1. Data controller
Goldtech Holdings INC., referred to below as “Goldtech”, is the controller of the personal data it collects directly through its website and communication channels, as described in this Privacy Policy.
Our contact details are:
Legal name: Goldtech Holdings INC.
Address: Avenida Balboa, Edif. BAC, Torre Menor, Piso 4, Panama City, Panama.
Email: sales@goldtechholdings.com.
Website: https://goldtechholdings.com.
For questions about this policy or the processing of your personal data, please email the address above with the subject line “Personal data protection”.
2. Purpose and scope
This Privacy Policy explains what personal data we may collect, how we use it, when we may share it, how long we retain it and how you can exercise your rights.
It applies to the processing of personal data in connection with:
Browsing our website.
Communications sent to Goldtech.
Requests for information, quotations, proposals or demonstrations.
Managing business relationships with customers, prospective customers, suppliers and business associates.
Providing services and responding to support requests, where applicable.
Where a service or activity requires specific privacy terms, these will be provided separately.
Where Goldtech processes personal data on behalf of a customer, it will do so in accordance with the relevant contract and the lawful instructions it receives. This policy does not replace any data processing agreements required for those services.
3. Legal framework and principles
Goldtech processes personal data in accordance with the applicable laws of the Republic of Panama, in particular Law 81 of March 26, 2019 on Personal Data Protection and its implementing regulation, Executive Decree 285 of May 28, 2021.
Processing is guided by the principles of fairness, purpose limitation, proportionality, truthfulness and accuracy, security, transparency, confidentiality, lawfulness and portability.
Only data that is appropriate and necessary for the stated purposes will be requested. Where data needs to be used for a different purpose, the relevant information will be provided and consent obtained where required.
4. Personal data we may collect
Depending on your relationship with Goldtech and the channels you use, we may process:
4.1. Identity and contact details
First and last name, email address, telephone number, company, job title and any other professional contact details you provide.
4.2. Enquiries and requests
Message content, requests for information, project requirements, contact preferences and documents submitted voluntarily.
4.3. Commercial and contractual information
Data needed to prepare proposals, manage orders, enter into contracts, issue invoices, process payments and provide the requested services.
4.4. Technical and support information
The requester's contact details, descriptions of issues and technical information needed to respond to a support request. Any third-party information provided must be limited to what is strictly necessary and covered by the appropriate authorisation or lawful basis.
4.5. Browsing data
The infrastructure that operates the website may generate technical logs, such as IP address, access date and time, requested pages, browser characteristics and security events. Processing must be limited to the website's operational, diagnostic and security needs.
We do not request sensitive data through our general contact channels. Please avoid sending passwords, access credentials, health data, full banking details or any other information that is not needed to handle your request.
5. Sources of personal data
Personal data may be obtained:
Directly from the individual, when contacting Goldtech or requesting our services.
From the organisation to which the individual belongs, where necessary to manage a professional or contractual relationship.
From authorised third parties, where there is a lawful basis for disclosure.
From technical logs generated through use of the website, as described in this policy.
Where applicable, additional information will be provided about the source and processing of data not obtained directly from the individual.
6. Purposes of processing
Goldtech may use personal data, as applicable, to:
Respond to enquiries and requests for information.
Prepare requested quotations, commercial proposals and demonstrations.
Manage business and contractual relationships.
Coordinate the delivery, implementation and support of products and services.
Administer orders, invoicing, payments and accounting obligations.
Maintain operational communications about contracted services.
Manage relationships with suppliers and business associates.
Protect the website and systems against unauthorised access, fraud and other incidents.
Handle requests to exercise rights, complaints and requests from authorities.
Comply with legal obligations and manage liabilities arising from our activities.
Send promotional information where consent or another applicable lawful basis exists.
Data will not be used for purposes incompatible with those stated without first obtaining the appropriate lawful basis.
7. Consent and lawful basis
Where required, Goldtech will obtain the individual's prior, informed and unambiguous consent before processing their personal data.
Data may also be processed without consent in circumstances permitted by law, including where necessary to perform a contractual relationship or comply with a legal obligation, provided the relevant conditions are met.
Consent may be withdrawn by emailing sales@goldtechholdings.com. Withdrawal will not affect processing lawfully carried out beforehand or prevent retention of data required by a legal obligation.
Simply browsing the website does not constitute consent to receive advertising or to processing that requires specific authorisation.
8. Marketing communications
Goldtech will send promotional communications with the recipient's authorisation or under another applicable lawful basis.
Recipients may ask for these communications to stop using the mechanism provided in the message or by emailing sales@goldtechholdings.com with the subject line “Unsubscribe from marketing communications”.
Communications necessary to respond to requests, provide services or manage contracts are not considered promotional communications.
9. Access to data and recipients
Access to personal data will be restricted to authorised personnel and those who need to process it for the purposes described.
Where necessary, the following parties may be involved:
Hosting, infrastructure and technology service providers.
Email and business management tool providers.
Administrative, accounting, legal and professional service providers.
Manufacturers, distributors and technology partners whose involvement is needed to respond to a request or provide a service.
