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HACIENDA CAPITAL

Privacy

Last updated: 1 September 2026
 

1. Who we are
 

Hacienda Capital Investments Corp. ("Hacienda Capital", "we", "us" or "our") is a corporation (sociedad anónima) incorporated under the laws of the Republic of Panama.
 

Commercial operation notice (Aviso de Operación) No. 155785468-2-2026-2026-574445605, issued by the Ministry of Commerce and Industries, Directorate General of Domestic Commerce
Registered activity: activities of holding companies (code 6420)
Address: 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
Privacy enquiries: privacy@hacienda.capital
 

Hacienda Capital is a holding company. We do not offer products or services to the general public. The personal data we process relates mainly to our shareholders, directors and officers, the businesses we invest in or evaluate and the people who represent them, our professional advisers and service providers, and visitors to our website.
 

For the purposes of Law 81 of 26 March 2019 on Personal Data Protection ("Law 81") and its implementing regulation, Executive Decree No. 285 of 28 May 2021 ("Decree 285"), Hacienda Capital is the data controller (responsable del tratamiento) of the personal data described in this Policy.
 

2. Scope
 

This Policy applies to personal data we process about:
 

shareholders, directors, officers and beneficial owners of Hacienda Capital and of its subsidiaries and affiliates;
investors, co-investors, lenders, counterparties and their directors, officers, employees and representatives;
founders, shareholders, management and key personnel of businesses we evaluate, invest in or support;
our professional advisers, suppliers and service providers and their personnel;

people who apply to work with us;
visitors to our website at hacienda.capital and anyone who contacts us by any means.

It does not apply to information about legal entities as such, except where that information identifies or can identify an individual.
 

3. Legal framework
 

We process personal data in accordance with:
 

  • Articles 42 and 44 of the Political Constitution of the Republic of Panama, which protect every person's right to access, rectify and protect their personal data and provide the habeas data remedy;

  • Law 81 of 2019 and Decree 285 of 2021;

  • Law 23 of 2015 on the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction, as amended, to the extent it applies to us or to entities we deal with;

  • Law 129 of 2020 on the Single Registry of Beneficial Owners of legal entities;

  • Law 52 of 2016 on accounting records, as amended by Law 254 of 2021, and the Commercial Code;

  • the Fiscal Code and other Panamanian tax laws, including obligations under international tax information exchange arrangements (CRS and FATCA) where applicable;

  • any other Panamanian law that requires or permits us to process personal data.
     

If you are located in the European Economic Area or the United Kingdom, you may also have rights under the EU General Data Protection Regulation or the UK General Data Protection Regulation. We will honour those rights where they apply.
 

4. The personal data we process
 

Identification and contact data. Full name, nationality, date and place of birth, identity document or passport details, tax identification number, residential and business address, email address, telephone numbers, signature, and any photograph appearing on an identity document.
 

Professional data. Employer, position, professional history and qualifications and, for job applicants, CVs, references and interview notes.
 

Corporate and ownership data. Shareholdings, directorships, powers of attorney, beneficial ownership information, and board and shareholder resolutions.
 

Due diligence and compliance data. Information collected to identify and verify you, your source of funds and source of wealth, whether you are a politically exposed person, and the results of sanctions, adverse media and public records screening, where this is required by law, by our banks, resident agent or counterparties, or by our own compliance procedures.
 

Financial and transactional data. Bank account details, payment records, capital contributions, distributions, loans, invoices and related correspondence.
 

Communications. Emails, letters, meeting notes and other records of our dealings with you.
 

Website and technical data. IP address, browser type, device identifiers, pages viewed, referring site and cookie data (see section 11).
 

Sensitive data. We do not seek to collect sensitive personal data as defined in Law 81, such as data revealing racial or ethnic origin, religious, philosophical or moral beliefs, political opinions, trade union membership, health, sex life or sexual orientation, or genetic or biometric data. If sensitive data is disclosed to us incidentally, for example within a document you provide, we process it only where Law 81 permits and, where the law requires, with your explicit consent. Information about criminal convictions or offences is processed only to the extent needed for sanctions, anti-money-laundering and fit-and-proper checks permitted by Panamanian law.
 

5. How we obtain personal data
 

  • Directly from you, in person, by email, through our website or in documents you provide.

  • From the company, fund or organisation you represent or are connected with.

