Santex Group, hereinafter referred to as “Santex” or the “Company”, informs the holders of personal data, hereinafter referred to as the “Data Subjects”, about its privacy policy, which regulates the way information is collected, stored, used, transmitted, and protected when provided and/or collected during the use of services provided by the Company, in compliance with the provisions of National Law No. 25.326 on Personal Data Protection and related regulations. By using Santex’s services, the User accepts this Personal Data Privacy Policy, therefore if the User does not agree with this Policy, they will not be able to use the services and functionalities of Santex, and it is therefore recommended that they avoid providing any personal data.

1. Scope of Application
This Policy shall apply to the processing of personal data collected through:
a) The main website identified with the domain santexgroup.com, including its internal pages, landing pages, and subdomains;
b) The virtual assistant SAM, in any of its access modes, including when embedded in the form of an iframe; and
c) Any advertising action carried out by the Company at the various events in which it participates.

2. Personal Data Collected
The Company may collect, as applicable, the following data:
a) Data derived from browsing the website or subdomains

• IP address, approximate location, language, device type, operating system, browser, access times.

• Pages visited, session duration, browsing behavior (scrolling, clicks, forms viewed).

b) Data provided through voluntary forms and registrations

• First name, last name, email address.

• Company, position, nature of the request.

• Contact and/or subscription preferences.

c) Data collected through interaction with the SAM assistant

• Conversation records (messages, questions, and history).

• Interaction timestamps.

• Information derived from the analysis of the conversation (topics of interest, frequency, intentions).

• Identifying data expressly provided in the conversation (first name, last name, email address, company, position).

Santex will only collect Personal Data that each User has voluntarily provided and/or agreed to provide. If the User decides not to provide the required information in any of the available forms, Santex will be unable to properly provide its services. In the event that the User provides and/or manages information from another natural or legal person, Santex will assume that they have previously obtained the corresponding authorization from the data subject for its collection and processing in accordance with the terms of this Policy.

3. Means and Mechanisms of Collection
Data collection will be carried out through the following means:

• Cookies and similar technologies, including Google Analytics 4, Microsoft Clarity, and Hotjar.

• Marketing tags and pixels, such as Apollo, Meta, and Google Ads.

• Registration and contact forms voluntarily completed by each Data Subject.

• Voluntary interactions with the SAM assistant.

The SAM assistant will also collect data that, by themselves, cannot be directly associated with a specific person, such as usage patterns, operation times, and other traffic data that allow analysis of SAM’s usability in order to improve the user experience.

4. Purpose of Processing
The personal data collected will be processed for the following purposes:
a) Responding to inquiries, requests, or requirements from Data Subjects.
b) Managing business opportunities and providing information about products and services.
c) Sending communications, notifications, and informational material that may be of interest.
d) Implementing marketing, advertising, and commercial prospecting actions, including personalized campaigns and effectiveness analysis.
e) Optimizing the user experience, site performance, and the functioning of the SAM assistant.
f) Analyzing usage trends, identifying interests and needs of users to provide relevant information and content.

5. Retention Period
The data will be retained for the following periods:

• Cookies (Google Analytics 4): up to fourteen (14) months.

• Voluntary forms and registrations: until the Data Subject requests deletion or opt-out.

• Interactions with the SAM assistant: until the Data Subject requests deletion or opt-out.

6. Data Transfer and Disclosure
Personal data may be transferred or shared with third parties solely for the purposes set forth in this Policy, including:

• Analytics and marketing platforms, for example with Google Analytics, Microsoft Clarity, Hotjar, Apollo, Meta, Google Ads.

• Automation and business management tools, for example with Mailchimp, Salesforce, or other equivalents.

• Business partners and affiliated companies, where necessary for the management of joint opportunities.

In all cases, such third parties must assume contractual obligations of confidentiality and data security at the same level applied by Santex.

7. Rights of Data Subjects
The Data Subject may, at any time and at no cost, exercise the rights recognized in Articles 14 and 16 of Law No. 25.326, including:

• Access their personal data under processing.

• Request the rectification, update, deletion, or confidentiality of such data.

• Request the removal or blocking of their name from databases for advertising purposes.

To this end, the User must submit their request to: privacy@santexgroup.com, stating the right they wish to exercise, their reasons and grounds, as well as any additional information that allows Santex to understand the request and proceed efficiently to provide a satisfactory response.

It is hereby informed that the National Directorate for the Protection of Personal Data, the regulatory authority of Law No. 25.326, has the authority to handle complaints and claims regarding non-compliance with personal data protection regulations.

8. Security Measures
Santex will adopt the technical, organizational, and legal measures necessary to ensure the security, confidentiality, and integrity of the personal data processed, preventing its alteration, loss, consultation, or unauthorized processing.

9. Policy Modification
Santex may modify this Policy at any time. Modifications will be published on the website, indicating the date of the last update.