DUNALASTAIR PRIVACY POLICY

We hereby inform you about our policies regarding the collection, use, storage, and protection of personal data received from users of the App.

In accordance with Article 19 No. 4 of the Political Constitution of the Republic, Law No. 19.628, and applicable regulations, Dunalastair has established the following privacy policy to safeguard the security, confidentiality, and privacy of its users.

These policies are intended to ensure the proper use of the information collected through visits to digital platforms and their content.

We may collect information about you or that you provide when using the mobile application (the “Application”) and all equipment, data, and services related to the Application made available in the Republic of Chile, and/or through other interactions and communications you have with us.

1. Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for you to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.

Application or app means the software program provided by the Company downloaded by You on any electronic device.

Company (referred to as either “the Company,” “We,” “Us,” or “Our” in this Agreement) refers to Dunalastair SPA.

Country refers to Chile.

Device means any device that can access the Service such as a computer, a cell phone, or a digital tablet.

Personal data refers to any information that relates to an identified or identifiable individual.

The Service refers to the Application.

Service provider means any person or legal entity that processes the data on behalf of the Company.

This refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.

Third-party social media service refers to any website or social network website through which a User can log in or create an account to use the Service.

Usage data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Scope and Application

This Privacy Policy applies to your use of our Services. Unless otherwise expressly indicated herein, this Privacy Policy does not apply to information collected by third parties, including through applications, websites, or content (including promotional content) that may link to or be accessible from the Services. These third parties may have their own privacy policies, which we encourage you to read before providing information to or through them.

3. What Data We Collect

When accessing and using the Dunalastair application, users will be asked to provide certain information, as indicated in the Terms and Conditions.

Thus, data is collected from subscribers and/or users of digital platforms through two mechanisms:

a) Manual Mechanisms: Formal and express requests for information from subscribers and users that involve the collection of personal data, including but not limited to:

• Information provided when you register an account to access the Services or use the Services, or when you modify that account, including your first name, last name, age, gender, email address, date of birth, identification number, phone number, health information, photos, among others.

• Information provided in the event you contact us to request a service or assistance, or if you otherwise communicate with us, including, for example, the content of the message.

• Information provided when sharing content with other users through the Services.

• Other information that you choose to provide us.

Dunalastair reserves the right to use and collect this data in order to improve the quality of information on the portal and better segment the areas of interest for its users in general.

b) Automatic Mechanisms: These are computerized processes performed to generate records of user activities on digital platforms, with the aim of establishing patterns of activity, browsing, and audience, which do not involve the personal identification of those subscribers and users accessing these platforms.

Dunalastair reserves the right to collect and use this general information in order to establish criteria to improve the contents of its platforms, in all cases disassociated from the person who left the data during navigation.

Cookies and Tracking: Like many websites, we use cookies and similar technologies to collect additional site usage data and manage our services. Some of our services may not function properly if cookies are disabled. When allowed by your browser or device, we use both session cookies and permanent cookies to better understand how you interact with the platform, obtain aggregate usage patterns, and personalize and manage our services in other ways, such as providing account security, personalizing content we show you, including ads, and remembering your language preferences.

Email Notifications and Newsletter: To provide users with relevant and interesting information, Dunalastair reserves the right to maintain the aforementioned information in its care, creating an email list to send information to users about their accounts, service changes, or new policies. Users may not opt to remove their emails from this list (unless they request the cancellation of their accounts). However, they may request the cancellation of their subscription to non-administrative emails such as newsletters, informational bulletins, and other emails.

When interacting with emails sent by Dunalastair (e.g., by opening the email or clicking on links within it), Dunalastair may collect information about that interaction.

We will not send emails to users asking them to enter their password or other personal information or account information.

4. Use of Information

Generally, we use each user’s personal data to provide and improve platforms, including but not limited to the following purposes:

• To verify your identity and recognize you when you use the Services again.

• To operate and improve the Services.

