Last updated: 1 September 2026

1. Who we are

This Cookie Policy explains how Hacienda Capital Investments Corp. ("Hacienda Capital", "we", "us" or "our") uses cookies and similar technologies on our website at hacienda.capital (the "Site").

Hacienda Capital is a corporation (sociedad anónima) incorporated under the laws of the Republic of Panama, RUC 155785468-2-2026 DV 23, with its address at Edificio Capital Plaza, Departamento 904, Avenida Roberto Motta, Urbanización Costa del Este, Corregimiento de Juan Díaz, Distrito de Panamá, Provincia de Panamá, Republic of Panama. We are the data controller (responsable del tratamiento) of any personal data collected through cookies on the Site.

This Policy should be read together with our Privacy Policy, which explains how we process personal data more generally and how you can exercise your rights.

2. What cookies are

Cookies are small text files that a website places on your computer, phone or other device when you visit. They allow the site to recognise your device, remember your preferences and understand how the site is used. Cookies set by us are "first-party" cookies. Cookies set by other organisations through our Site are "third-party" cookies.

We use the word "cookies" in this Policy to cover similar technologies as well, such as local storage, pixels and scripts that store or read information on your device.

3. Legal framework

Information collected through cookies that identifies you or can be combined to identify you is personal data under Law 81 of 26 March 2019 on Personal Data Protection and Executive Decree No. 285 of 28 May 2021. We collect it only where Law 81 permits: for cookies that are strictly necessary to provide the Site you have requested, and otherwise with your consent, which you may withdraw at any time.

If you visit the Site from the European Economic Area or the United Kingdom, the EU ePrivacy rules, the EU General Data Protection Regulation or the UK General Data Protection Regulation and the Privacy and Electronic Communications Regulations may also apply. Our approach of asking for consent before setting any non-essential cookie is designed to satisfy those rules as well.

4. The cookies we use

The Site is built and hosted on the Wix platform, operated by Wix.com Ltd. Wix sets the cookies the Site needs to function. We use Google Analytics, provided by Google, and our own first-party tracking script to understand how the Site is used. No other party sets cookies on the Site.

4.1 Strictly necessary cookies

These cookies are essential for the Site to work and to keep it secure. They enable core functions such as page navigation, security checks, load balancing and remembering the choices you make in our cookie banner. They do not require your consent and cannot be switched off in our banner, although you can block them in your browser (see section 6), in which case parts of the Site may not work.

Wix sets the following strictly necessary cookies.

XSRF-TOKEN is used for security, to protect against cross-site request forgery, and lasts for your browsing session.

hs is used for security and lasts for your browsing session.

TS* cookies are used for security and fraud prevention and last for your browsing session.

svSession identifies unique visitors and tracks sessions, and is used in connection with user login. It lasts for two years.

smSession identifies logged-in site members where member areas are used and lasts for your browsing session.

consent-policy stores your cookie banner choices and lasts for 12 months.

bSession measures system effectiveness and lasts for 30 minutes.

SSR-caching indicates how the Site was rendered and lasts for one minute.

_wixCIDX is used for system monitoring and debugging and lasts for three months.

_wix_browser_sess is used for system monitoring and debugging and lasts for your browsing session.

fedops.logger.X measures platform stability and effectiveness and lasts for 12 months.

wixLanguage remembers your language preference on multilingual sites and lasts for 12 months.

4.2 Analytics cookies

These cookies help us understand how visitors use the Site, for example which pages are visited most often, how visitors arrive at the Site and whether they encounter errors. We use the information in aggregated form to improve the Site. We do not use it to identify individuals. These cookies are set only if you accept them in our cookie banner.