  • From our subsidiaries and affiliates.

  • From publicly available sources, including the Public Registry of Panama, other corporate registries, court records, sanctions lists and the press.

  • From third parties that provide identity verification, screening, credit reference or corporate intelligence services.

  • From our banks, resident agent, lawyers and other professional advisers in the course of their work for us.

  • Automatically, through cookies and similar technologies when you use our website.
     

6. Purposes and legal bases
 

Under Law 81 we may process your personal data with your consent, or without it where the processing is necessary to perform a contract or pre-contractual steps with you or the entity you represent, to comply with a legal obligation, where the data comes from publicly accessible sources, or in the other cases Law 81 expressly permits. Where we rely on consent, you may withdraw it at any time (see section 9).
 

We process personal data for the following purposes:
 

Corporate governance and administration. Maintaining our registers of shareholders and directors, convening and recording meetings, paying dividends and distributions, making filings with the Public Registry of Panama and the Ministry of Commerce and Industries, and meeting the information requirements of our resident agent, including beneficial ownership reporting under Law 129 of 2020. Basis: legal obligation; contract; consent where applicable.

Investment activity. Identifying, evaluating, negotiating, structuring, executing, financing, monitoring and exiting investments in subsidiaries and other businesses, including due diligence on their owners, directors and management. Basis: contract; publicly available sources; consent where required.

Compliance and risk management. Identity verification, know-your-customer and anti-money-laundering procedures, sanctions and politically exposed person screening, fraud prevention, and responding to lawful requests from regulators, tax authorities, courts and law enforcement. Basis: legal obligation; contractual requirements of banks and counterparties; consent where required.

Tax and accounting. Keeping accounting records, preparing financial statements and tax filings, and reporting under CRS and FATCA where applicable. Basis: legal obligation.

Banking and payments. Opening and operating bank accounts and making and receiving payments. Basis: contract; legal obligation.

Communications and relationship management. Responding to enquiries and managing our relationships with shareholders, partners, advisers and portfolio companies. Basis: contract; consent.

Website operation and security. Operating, securing and improving our website and IT systems. Basis: processing necessary to deliver the website you have requested; your consent for non-essential cookies.
Recruitment. Assessing applications and, if successful, entering into an employment or services contract. Basis: pre-contractual steps at your request; consent.

Legal rights. Establishing, exercising or defending legal claims and enforcing our agreements. Basis: legal obligation; contract; other grounds permitted by Law 81.

Corporate transactions. Any merger, reorganisation, sale, financing or similar transaction involving Hacienda Capital or its assets. Basis: contract; consent where required.
 

We do not use personal data for marketing to the general public and we do not sell personal data. We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing.
 

7. Who we share personal data with
 

We share personal data only where necessary for the purposes above, with:
 

  • our subsidiaries and affiliated companies;

  • our resident agent, lawyers, notaries, accountants, auditors and tax advisers;

  • banks, payment service providers and custodians;

  • identity verification, screening and corporate intelligence providers;

  • IT, cloud hosting, email, document management and cybersecurity providers acting on our instructions as data processors (encargados del tratamiento);

  • co-investors, counterparties and their advisers, where you are involved in a transaction;

  • Panamanian and foreign public authorities, including the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI), the Dirección General de Ingresos, the Unidad de Análisis Financiero, the Public Registry, the Ministry of Commerce and Industries, courts and law enforcement, where the law requires or permits;

  • prospective purchasers, investors or lenders and their advisers in connection with a corporate transaction, under confidentiality obligations.
     

Our processors act only on our documented instructions and must keep personal data secure and confidential, as Law 81 and Decree 285 require.
 

8. International transfers
 

We store personal data on servers located in the European Union and in Latin America, operated by service providers acting as our processors. Providers holding data in the European Union are themselves subject to the EU General Data Protection Regulation. Our subsidiaries, counterparties, advisers and other service providers may also be located in countries outside Panama.
 

Law 81 permits personal data to be transferred outside Panama where the recipient country or the recipient offers a level of protection equivalent to that of Panamanian law, where you have consented, where the transfer is necessary to perform a contract with you or in your interest, or in the other cases Law 81 and Decree 285 allow. Where we transfer personal data abroad we put appropriate safeguards in place, including contractual confidentiality and data protection commitments, and we transfer only what is necessary.
 