Administrative or judicial authorities and other competent bodies, where there is a legal obligation or lawful basis.
Providers will be subject to the confidentiality, security and data protection obligations appropriate to their roles.
Goldtech will not sell personal databases or disclose information to third parties for their own advertising purposes without the appropriate authorisation or lawful basis.
10. International processing and transfers
Given the international nature of technology services, some providers or parties involved in delivering a service may be located outside Panama.
Where processing involves international transfers, Goldtech will verify that a legal condition permitting the transfer exists and put in place any required protection safeguards.
Where the individual's consent is required, relevant information about the transfer will be provided beforehand.
You may request information about transfers involving your personal data using the contact email provided in this policy.
11. Data retention
Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected and to meet the relevant legal obligations or liabilities.
The following criteria will apply:
Enquiries and requests for information: while they are being handled and for any reasonably necessary follow-up.
Proposals and negotiations: while the business opportunity remains active and for the period needed to address potential liabilities.
Contractual, accounting and invoicing information: for the duration of the relationship and the retention periods required by applicable law.
Support information: while the request is being handled and for the period needed to maintain service continuity and manage liabilities.
Data used for advertising: until consent is withdrawn, an unsubscribe request is received or the purpose justifying its use no longer exists.
Technical logs: for the period needed to operate, diagnose and secure systems.
Once retention is no longer necessary, data will be deleted, anonymised or kept with restricted access where a legal reason prevents its immediate deletion.
12. Security and confidentiality
Goldtech undertakes to apply technical and organisational measures appropriate to the nature of the data and the risks of processing, with the aim of preventing loss, alteration, misuse, disclosure or unauthorised access.
Security management includes access restrictions based on roles, confidentiality obligations, system protection and incident handling.
These measures will be reviewed and adapted to technological, operational and risk-related changes.
No system can guarantee absolute security. If an incident affects personal data, Goldtech will assess its consequences, take response measures and make any notifications required by applicable law.
To report a possible exposure or misuse of personal data, email sales@goldtechholdings.com with the subject line “Privacy — Incident”.
13. Individuals' rights
Under Panamanian law and the conditions applicable to each processing activity, individuals may exercise the following rights:
Access: to learn which personal data is processed, its source, purpose and any other relevant information.
Rectification: to request the correction of inaccurate, incomplete, outdated or irrelevant data.
Cancellation: to request deletion of data where applicable.
Objection: to refuse or request that processing cease in the circumstances provided by law.
Portability: to obtain a copy of data in a structured, generic and commonly used format, where the legal conditions are met.
Withdrawal of consent: to withdraw authorisation for processing that depends on consent.
Cancellation, objection or withdrawal will not prevent retention or use of data where a legal obligation or another applicable exception exists.
How to exercise your rights
Send a request to sales@goldtechholdings.com with the subject line “Exercise of personal data rights”, including:
First and last name.
The right you wish to exercise.
A clear description of your request.
Contact details for receiving a response.
If acting through a representative, evidence of their authority must be provided. Additional identification information will only be requested where necessary and proportionate.
Goldtech will handle requests within the deadlines established by Panamanian law. You do not need to purchase our services or agree to marketing communications to exercise these rights.
14. Enquiries and complaints to the authority
If you believe the processing of your personal data infringes your rights, you may contact Goldtech first, without limiting your right to approach the competent authority directly.
In Panama, the supervisory authority is the National Authority for Transparency and Access to Information — ANTAI — through its Personal Data Protection Directorate.
Website: https://www.antai.gob.pa.
Email: protecciondedatos@antai.gob.pa.
15. Cookies and similar technologies
The website may use cookies or other storage technologies to enable certain functions.
If analytics, advertising, tracking tools or third-party services requiring information or consent are introduced, the relevant notice will be provided and the necessary mechanisms enabled before they are used.
Users can manage cookies through their browser settings. Blocking certain technologies may affect how some website features work.
Simply visiting the website will not be interpreted as authorisation to activate technologies that require specific consent.
16. Third-party links and services
The website may contain links to pages or services managed by third parties.
This policy does not govern processing carried out by those third parties under their own responsibility. We recommend reviewing their privacy policies before providing them with personal information.
Where Goldtech engages a provider to process data on its behalf, that relationship will be subject to the relevant data protection obligations and will not be excluded by this provision.
17. Children's data
Goldtech's website and commercial offering are intended for businesses, organisations and adults.
We do not knowingly request personal data from children through the website's general channels.
If a parent, guardian or representative believes a child has provided data without the appropriate authorisation, they may contact the email address provided so that the situation can be assessed and appropriate action taken.
18. Updates to this policy
Goldtech may amend this Privacy Policy to reflect changes in legislation, technology or its processing activities.
The current version will be available on this page and will include its update date. Where a change requires new authorisation or a specific notification, this will be provided before the processing is carried out.
19. Contact
For any questions about this Privacy Policy or the processing of your personal data:
Goldtech Holdings INC.
Avenida Balboa, Edif. BAC, Torre Menor, Piso 4, Panama City, Panama.
Email: sales@goldtechholdings.com.
Website: https://goldtechholdings.com.