Política de privacidad — copia

Privacy Notice

As the party responsible for the processing of personal data, Corporación Alken del Sur BJK S.A., with legal identification number 3-101-778461, is committed to respecting your right to privacy when using our digital platforms (such as our websites, mobile applications, social media pages, or any online form for activity registration) and when contacting us via email.
This privacy policy aims to inform you about how Corporación Alken del Sur BJK S.A., headquartered in Pérez Zeledón, 150 meters east of the PZ Country Club, Barrio Cooperativa, San Isidro del General, Costa Rica («ALKEN») and its subsidiaries (collectively, «Alken,» «we,» «us,» or «our») collect, store, use, and process your personal data (“personal data”) provided through any digital medium managed by Alken (the “digital platforms”).

By using Alken’s services, you accept these terms. Please read them carefully.

Table of Contents

1. What types of personal data do we collect?
2. For what purposes do we use your personal data?
3. What happens if you refuse to provide us with your personal data?
4. Why and to whom do we transmit your personal data?
5. How long do we retain your personal data?
6. How do we protect your personal data?
7. What are your rights?
8. How do we process children’s personal data?
9. How can you contact us?

1. What types of personal data do we collect?
Personal data is collected solely for the purposes outlined in Section 2 and whenever you participate in any events, activities, or services offered through our digital platforms.
The type and amount of information collected for these events and services may vary depending on ALKEN’s activities.

Subject to applicable legal requirements, we may use a variety of technologies to collect and provide information about how you access and use our digital platforms. We may also utilize demographic information (such as your age, gender, and areas of interest, if available) about users of our digital platforms, which we may obtain from third parties or through social media platforms you use («Usage Information»). Usage Information may include the pages you viewed, the times you viewed them, the beverage or other content information you accessed or provided, the language used, including demographic details about you, and the pages you visited before viewing the current page, among others.

2. For what purposes do we use your personal data?
The type of information we collect depends on how you interact with us. We collect your personal data for the following purposes:

• Business Purposes: Your information may be used to maintain a history of your consumption patterns, send you commercial information and advertisements, and serve as contact information for informative purposes, statistical analysis, or following up on matters with the company. It may also involve the international transfer of your data, among others. This information may relate to ALKEN brands or other brands of products you may not have purchased.
• Responding to Service Requests or Fulfilling Contracts: When you register or subscribe to our digital platforms (mobile applications, websites, social media, etc.), your personal data is used to provide the functionalities and services you subscribed to, along with associated advantages and privileges (e.g., receiving selected communications at the time of registration, being invited to events, participating in contests, etc.).
• Sending Operational or Administrative Communications: This includes emails such as confirmation messages when you register [or unsubscribe] from a service or functionality, as well as notifications about service updates (e.g., updates to privacy notices, service interruptions, or modifications to online services or IT support policies).
• Marketing Communications: Provided we have your consent, we may send you targeted marketing messages, emails, or SMS.
• Consent-Based Activities: Besides the main purpose for which you provided your personal data, we may also ask for your consent (e.g., by ticking a box) to use your data for a different activity or service. For example, if you register for a contest or promotional activity, we may invite you to subscribe to newsletters or alerts from the digital platform hosting the promotion.
• Legitimate Interest: To enhance our services, we may combine, update, or aggregate your personal data collected through our digital platforms with data received from third parties or external sources. For example, demographic data or survey information (such as age, gender, family details, and interests) may be combined with personal data collected through our services.

These combined datasets and/or demographic data help us conduct marketing and demographic studies to improve, personalize, and tailor our products and services to meet your needs. Some tools we use may involve automated decision-making as permitted by applicable law.

• Accuracy and Updates: We ensure your personal data is accurate and up-to-date or complete it with additional information you provide. We strive to avoid duplications in our database by verifying each interaction and checking the accuracy or completeness of your personal data.

3. What happens if you refuse to provide us with your personal data?
If you refuse to provide the requested personal data, you may not be able to participate in certain activities, enjoy personalized functionalities, or access specific digital platform features and special services. However, you are not obligated to provide personal data to browse our digital platforms and learn about ALKEN and our products. We will always indicate which data is necessary for a specific service.

