DATA PROTECTION

We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of Pafru Internacional S.A. The use of the websites of Pafru Internacional S.A. is generally possible without providing any personal data. However, if a data subject wants to make use of special services of our company through our website, the processing of personal data may be necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address, or phone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to Pafru Internacional S.A. With this privacy policy, our company aims to inform the public about the type, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects will be informed about their rights through this privacy policy.

Pafru Internacional S.A., as the data controller, has implemented numerous technical and organizational measures to ensure the most complete protection possible of the personal data processed through this website. However, internet-based data transmissions may fundamentally have security vulnerabilities, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, such as by phone.

1. DEFINITIONS

The privacy policy of Pafru Internacional S.A. is based on the terminology used by the European legislator when enacting the General Data Protection Regulation (GDPR). Our privacy policy aims to be easily readable and understandable for both the public and our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this privacy policy, we use, among others, the following terms:

  • a)    personal data

    Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is considered to be one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

  • b)    data subject

    The data subject is any identified or identifiable natural person whose personal data is processed by the controller.

  • c)    processing

    Processing is any operation or set of operations which is performed on personal data, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, aligning or combining, restricting, erasing, or destroying.

  • d)    restriction of processing

    Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

  • e)    profiling

    Profiling is any form of automated processing of personal data that consists of using personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.

  • f)    pseudonymization

    Pseudonymization is the processing of personal data in a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separate and is subjected to technical and organizational measures that ensure that the personal data is not attributed to an identified or identifiable natural person.

  • g)    controller or processing controller

    Controller or processing controller is the natural or legal person, public authority, agency, or other body that alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or controllers may be designated, or the specific criteria for their designation may be provided for by Union law or the law of the Member States.

  • h)    processor

    Processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

  • i)    recipient

    Recipient is a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the course of a particular inquiry in accordance with Union law or the law of the Member States shall not be regarded as recipients.

  • j)    third party

    Third party is a natural or legal person, public authority, agency, or another body, other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

  • k)    consent

    Consent is any freely given, specific, informed, and unambiguous indication of the data subject's wishes, by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

  1. NAME AND ADDRESS OF THE DATA PROCESSOR

Responsible in the sense of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions with data protection character is:

Pafru Internacional S.A.
Rustic Plaza Office No. #09
Barrio San José, Alajuela
Costa Rica

E-Mail: contact@pafru.com
Website: www.pafru.com

  1. COOKIES

The websites of Pafru Internacional S.A. use cookies. Cookies are text files that are stored on a computer system via an internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string through which websites and servers can assign the specific internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the affected person from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified by the unique cookie ID.

Through the use of cookies, Pafru Internacional S.A. can provide users of this website with more user-friendly services that would not be possible without setting cookies.

Using a cookie, the information and offers on our website can be optimized in the interest of the user. Cookies allow us, as mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. A user of a website that uses cookies does not have to enter their login details again on each visit to the website because this is handled by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The affected person can prevent the setting of cookies by our website at any time by means of a corresponding setting in the internet browser used and thereby permanently object to the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the affected person disables the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

  1. COLLECTION OF GENERAL DATA AND INFORMATION

The website of Pafru Internacional S.A. collects a series of general data and information with each access to the website by an affected person or an automated system. This general data and information is stored in the server's log files. The following can be collected: (1) the types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to provide safety in the event of attacks on our information technology systems.

When using this general data and information, Pafru Internacional S.A. does not draw conclusions about the affected person. This information is rather necessary to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website, and (4) provide law enforcement agencies with the information necessary for prosecution in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by Pafru Internacional S.A. both statistically and with the aim of increasing data protection and data security in our company to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data from the server log files are stored separately from all personal data provided by an affected person.

  1. CONTACT OPTIONS VIA THE WEBSITE

The website of Pafru Internacional S.A. contains information due to legal regulations that allows for quick electronic contact with our company as well as immediate communication with us, which also includes a general address for so-called electronic mail (email address). If an affected person contacts the person responsible for processing by email or through a contact form, the personal data transmitted by the affected person will be automatically stored. Such personal data voluntarily provided by an affected person to the person responsible for processing will be stored for purposes of processing or contacting the affected person. No disclosure of this personal data to third parties will take place.

  1. Routine deletion and blocking of personal data

The data controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purposes or as required by the European legislator or another legislator in laws or regulations to which the data controller is subject.