**Google Analytics**, provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, California, USA) and, for visitors in the European Economic Area, Google Ireland Limited.

| Cookie | Set by | Purpose | Duration |

| _ga | Google Analytics | Distinguishes visitors | 2 years |
| _ga_[measurement ID] | Google Analytics | Maintains session state for the Site's Google Analytics property | 2 years |

Google Analytics does not log or store IP addresses. Google processes the data on our behalf and may also use it for its own purposes as described in Google's privacy policy (policies.google.com/privacy). You can prevent Google Analytics from collecting your data on any website by installing the Google Analytics opt-out browser add-on (tools.google.com/dlpage/gaoptout).

**Hacienda Capital tracking script**, developed and operated by us.

| Cookie | Set by | Purpose | Duration |

| [hc_vid] | Hacienda Capital | Assigns a random identifier to distinguish returning visitors | [13 months] |
| [hc_sid] | Hacienda Capital | Groups page views into a single visit | [30 minutes] |

Our own script records the pages you view, the time and duration of your visit, the site that referred you, your browser and device type and [a truncated form of] your IP address. It does not read data from other websites and does not share data with anyone outside Hacienda Capital and our hosting providers.

4.3 Cookies we do not use

We do not use advertising cookies, social media tracking cookies, cross-site tracking or any technology designed to build a profile of you for marketing purposes. We do not sell information collected through cookies.

4.4 Where cookie data is processed

Wix.com Ltd. is based in Israel and processes site data on servers in the United States, Europe and Israel. Google processes Google Analytics data on servers in the United States and in other countries where Google operates; for visitors from the European Economic Area and the United Kingdom, Google LLC participates in the EU-U.S. Data Privacy Framework and its UK extension. Data collected by our own tracking script is stored on servers in the European Union and in Latin America. Section 8 of our Privacy Policy explains the safeguards we apply to transfers of personal data outside Panama.

5. Your choices

When you first visit the Site, a banner asks whether you accept optional cookies. Strictly necessary cookies are set regardless, because the Site cannot operate without them. Optional cookies are set only if you click accept.

You can change your mind at any time. Use the "Cookie settings" link in the footer of the Site to review and withdraw your consent. Withdrawing consent stops us from setting further optional cookies; to remove cookies already on your device, use your browser controls (section 6). Withdrawal does not affect the lawfulness of any processing carried out before you withdrew.

6. Controlling cookies in your browser

Most browsers let you see which cookies are stored, delete them individually or all at once, and block cookies from some or all sites. Instructions are available in each browser's help pages, including for Chrome, Safari, Firefox and Edge, and for mobile browsers. Blocking all cookies may prevent parts of the Site from working properly.

7. How long cookie data is kept

Each cookie's lifetime is shown in the tables above. Visitor-level data in Google Analytics is retained for [14] months, the period we have configured, after which Google deletes it and only aggregated reports remain. Data collected by our own tracking script is kept for no longer than [thirteen] months from collection, after which it is deleted or irreversibly anonymised. Records of your consent choices are kept for as long as needed to demonstrate compliance with Law 81.

8. Your rights

Where cookie data is personal data, you have the rights of access, rectification, cancellation, opposition and portability described in section 9 of our Privacy Policy, and the right to withdraw consent at any time. You can exercise these rights by emailing privacy@hacienda.capital or writing to the address in section 1. You may also complain to the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI), the Panamanian data protection authority, at antai.gob.pa.

9. Changes to this Policy

We may update this Policy from time to time, for example if we change the cookies the Site uses. The current version, with its date, will always be published on the Site. Where a change means we would set new optional cookies, we will ask for your consent again.

10. Language and governing law

This Policy is governed by the laws of the Republic of Panama. It is published in English for convenience. If a Spanish-language version is published, the Spanish version prevails in the event of any inconsistency.

11. Contact

Hacienda Capital Investments Corp.
Edificio Capital Plaza, Departamento 904, Avenida Roberto Motta, Urbanización Costa del Este, Corregimiento de Juan Díaz, Distrito de Panamá, Provincia de Panamá, Republic of Panama
Telephone: +507 200-9874
Email: privacy@hacienda.capital

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