4. Why and to whom do we transmit your personal data?

a. To companies within Corporación Alken del Sur BJK S.A.:
For the purposes outlined in section 2, ALKEN may share your personal data within the Alken Group, including Dimond, Quimera, Seren, Transporte Sobre Ruedas, Residencial Sulit, and Residencial Vima. Various ALKEN employees, representatives, and advisors (both internal and external) may access the information for these same purposes. Providing this information is optional; however, refusing to provide it may result in the company being unable to offer certain services.

b. To third parties: Your personal data may be transmitted to third parties only in the following cases:

• For marketing purposes: Provided we have your consent.
• For assistance purposes: We may engage service providers, agents, or contractors to support or maintain our digital platforms or assist in administering such platforms, programs, promotions, and features. These third parties are committed to protecting your personal data to the same security standards as ALKEN. Where required by law, these commitments will be formalized contractually.
• For co-sponsored promotional programs: In joint or co-sponsored promotional activities on our digital platforms with other companies or trusted third parties, we may collect and share your personal data, provided we have your consent, if legally required. If another company collects or receives your personal data during these promotional activities, you will be informed at the time of data collection.
• By legal or security requirements: We may share your personal data if legally obligated to do so or in good faith when such sharing is necessary to comply with legal proceedings, respond to claims, or protect the safety and rights of ALKEN, its customers, or the public.
• In case of corporate changes: In the event of a merger, acquisition, or transfer of all or part of ALKEN’s business, the buyer may access certain information, including personal data, as permitted by law. Data may also be transferred during restructurings, insolvency proceedings, or similar circumstances, if legally permissible.

5. How long do we retain your personal data?

We will store your personal data in our databases as long as your account remains active, for the duration of the contract signed with you, or as necessary to provide the requested services, respond to inquiries, address issues, or offer new and improved services. We may also retain personal data in line with our internal retention procedures to fulfill legal and regulatory obligations, resolve disputes, or enforce agreements.

Data will generally be deleted from our databases ten years after the recorded events, unless otherwise required by specific regulations. If further retention is needed beyond this period, the data will be anonymized.

Thus, we may retain your personal data after you have ceased using ALKEN’s services or platforms, in compliance with legal requirements.

6. How do we protect your personal data?

ALKEN employs technical and organizational measures to safeguard the privacy and security of personal data collected through our digital platforms. These measures include:

1. Storing personal data in protected operating environments accessible only to authorized ALKEN personnel, agents, and contractors.
2. Verifying the identity of registered users before granting access to their personal data.

7. What are your rights?

You have the following rights concerning your personal data:

a. Access: You may access your personal data.
b. Rectification or deletion: You may request corrections, updates, or deletion of data if they are inaccurate, incomplete, outdated, or collected without your consent.
c. Consent withdrawal: If your data is processed with your consent, you may withdraw it at any time without affecting prior processing based on said consent.
d. Deletion: You may request the deletion of your personal data if:

• The data is no longer necessary for its purpose.
• You have withdrawn consent for processing based solely on that consent.
• You have objected to processing.
• The processing is illegal.
• The data must be deleted to comply with applicable legal obligations.

e. Restriction of processing: You may request restricted data processing under certain conditions, such as contesting the accuracy of your data or requiring retention for legal purposes.

f. Limitation of services: You may choose not to provide personal data, but this may limit your activities and the functionalities we can offer.

g. Objection: You may object to processing your data for marketing or profiling purposes or when based on ALKEN’s legitimate interest.

8. How do we handle children’s personal data?
Our website is not intended for minors, as they do not meet the legal age required to enter into professional service contracts («minors»). Therefore, we do not knowingly collect any personal data from minors. Users must be at least eighteen years old to create an account and participate in activities and transactions on our digital platforms. If we become aware or are informed that a minor has provided us with their personal data through our digital platforms, we will proceed to delete it.

9. How can you contact us?
If you have questions, complaints, or comments related to this privacy policy or our data collection practices, you can send us an email at: recepcion@grupoalkencr.com.

Consent

By accepting this document, I confirm that I have been informed that Corporación Alken del Sur BJK S.A., legal ID 3-101778461 (the «Company»), maintains and manages a personal data database (the «Database») where the information provided at this time, as well as any other information provided during my current or potential future commercial relationship with the Company (the «Information»), is stored.

I understand that I have the right to request access, correction, updating, and deletion of the Information under the terms set forth in the «Law for the Protection of Individuals Regarding the Processing of Their Personal Data» and its regulations. I also declare that I have been informed that the Company and its affiliates are responsible for the Database and that I am aware of the address of their offices as indicated above.

I have been informed that I can exercise all these rights by expressing my desire via email to recepcion@grupoalkencr.com. Additionally, I acknowledge that providing this information does not establish an employment relationship with the Company or modify any current employment relationship.