If the storage purpose ceases or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will routinely be blocked or deleted in accordance with legal requirements.

  1. RIGHTS OF THE DATA SUBJECT

a)    Right to Confirmation

Every data subject has the right granted by the European legislator to request confirmation from the controller of the processing as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they can contact an employee of the controller at any time.

  • b)    Right to Access

    Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, free of charge, information at any time about the personal data concerning them stored and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

    • the purposes of processing

    • the categories of personal data being processed

    • the recipients or categories of recipients to whom the personal data have been disclosed or are still to be disclosed, particularly recipients in third countries or international organizations

    • if possible, the planned duration for which the personal data will be stored, or, if that is not possible, the criteria for determining such duration

    • the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or of a right to object to such processing

    • the existence of a right to lodge a complaint with a supervisory authority

    • if the personal data are not collected from the data subject: all available information about the source of the data

    • the existence of automated decision-making, including profiling, according to Article 22 paragraphs 1 and 4 GDPR and — at least in these cases — meaningful information about the logic involved as well as the significance and the intended consequences of such processing for the data subject

    Furthermore, the data subject has the right to know whether personal data have been transferred to a third country or to an international organization. If this is the case, the data subject has the right to obtain information about the appropriate safeguards in connection with the transfer.

    If a data subject wishes to exercise this right to access, they can contact an employee of the controller at any time.

  • c)    Right to Rectification
    Every data subject affected by the processing of personal data has the right granted by the European legislator to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request, taking into account the purposes of processing, the completion of incomplete personal data — including by means of a supplementary statement.

    If a data subject wishes to exercise this right to rectification, they can contact an employee of the controller at any time.

  • d)    Right to Erasure (Right to be Forgotten)
    Every data subject affected by the processing of personal data has the right granted by the European legislator to request from the controller the immediate deletion of personal data concerning them, provided that one of the following reasons applies and as long as processing is not necessary:

    • The personal data have been collected for such purposes or have been processed in any other manner, for which they are no longer necessary.

    • The data subject withdraws their consent on which the processing is based according to Art. 6 paragraph 1 letter a GDPR or Art. 9 paragraph 2 letter a GDPR, and there is no other legal basis for the processing.

    • The data subject objects to the processing according to Art. 21 paragraph 1 GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects according to Art. 21 paragraph 2 GDPR against the processing.

    • The personal data have been processed unlawfully.

    • The deletion of personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.

    • The personal data were collected in relation to the services of the information society according to Art. 8 paragraph 1 GDPR.

    If one of the above-mentioned reasons applies and a data subject wishes to request the deletion of personal data stored at Pafru Internacional S.A., they can contact an employee of the controller at any time. The employee of Pafru Internacional S.A. will ensure that the deletion request is complied with without delay.

    If personal data have been made public by Pafru Internacional S.A. and our company is obliged as controller according to Art. 17 paragraph 1 GDPR to delete the personal data, Pafru Internacional S.A. will take appropriate measures, taking into account available technology and the implementation costs, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure of all links to such personal data or of copies or replications of such personal data, as long as processing is not necessary. The employee of Pafru Internacional S.A. will arrange for the necessary measures in each case.

  • e)    Right to Restrict Processing
    Every data subject affected by the processing of personal data has the right granted by the European legislator to request the restriction of processing from the controller if one of the following conditions is met:

    • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

    • The processing is unlawful, the data subject opposes the deletion of the personal data and requests instead the restriction of the use of the personal data.

    • The controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the establishment, exercise or defense of legal claims.

    • The data subject has lodged an objection to the processing according to Art. 21 paragraph 1 GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

    If one of the above-mentioned conditions applies and a data subject wishes to request the restriction of personal data stored at Pafru Internacional S.A., they can contact an employee of the controller at any time. The employee of Pafru Internacional S.A. will arrange for the restriction of processing.

  • f)     Right to Data Portability
    Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which they provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to whom the personal data were provided, provided that the processing is based on consent according to Art. 6 paragraph 1 letter a GDPR or Art. 9 paragraph 2 letter a GDPR or on a contract according to Art. 6 paragraph 1 letter b GDPR and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller.

    Furthermore, the data subject has the right to obtain, when exercising their right to data portability according to Art. 20 paragraph 1 GDPR, that the personal data are transmitted directly from one controller to another controller, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

    To assert the right to data portability, the data subject can contact an employee of Pafru Internacional S.A. at any time.