• To provide you with information and the services or assistance you request.

• To communicate with you and send important notices about our services, including but not limited to communications regarding changes in Services, software updates, and upcoming account expiration.

• To customize and improve the Services according to your personal interests, and to provide or recommend features, content, social connections, ads, and other goods and services.

• To request information from you, such as inviting you to participate in surveys.

• To contact you.

• To estimate the number of users and usage patterns, and to track and evaluate the effectiveness of our efforts.

• To monitor, investigate, or prevent illegal, abusive, or suspected illegal activities and content.

• To notify you of your non-compliance with the Terms and Conditions or other terms of the Services.

• To enforce the rights we hold under any agreement between you and us.

• For internal administration and operations, including, without limitation, to detect and prevent errors, fraud, abuse of our Services, and other illegal activities; to troubleshoot software bugs and operational problems; to perform data analysis, testing, and research; and to monitor and analyze usage and activity trends.

• For the purpose for which the information was provided.

• For any other purpose, with your consent.

By using the site or mobile application, users have agreed to the collection of certain personal data, in accordance with this policy and the terms and conditions of use.

5. Freedom, Choice, and Access to Collected Information

At any time, users may exercise the rights granted by Law No. 19.628 and its subsequent amendments. This includes the following:

a) Requesting information regarding the data banks for which the agency is responsible, the legal basis for their existence, their purpose, types of stored data, and a description of the universe of people they include.

b) Requesting information on data relating to yourself, its origin and recipient, the purpose of storage, and the identification of individuals or organizations to which your data is regularly transmitted.

c) Requesting the modification of your personal data when it is incorrect or not up-to-date, if applicable.

d) Requesting the deletion or cancellation of the data provided when desired, as applicable. Platforms, both on the website and in app formats, may link to third-party servers outside our control and domain, so each user will be responsible for reviewing the privacy policies of such sites.

Dunalastair is not responsible for the collection, use, processing, and transfer of data obtained by third-party servers.

6. Disclosure of Content

In the limited situations where Dunalastair discloses private personal data, it will be done under the control of each user, as it is important for managing services or as required by law.

Dunalastair is not responsible for the disclosure of content shared on the platform by third parties. Notwithstanding the above, we reiterate our commitment to strict compliance with this privacy policy, according to the care and publicity measures agreed upon with each user.

7. Security

Aside from the authorizations established above, Dunalastair will maintain the due confidentiality of personal data and will not transmit it to third parties, except when it is required by a legal mandate or an order issued by the Courts of Justice.

To avoid any loss, misuse, alteration, unauthorized access, and/or theft of personal data or confidential information provided by users, Dunalastair has adopted security and personal data protection measures according to industry standards, guaranteeing their protection under the legally required degree of diligence. Consequently, users declare their understanding that in the case of violation through illegal actions, force majeure, or authority requirements, Dunalastair cannot guarantee the total and absolute inviolability of its database, nor the perfect operation of its protection and safeguarding mechanisms. The security of users’ personal data is very important to Dunalastair; however, we inform you that no method of internet transmission or electronic storage is completely fail-proof. Notwithstanding the above, Dunalastair commits to implementing this privacy and security policy strictly.

8. Changes to This Privacy Policy

This privacy policy will take effect from January 1, 2024, and for an indefinite period, except for any changes in its clauses that may occur in the future. In the event of any modification, it will take effect from its publication on the website www.dunalastair.cl

We reserve the right to update or modify the privacy policy at any time, and it will be the responsibility of each user to periodically review its changes.

It will be understood that any activity and/or use of the platform, whether through the website or its mobile application format, constitutes tacit acceptance of the modifications made to this policy and consent to the application of the same in its entirety.

If any modification is made to this policy, we will notify users via email at the email address provided by them.

9. Contact

If you have any questions about this policy, or if you encounter issues related to data protection by Dunalastair, please send an email to dunalastair@dunalastair.cl