1. GENERAL CONSIDERATIONS

SNAPPY a company belonging to the same economic group duly incorporated under the laws of the State of Florida whose purpose is to provide, among others, virtual assistant services with artificial intelligence (hereinafter, the "Services").

In order to guarantee the best travel assistance service, SNAPPY may obtain, collect and/or store information and personal data of its customers (hereinafter, "Personal Information" and the "Customers", respectively) provided that such information and data are essential and necessary for the provision of such Services.

As responsible for the correct use and administration of such Personal Information, SNAPPY has sufficient security, technical and administrative measures in place to maintain the required level of protection and safeguarding, thus guaranteeing its Clients the due reliability and security in the handling of such information.

SNAPPY guarantees the privacy and confidentiality of the Personal Information provided by its Customers through any of SNAPPY's Websites, e-mail, sales channels or by any other means of communication, in accordance with the provisions of the applicable regulations on the matter.

In order to respect to the maximum the interests and expectations of its Customers, SNAPPY has a serious commitment linked to the respect and observance of this Privacy, Confidentiality and Personal Data Protection Policy (hereinafter, the "Privacy Policy" or "Policy"), in relation to the collection, use, storage, protection and disclosure of data.

2. WHAT PERSONAL INFORMATION IS COLLECTED?

SNAPPY collects and stores the personal information provided by its Customers in order to contact and/or identify them, through the various channels enabled for this purpose. In turn, SNAPPY obtains and stores the Personal Information that Customers provide when performing the following actions: (i) contracting virtual assistance Services, (ii) browsing SNAPPY's Website and/or registering as a user through an Account on said Website, (iii) using the various online Services, (iv) participating in promotions, contests, sweepstakes and/or promotional and/or marketing campaigns, (v) contacting via email, and (vi) using the application for cell phones and tablets.

The Personal Information collected may include, but is not limited to, first and last name, mailing address, telephone number, tax identification number, e-mail address.

SNAPPY only collects personal information provided freely and voluntarily by the Customer, not storing any other information that is not provided in this way.

The Client may choose not to provide certain Personal Information when it deems it appropriate to do so, to the extent that the failure to provide such Personal Information does not prevent the provision of the Services of interest to the Client.

With the reservations specified in this Policy and being the guiding principle regarding Personal Information, confidentiality, protection and security in the treatment, the Customer expressly accepts that such information may be transferred to external service providers of SNAPPY (such as, for example, technology providers, legal advisors, etc.) that are necessary for the provision of the Services.

In all cases in which SNAPPY exceptionally provides Personal Information to suppliers for the provision of the required Service, it shall be required that they are treated with confidentiality, in accordance with the regulations governing the protection of personal data and that they are intended for the sole and exclusive purpose of performing the Services.

3. WHAT DO WE DO WITH THE PERSONAL INFORMATION WE COLLECT?

SNAPPY will store any Personal Information provided by the Customer, for a satisfactory provision of the Services that may be required and the Customer, by granting them, expressly consents that:

a) SNAPPY stores any Personal Information it may have obtained for, during and/or as a consequence of the requested Services, in the Records duly declared to the Control Authority.

b) SNAPPY may assign and/or transfer and/or provide the necessary Personal Information to: (i) external suppliers linked to SNAPPY, who contribute to the fulfillment of the purpose of the required service; (ii) third parties with whom SNAPPY has signed confidentiality agreements, provided that such third parties are linked, related and/or connected to the fulfillment of the required Services and require such Personal Information for the provision; (iii) companies belonging to the SNAPPY Group, its controlling and controlled companies, provided that this is necessary to fulfill the purpose for which they were obtained. SNAPPY may offer them better services or provide information related to products already purchased.

c) SNAPPY may contact them in order to: (i) improve commercial and promotional initiatives, personalize content, presentation and services; (ii) send information or messages by e-mail about new services, advertising or promotions, banners of interest, news about SNAPPY, (iii) send notices about contests and/or sweepstakes that SNAPPY organizes.

d) SNAPPY may share Personal Information with business partners, with whom they may jointly offer products or services. Such suppliers and business partners will be subject to confidentiality agreements that prohibit unauthorized use or disclosure of the Personal Information to which they have access. The access to the Personal Information by third will be governed by the policy of resignation (opt out) described next.

e) With respect to the retention period of Customer Personal Information, it will be consistent with the original purpose for which it was collected. In this regard, SNAPPY will store the Customer's Personal Information as long as the Customer has an active account on the SNAPPY Website and/or continues to be a SNAPPY Customer, and for a reasonable period of time after such conditions no longer exist. This reasonable period includes the time necessary for SNAPPY to conduct audits, comply with legal obligations, resolve disputes and ensure compliance with its legal agreements.

4. HOW TO ACCESS, UPDATE OR CORRECT YOUR PERSONAL INFORMATION?

The Personal Information will be stored and the Customers - in their capacity as holders of the Personal Information stored - have the right to exercise the right of access, rectification, cancellation and/or deletion. For any consultation and/or additional information that the Customer may require in relation to this Policy, he/she may contact SNAPPY at the call centers and/or through an e-mail addressed to [email protected].

The Personal Information will be treated with the legally required degree of protection to guarantee its security and avoid its alteration, loss, treatment or unauthorized access.

5. OPT OUT POLICY

When the Customer carries out transactions or registers as a user on the SNAPPY platform or purchases any of its Services, they will be given the option of whether they wish to receive promotional newsletters, messages or e-mail alerts about offers.

The Customer may change their choices at any time, through the email settings where they will be given the opportunity to unsubscribe from receiving messages.

6. EXTERNAL LINKS

The SNAPPY Web Site contains links to other sites. SNAPPY is not responsible for the privacy or content of such websites. If you visit such other websites, SNAPPY advises you to review their privacy and confidentiality policies. The Customer may choose not to provide us with information, assuming all the consequences that may arise and/or originate from such a decision.

By reading this Privacy Policy and using the Services, you accept and authorize SNAPPY to process the data you may have obtained, in accordance with the terms of this Policy and within the framework of specific regulations. The lack of formal communication of disagreement with these terms and conditions shall imply the express consent of the Customer to the extent, method and guidelines set out in these terms and conditions.