  • g)    Right to Object
    Every data subject affected by the processing of personal data has the right granted by the European legislator to object at any time to the processing of personal data concerning them, which is based on Article 6(1)(e) or (f) GDPR, for reasons relating to their particular situation. This also applies to profiling based on these provisions.

    Pafru Internacional S.A. will no longer process personal data in the event of such an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing is for the establishment, exercise or defense of legal claims.

    If Pafru Internacional S.A. processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purposes of such marketing. This also applies to profiling, to the extent it is related to such direct marketing. If the data subject objects to Pafru Internacional S.A. regarding the processing for direct marketing purposes, Pafru Internacional S.A. will no longer process the personal data for these purposes.

    Furthermore, the data subject has the right to object, for reasons relating to their particular situation, to the processing of personal data concerning them which takes place at Pafru Internacional S.A. for scientific or historical research purposes or for statistical purposes according to Art. 89 paragraph 1 GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

    To exercise the right to object, the data subject can contact any employee of Pafru Internacional S.A. directly or any other employee. The data subject is also free to exercise their right to object in connection with the use of information society services, irrespective of Directive 2002/58/EC, using automated procedures in which technical specifications are employed.

  • h)    Automated Individual Decision-Making, Including Profiling
    Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — that produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is permissible under Union or Member State law to which the controller is subject and which also establishes suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject's explicit consent.

    If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is made with the explicit consent of the data subject, Pafru Internacional S.A. will implement appropriate measures to protect the rights and freedoms and legitimate interests of the data subject, which at a minimum include the right to obtain human intervention on the part of the controller, to present their own viewpoint and to contest the decision.

    If the data subject wishes to assert rights regarding automated decisions, they can contact an employee of the controller at any time.

  • i)      Right to Withdraw a Data Protection Consent

    Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw their consent to the processing of personal data at any time.

    If the data subject wishes to exercise their right to withdraw consent, they can contact an employee of the controller at any time.

  1. DATA PROTECTION IN APPLICATIONS AND IN THE APPLICATION PROCESS

The data controller collects and processes the personal data of applicants for the purpose of carrying out the application procedure. Processing may also be carried out electronically. This is particularly the case when an applicant submits the appropriate application documents electronically, for example by email or via a web form on the website, to the data controller. If the data controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of managing the employment relationship in accordance with legal regulations. If no employment contract is concluded by the data controller with the applicant, the application documents will be automatically deleted two months after the notification of the rejection decision, provided that there are no other legitimate interests of the data controller opposing deletion. Other legitimate interests in this sense may include a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

  1. DATA PROTECTION PROVISIONS FOR THE USE AND APPLICATION OF GOOGLE ADSENSE

The data controller has integrated Google AdSense on this website. Google AdSense is an online service that enables the placement of advertisements on third-party websites. Google AdSense is based on an algorithm that selects the advertisements displayed on third-party sites to match the content of those respective sites. Google AdSense allows for interest-based targeting of internet users, which is implemented by generating individual user profiles.

The operator of the Google AdSense component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of the Google AdSense component is to incorporate advertisements on our website. Google AdSense sets a cookie on the information technology system of the affected person. What cookies are has already been explained above. By setting the cookie, Alphabet Inc. is enabled to analyze the use of our website. With each call of one of the individual pages of this website, which is operated by the data controller and on which a Google AdSense component has been integrated, the internet browser on the affected person's information technology system is automatically prompted by the respective Google AdSense component to transmit data for the purposes of online advertising and the billing of commissions to Alphabet Inc. As part of this technical process, Alphabet Inc. gains knowledge of personal data, such as the IP address of the affected person, which is used by Alphabet Inc. among other things to trace the origin of visitors and clicks and consequently enable commission billing.

The affected person can prevent the setting of cookies by our website, as described above, at any time by means of a corresponding setting in the web browser used and thus permanently object to the setting of cookies. A corresponding setting in the web browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the affected person. In addition, a cookie already set by Alphabet Inc. can be deleted at any time via the internet browser or other software programs.

Google AdSense also uses so-called counting pixels. A counting pixel is a miniature graphic embedded in web pages to enable log file recording and log file analysis, allowing for statistical evaluation. Based on the embedded counting pixel, Alphabet Inc. can determine whether and when a web page has been opened by an affected person and which links have been clicked by the affected person. Counting pixels serve, among other things, to evaluate the flow of visitors to a website.

