Privacy Policy.

1. Identification of the data controller

The controller of personal data collected through this website and in the course of the professional services we render is RESET (the "Firm"), with offices at C.C. Plaza Paitilla, P.B., Office 25, Panama City, Republic of Panama. RESET operates four strategic capabilities —Digital Reset, Legal Reset, Social Impact, and Enterprise Reset— under a single data-processing responsibility.

Controller's contact email: hola@reset-corp.com · Phone: +507 310-9137.

For specific data-protection inquiries, write to the same email with "Data protection" or "Subject access request" in the subject line.

2. Applicable legal framework

This Policy is governed primarily by:

• Law 81 of March 26, 2019 on Personal Data Protection of the Republic of Panama.
• Executive Decree No. 285 of May 28, 2021, the regulation implementing Law 81.
• Law 23 of April 27, 2015 and related rules on prevention of money laundering, terrorist financing, and financing of weapons of mass destruction, applicable when the engagement consists of legal services rendered by Legal Reset.
• Regulation (EU) 2016/679 (GDPR) and the ePrivacy Directive 2002/58/EC, where data subjects reside in the European Economic Area or where we offer services targeted at residents of it.
• Panama's Judicial Code and the Code of Professional Ethics for Attorneys, regarding the heightened professional secrecy applicable to Legal Reset client information.

3. Categories of personal data we process

We process the following categories of data depending on the context in which you interact with us:

3.1. Contact data. When you complete the Site's contact form or write to us by email: first name, last name, email address, phone number, the strategic capability you are interested in (Digital Reset, Legal Reset, Social Impact, or Enterprise Reset), and the content of your message.

3.2. Browsing data. IP address, browser type, operating system, language, pages visited, time on page, referring site. Collected through cookies and similar technologies; details in our Cookie Policy.

3.3. Professional and counterparty data. When the engagement consists of legal services rendered by Legal Reset, we collect the data needed to render the service: identification, address, tax ID, corporate structure, ultimate beneficial owners, background, and other data required by Know Your Customer and anti-money-laundering rules.

3.4. Sensitive data. Only when strictly necessary for the engagement, and always with the data subject's express, informed consent under article 11 of Law 81. We apply heightened security measures to such data.

3.5. Communications data. Emails, calls, video meetings, and professional messaging. When the engagement is with Legal Reset, these communications are protected by professional secrecy once a formal lawyer-client relationship is established.

4. Purposes of processing

We process your data for the following specific, explicit, and legitimate purposes:

• Respond to contact requests and answer inquiries.
• Assess the viability of a potential engagement and, for Legal Reset, screen for conflicts of interest.
• Render the services contracted under the corresponding proposal or engagement letter.
• Comply with applicable legal and regulatory obligations, including KYC and anti-money-laundering rules when the engagement is with Legal Reset.
• Issue invoices and meet tax obligations.
• Improve site quality and security through aggregate analytics.
• Defend our rights and those of our clients in court or out of court when necessary.

We do not use personal data for purposes other than those declared here. We do not carry out advertising profiling, sell data subjects' data, or share it with third parties for marketing purposes.

5. Legal basis for processing

Under article 6 of Law 81 and, where applicable, article 6 of the GDPR, processing is based on one or more of the following grounds:

• Express, informed consent given when completing the contact form or accepting non-essential cookies.
• Performance of a contract or pre-contractual measures (rendering the service you engage us for).
• Compliance with a legal obligation (KYC where applicable, document retention, tax obligations).
• Legitimate interest in maintaining site security, fraud prevention, defending our rights and those of our clients, and improving our services.

6. Retention periods

We keep personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a legal obligation requires otherwise:

• Contact form data that does not lead to a contractual relationship: up to twenty-four (24) months from the last contact.
• Active client data: for the entire duration of the professional relationship.
• Files and documentation for legal services (Legal Reset): five (5) years after the relationship ends, in accordance with article 92 of Law 23 of 2015 and the statute of limitations for professional liability claims.
• KYC and compliance documentation (Legal Reset): five (5) years after the relationship ends.
• Accounting and tax documentation: five (5) years or the period required by tax law.
• Browsing data and cookies: as set out in the Cookie Policy.

