MENDEL will be responsible for the processing and protection of the Personal Data of its Users, and carries out the activities of collecting, storing, and safeguarding the Information, as the controller, through the internet website www.mendel.com (hereinafter the “Website”) and/or the Mendel App, for which reason it makes available to you the Privacy Policies detailed below.

The protection of Personal Data is the responsibility of MENDEL, and its owners may exercise the rights granted to them by the applicable regulations in accordance with the procedure established in Law No. 25,326 on the Protection of Personal Data.

MENDEL may request from the User the Personal Data necessary for the provision of the contracted services. The User expressly accepts that MENDEL may request and process the data listed below without limitation and without prejudice to other data that may also be requested and/or processed at the request of MENDEL:

1. Personal identification data of the User.
2. Contact details of the User and the User’s Persons.
3. Data relating to the location of the device from which the Website is accessed and/or the Mendel App is run.
4. Access IP data corresponding to the device using the Mendel App and the Website.
5. Tax data for billing services.
6. Corporate Information and Financial Information and information relating to the User’s credit risk profiling and/or profiling in terms of Law No. 25,246 on Concealment and Laundering of Criminal Assets, as well as other financial data corresponding to the means of disposal that the corporate User and the User’s Persons use.

MENDEL also collects the following personal data:

Identification and contact data of natural persons, where applicable:

• Name
• Marital status
• CUIL/CUIT
• place of birth
• Birthdate
• Nationality
• Home
• Home phone
• Cellular phone
• Email
• Age

Identification and contact data of legal entities:

• Company name
• Activity or corporate purpose
• Country of incorporation
• Tax ID
• Home
• Phone
• Date of incorporation
• Shareholding Structure
• Name of attorney(s), administrator(s), manager(s)
• Name of the Final Beneficiary

Employment data

• Position or post held
• Work address
• Email
• Telephone(s)

Academic data

• Educational background
• Curriculum Vitae of the Company ( legal entities )

Migration data

• Residence rights
• Country of incorporation of the Company (legal entities)

Asset and/or financial data of natural persons:

• Credit history
• Income
• Bank Accounts
• Credit card number(s)

Asset and/or financial data of legal entities:

• Credit history
• Financial Statements
• Bank Accounts

All of these data may be obtained personally or through electronic means (equipment, optical media or any other technology, automated data processing systems and telecommunications networks, whether public or private, in terms of the applicable legal provisions that MENDEL makes available to the User for this purpose, in which they will record the creation, transmission, modification or extinction of rights and obligations).

Under no circumstances does MENDEL request data from minors deliberately or intentionally.

The data marked as “mandatory” on the registration forms or information requests are essential for (i) opening the User’s account, (ii) enabling the issuance of cards, and (iii) complying with anti-money-laundering and know-your-customer (KYC) regulatory requirements.

– Refusal to provide this data will prevent the creation of the account and the contracting of the services.

– Supplying false or inaccurate data entitles MENDEL to suspend or cancel the services and, where applicable, to report the irregularity to the competent authority.

– Providing complete and accurate information allows the User to receive the products and benefits associated with the platform.

In the specific case of the Mendel APP and the Website, as well as those specialized third parties, where appropriate providers and/or commercial entities, MENDEL may collect the following additional data:

• Geolocation.
• Biometric Data.

The personal data that MENDEL collects are for two types of purposes:

1. Those that gave rise to and are necessary for the existence, maintenance and fulfillment of the relationship between MENDEL and the User by virtue of the services provided by MENDEL.

• Identify customers and validate their identity.
• Manage and operate the services and products that you request or contract with MENDEL.
• Analyze payment capacity and liquidity.
• Inform the customer about changes in products and services.
• Registration of your data for the purposes of the contracted product and service.
• Formalize and register the contracting of a product or service.
• Geolocation of the User who wishes to contract, through a mobile device or Website.
• Identify Users, verify and validate their identity, as well as verify and validate the veracity of the Corporate Information and Financial Information, including analysis of their credit capacity.
• Identify representatives, officers, employees, contractors, subcontractors, directors, managers and/or other officials of the User.
• Promotion and evaluation of financial services and products including credit analysis and risk profile assignment.
• Marketing and promotional activities, sending Users information that may be of interest to them.
• Market analysis activities, intelligence related to the spending and consumption behavior of the User and his/her representatives, risk analysis, analysis of purchasing preferences (product categories, prices, location, etc.), delivery of results on the activity of the User and his/her representatives in the use of means of disposal.

