User grants his authorization to WIT, Inc., its subsidiaries or other companies contracted to carry out activities of delivery, promotion, collection or analysis of information (hereinafter referred to as Responsible and Processors) and to the Sellers, for the processing of personal data. obtained in the context of the use of the Site. The purpose of this authorization is to provide a comprehensive service for order management, including operational, logistic, and billing purposes, among others. It also includes the creation of databases of visitors to this Site, the knowledge of visitors, users and customers, and the possibility of adapting the content of the Site, performing statistical analysis of the actions carried out on the Site and the behavior of purchase by users and customers. In addition, it seeks to improve the advertising, marketing and promotional strategies of the Company, based on the needs and preferences of users and customers. Users may also be contacted to respond to their comments and requests for information, or to send them messages on topics of interest to them. In addition, information from WIT, Inc. and its affiliates may be sent.
The personal data that Users provide on this website will not be used for purposes other than those authorized by the user himself. Such data will remain in secure operating environments and will not be available to the public.
The User is informed that, as the owner of the personal data, he has the following rights:
Know, update and rectify your personal data against WIT, Inc., its affiliates or vendors.
Request proof of authorization granted to WIT, Inc. and its affiliates or vendors.
Request information from WIT, Inc. and its affiliates or vendors, upon request, about the use that has been made of your personal data.
In the event of having a complaint or query before WIT, Inc. and its subsidiaries or vendors, file complaints with the Superintendence of Industry and Commerce for violations of the applicable legal regulations.
Revoke the authorization and/or request the deletion of personal data when the Treatment does not respect the constitutional and legal principles, rights and guarantees.
Free access to your personal data that has been processed.
XV.Cookies and Us
The publication on the website of defamatory, threatening information or content that violates the law is prohibited. WIT, Inc. reserves the right to remove from the site any material it deems inappropriate, which right you may exercise at any time.
The availability of the site and the means of communication does not obligate WIT, Inc. to keep them active at all times.
WIT, Inc. will not be responsible in the event that a user registers false information and accesses the web page in this way, nor will it assume responsibility for the use of the site that the user makes under false assumptions.
WIT, Inc. establishes the following prohibitions, as part of a policy of correct use of its website:
The use of the site, its contents, technical elements and applications for illegal purposes. Violation, destruction, modification or use of third-party information without the proper authorization of the owner of said information.
Use of the name of WIT Inc or of the technological platforms provided by the company to distribute commercial messages or unsolicited emails (Spam).
Use of the name of WIT inc or of the technological platforms provided by the company to transmit or disseminate pornography, child pornography, racist material, threats of any kind, verbal abuse that threatens the moral integrity of people or any other manifestation that violates the privacy legislation in force in the United States.
Uploading files to the website that may damage or affect the information contained therein, such as viruses and worms, or other conduct that may cause errors, damage, interruptions, or suspension of the page’s operation.
Attempt to access restricted areas and/or impersonation of another user or of any third.
WIT, Inc. will take the necessary legal actions to repair the damages caused by any user who fails to comply with the rules contained in this document.
WIT, Inc. reserves the right to expel any user who does not comply with the rules established in this document.
Cookies: «Cookies» or information files stored on the hard drive of computers may be used with the aim of collecting additional information from users during their visit to the website, with the purpose of improving the site or adjusting WIT products. , Inc. to the interests and needs of users. The user has the option of configuring their browser to reject cookies or to receive notifications when a cookie is sent to their computer (the user’s guide for the PC’s operating system may provide information on how to do this). However, the rejection of cookies could limit access to certain areas of the website or prevent the receipt of personalized information during visits to the same.
Transfer of data: WIT, Inc. will not use the data collected on its website for purposes other than those expressed in this document, nor will it transfer the data to third parties without the prior consent of the owners of said data.