7. Disclosure to third parties

We do not sell your data. We disclose data to third parties only when necessary to fulfill the stated purposes and always under processing agreements that ensure an adequate level of protection. The main recipients are:

• Zoho Corporation Pvt. Ltd. — provider of the CRM and conversational assistant (SalesIQ) used to handle the Site's contact form and chat.
• Vercel, Inc. — hosting provider for the website.
• Google LLC — provider of web fonts (Google Fonts) and, through a private connection managed from Zoho SalesIQ, processing of conversational-assistant messages (Gemini).
• Public authorities when there is a legal obligation (judiciary, public ministry, tax authorities, financial supervision agencies, ANTAI).
• Collaborating professionals and corresponding lawyers in other jurisdictions, only with your prior authorization or when strictly necessary to execute a Legal Reset engagement.

All third parties we work with are contractually bound by the obligations of article 27 of Executive Decree 285 of 2021 and, where applicable, the safeguards required by the GDPR.

8. International transfers

Some providers process data outside Panama. When that occurs, we require either an adequacy finding for the destination country or recognized contractual safeguards (standard contractual clauses, binding corporate rules) under article 35 of Law 81 and, where applicable, chapter V of the GDPR. You can request a copy of the safeguards by writing to hola@reset-corp.com.

9. Your rights as a data subject (access, rectification, erasure, objection, portability)

Under Law 81 and, where applicable, the GDPR, you hold the following rights:

• Access: know what data we process about you.
• Rectification: correct inaccurate or incomplete data.
• Erasure: request deletion when the data is no longer necessary or when you withdraw consent, subject to legal retention obligations.
• Objection: object to processing on grounds related to your particular situation.
• Portability: receive your data in a structured, commonly used format and, where technically feasible, transmit it to another controller.
• Restriction of processing: require us to store rather than further process your data.
• Withdrawal of consent at any time, without affecting the lawfulness of processing carried out beforehand.
• Not be subject to automated decisions with significant legal effect without human intervention.

How to exercise them: write to hola@reset-corp.com with your request and a copy of your ID. We respond within thirty (30) calendar days of receipt, in line with article 24 of Law 81.

10. Complaints to the supervisory authority

If you believe the processing of your data infringes the law, you may file a complaint with the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI), the supervisory authority for personal data protection in Panama: antai.gob.pa. If you reside in the European Union, you may also approach the supervisory authority of your country of residence or place of work.

11. Professional secrecy

When the engagement consists of legal services rendered by Legal Reset, the information you entrust to us is subject to the professional secrecy set forth in Panama's Judicial Code and the Code of Ethics of the National Bar Association of Panama. This protection is additional to and stronger than Law 81: it yields only when the law itself permits, when the client expressly waives it, or when a court orders disclosure in the cases provided by law.

12. Security measures

We apply reasonable technical and organizational measures to protect personal data against unauthorized access, loss, or alteration: encryption in transit (TLS), least-privilege access control, encrypted backups, access logs, confidentiality agreements with staff and providers, and periodic security reviews.

In the event of a personal data breach that poses a risk to the rights and freedoms of data subjects, we will notify ANTAI within seventy-two (72) hours and, where appropriate, also the affected individuals, in line with article 25 of Law 81.

13. Children

Our services are aimed at companies and professionals over the age of 18. We do not knowingly collect personal data from minors under 18. If you believe a minor has provided data without authorization, write to hola@reset-corp.com and we will delete it.

14. Changes to this Policy

We may update this Policy to reflect legal, operational, or technological changes. When changes are material, we will notify you at least thirty (30) days in advance through the website. The last-updated date appears at the top of this document.

15. Contact and rights exercise

For any inquiry about this Policy or to exercise your rights:

• Email: hola@reset-corp.com
• Phone: +507 310-9137
• Postal address: C.C. Plaza Paitilla, P.B., Office 25, Panama City, Republic of Panama

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