9. Your rights
 

Under Law 81 you have the following rights, known as the ARCO rights and the right to portability:
 

Access. To know whether we process your personal data, what data we hold, where it came from, the purposes of the processing and to whom it has been disclosed.

Rectification. To have inaccurate, incomplete or outdated data corrected.

Cancellation. To have your data deleted or anonymised when it is no longer necessary for the purpose, when you withdraw the consent on which processing was based, when it has been processed unlawfully, or in the other cases Law 81 provides. This right is subject to the legal retention obligations described in section 10.

Opposition. To object to processing for legitimate reasons relating to your particular situation, or where the processing is based on your consent, and to object to use of your data for purposes you have not agreed to.

Portability. To receive the personal data you have provided to us in a structured, commonly used format and, where technically feasible, to have it transmitted to another controller.

Withdrawal of consent. Where processing is based on your consent, to withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before it.
 

How to exercise your rights.

Email privacy@hacienda.capital or write to the address in section 1, stating the right you wish to exercise and enough information for us to identify you and locate your data. We may ask you to verify your identity before acting and, if you act for someone else, to prove your authority. We will respond within ten (10) business days of receiving a complete request, or within any different period Law 81 permits, and we will explain the reasons for any refusal. Requests are free of charge, save that we may charge a reasonable fee for repetitive or manifestly excessive requests where Law 81 allows.
 

Complaints. If you believe we have processed your personal data in breach of Law 81, you may lodge a complaint with ANTAI, the Panamanian data protection authority (antai.gob.pa), and you may bring a habeas data action before the Panamanian courts under Article 44 of the Constitution. We would welcome the chance to resolve your concern first, but you are not required to contact us before approaching ANTAI.
 

10. How long we keep personal data
 

We keep personal data only for as long as necessary for the purposes for which it was collected and to comply with our legal obligations. In particular:
 

corporate records, including registers of shareholders and directors and minutes, are kept for the life of the company and for the period required after its dissolution;

accounting records and supporting documentation are kept for at least five years from the end of the fiscal period to which they relate, as required by Panamanian commercial and tax law, including Law 52 of 2016 as amended;

due diligence, identity verification and transaction records collected for anti-money-laundering purposes are kept for at least five years after the end of the relationship or the transaction, as required by Law 23 of 2015 and by our banks and resident agent;

tax records are kept for the periods required by the Fiscal Code;

records relating to actual or threatened legal claims are kept until the matter is concluded and any limitation period has expired;

unsuccessful job applications are kept for up to [twelve] months after the decision unless you ask us to delete them sooner;

website logs and cookie data are kept for the periods stated in section 11.
 

When personal data is no longer needed we delete it or irreversibly anonymise it.
 

11. Cookies

Our website uses strictly necessary cookies that make the site work and keep it secure. These do not require your consent.
 

We also use analytics cookies to understand how visitors use the site. We set these only with your consent, which you can give or withdraw at any time through the cookie banner or your browser settings.

We do not use advertising or third-party tracking cookies. Cookie data is kept for no longer than [thirteen] months. You can delete or block cookies through your browser; some parts of the site may not work without the necessary cookies.
 

12. Security

We apply technical, organisational and administrative measures appropriate to the nature of the data and the risks involved, as required by Law 81 and Decree 285. These include access controls, encryption of data in transit, secure storage, confidentiality obligations for our staff and advisers, and due diligence on our processors. No system is completely secure. If a security breach affects your personal data in a way that creates a risk to your rights, we will notify ANTAI and you within the time limits and in the manner Law 81 and Decree 285 require.
 

13. Minors

Our website and our activities are not directed at persons under 18. We do not knowingly collect personal data from minors without the consent of a parent or guardian as required by Law 81. If you believe a minor has provided us with personal data, please contact us and we will delete it.
 

14. Third-party websites

Our website may contain links to websites operated by others. This Policy does not cover those sites and we are not responsible for their privacy practices. Please read their privacy policies before providing them with any personal data.
 

15. Changes to this Policy

We may update this Policy from time to time. The current version, with its date, will always be published on our website. Where a change is material and we hold your contact details, we will notify you where Law 81 requires it.

16. 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. Any dispute concerning this Policy is subject to the jurisdiction of the courts of the Republic of Panama, without prejudice to your right to complain to ANTAI.
 

17. 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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