2. Those that are not necessary and do not give rise to the legal relationship between MENDEL and the User.

• Customer satisfaction and quality surveys.
• Sending commercial and advertising information via email, cell phone (SMS, MMS).
• Inform about new products or services that are related to those contracted or acquired by the client.
• Debt collection management seeking the recovery of overdue portfolio, as well as to carry out preventive actions in this regard, including the sale of portfolio. By entering into a contract with MENDEL, the User expresses his/her express or tacit consent to carry out the processing in accordance with the provisions of the applicable regulations. Likewise, the User acknowledges and declares that with respect to the Personal Data of natural persons that he/she provides to MENDEL, the User is subject to the obligation to inform said natural persons about the processing of their personal data and the content of these Privacy Policies, and that he/she has duly complied with said information.

MENDEL adopts and implements appropriate practices for data collection, storage and management, and security procedures against unauthorized access, alteration, addition, deletion, disclosure and/or destruction of User Information, name, email address, password, transaction information and any other stored information.

MENDEL CONSIDERS THE PROTECTION OF ITS USERS’ PRIVACY AND THE SECURITY OF THEIR INFORMATION AS A PRIORITY.

MENDEL guarantees Users that access to their information is limited only to employees, representatives, suppliers and clients who need to know such information to perform their duties and/or provide or improve services in accordance with the purposes of its collection and processing set forth in these Privacy Policies. In this regard, MENDEL requires from such third parties the same or higher standards of security and confidentiality as employees for their own Information.

In accordance with articles 14 and 16 of Law No. 25,326 on the Protection of Personal Data, the User has the right to access the information that MENDEL collects in relation to him/her and to request the rectification, updating, deletion and confidentiality of the Information contained in the databases.

Likewise, the User may request, free of charge, the removal or blocking of his or her name and email from files or databases for advertising purposes (art. 27, paragraph 3 of Law No. 25,326 on the Protection of Personal Data).

If at any time the User wishes to exercise any of the aforementioned powers, the User must send his/her request to the email address [email protected]

MENDEL must provide access to the Personal Data requested as indicated above within (10) ten calendar days of receiving the request. Access to the Information will be free of charge and may be exercised at intervals of no less than 6 (six) months, unless a legitimate interest is proven to this effect.

In the event that the User requests the deletion and/or correction of Personal Data, MENDEL must respond to the User’s request within 5 (five) business days of verifying his/her identity by contacting the aforementioned email address.

The Public Information Access Agency is responsible for handling complaints and claims filed by those whose rights have been affected by non-compliance with current regulations on personal data protection. Users may contact the Public Information Access Agency at the following addresses: www.argentina.gob.ar/aaip Email: [email protected] Tel. +541128210047.

MENDEL may transfer and process the User’s personal data within and outside the country, to entities affiliated with MENDEL, regulators and companies that provide services, for the purposes mentioned in point IV of these Privacy Policies, for which the User gives his/her consent under these Privacy Policies. Such other countries to which the User’s personal data may be transferred and processed may not have adequate levels of protection such as those existing in Argentina. Notwithstanding the foregoing, MENDEL complies with current regulations and employs safeguard measures that guarantee adequate protection of User information pursuant to the provisions of Law No. 25,326 on the Protection of Personal Data and complementary regulations.

In addition, MENDEL may provide your Personal Data if any law so requires, or when requested by the competent authorities in terms of the applicable legislation.

When transferring this data, MENDEL will ensure that its affiliated entities, regulators and companies providing services assume the same obligations regarding the protection of Personal Data.

When accessing the Mendel Website and/or App, it is important to keep in mind that it uses mechanisms (Cookies and Web Beacons or other technologies) that automatically collect information, such as: source IP address, browser used, date and time you accessed the Mendel Website and/or App, browser type, operating system type, web pages visited, searches performed, advertising reviewed, lists and consumer habits on shopping pages, among others.

Considering the above, it is important for you to know that you can disable the use of these mechanisms at any time according to the instructions provided by each company that owns the web browsers.

At MENDEL, we reserve the right to make changes or updates to these Privacy Policies at any time to address legislative or jurisprudential developments, internal policies, new requirements for the provision or offering of our services or products and market practices.

In the event of any changes to these Privacy Policies, you will be notified through the Website.

If you have any questions or comments regarding these Privacy Policies, please contact us through the following communication channel: [email protected]