Personal data and information, which also includes the IP address and is necessary for collecting and billing the displayed advertisements, is transmitted to Alphabet Inc. in the United States of America via Google AdSense. This personal data is stored and processed in the United States of America. Under certain circumstances, Alphabet Inc. shares these personal data collected via the technical process with third parties.

Google AdSense is explained in more detail at this link https://www.google.de/intl/de/adsense/start/.

  1. PRIVACY POLICY ON THE USE AND APPLICATION OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

The data controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analytics service collects data about, among other things, which website a data subject came from (so-called referrer), which subpages of the website were accessed, or how often and for what duration a subpage was viewed. Web analytics is primarily used for optimizing a website and for cost-benefit analysis of online advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The data controller uses the addition "_gat._anonymizeIp" for web analytics via Google Analytics. This addition shortens and anonymizes the IP address of the internet connection of the affected person by Google when accessing our websites from a member state of the European Union or from another contracting state of the Agreement on the European Economic Area.

The purpose of the Google Analytics component is the analysis of the visitor flows on our website. Google uses the data and information obtained for, among other things, evaluating the use of our website, compiling online reports that illustrate the activities on our websites, and providing further services related to the use of our website.

Google Analytics places a cookie on the information technology system of the affected person. What cookies are has already been explained above. By setting the cookie, Google enables an analysis of the usage of our website. With each call of an individual page of this website operated by the data controller and on which a Google Analytics component is integrated, the internet browser on the information technology system of the affected person is automatically prompted by the respective Google Analytics component to transmit data for the purpose of online analysis to Google. In the course of this technical process, Google becomes aware of personal data, such as the IP address of the affected person, which Google uses among other things to trace the origin of visitors and clicks and subsequently enable commission settlements.

Cookies store personal information, such as access time, the location from which access was made, and the frequency of visits to our website by the affected person. During each visit to our websites, this personal data, including the IP address of the internet connection used by the affected person, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical process to third parties under certain circumstances.

The affected person can prevent the setting of cookies by our website as described above at any time by means of a corresponding setting of the web browser used and thereby permanently object to the setting of cookies. Such a setting of the web browser used would also prevent Google from setting a cookie on the information technology system of the affected person. Furthermore, any cookie already set by Google Analytics can be deleted at any time via the web browser or other software programs.

Additionally, the affected person has the option of objecting to the collection of data generated by Google Analytics that relate to the use of this website and to prevent such processing of data by Google. For this, the affected person must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about the visits to webpages may be transmitted to Google Analytics. The installation of the browser add-on is considered a rejection by Google. If the information technology system of the affected person is deleted, formatted, or reinstalled at a later time, the affected person must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or disabled by the affected person or by another person for whom they are responsible, the possibility of reinstalling or reactivating the browser add-on exists.

Further information and the applicable privacy policies of Google can be retrieved at https://www.google.de/intl/en/policies/privacy/ and at http://www.google.com/analytics/terms/en.html. Google Analytics is further explained at this link https://www.google.com/intl/en_us/analytics/.

  1. PRIVACY POLICY FOR THE USE AND APPLICATION OF GOOGLE REMARKETING

The data controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that allows a company to display advertisements to users who have previously visited the company's website. The integration of Google Remarketing allows a company to create user-related advertisements and consequently display interest-based ads to the internet user.

The company operating the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is to display interest-based advertising. Google Remarketing enables us to show advertisements through the Google advertising network or have them displayed on other websites tailored to the individual needs and interests of internet users.

Google Remarketing places a cookie on the information technology system of the affected person. What cookies are has already been explained above. By setting the cookie, Google enables recognition of the visitor to our website when they subsequently access websites that are also members of the Google advertising network. With each access to a website on which the Google Remarketing service has been integrated, the internet browser of the affected person automatically identifies itself to Google. As part of this technical process, Google gains knowledge of personal data such as the IP address or browsing behavior of the user, which Google uses, among other things, to display interest-based advertising.

Using the cookie, personal information, such as the websites visited by the affected person, is stored. Therefore, with each visit to our websites, personal data, including the IP address of the internet connection used by the affected person, is transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties under certain circumstances.

The affected person can prevent the setting of cookies by our website, as described above, at any time by means of a corresponding setting in the web browser used, thus permanently objecting to the setting of cookies. Such a setting in the web browser used would also prevent Google from placing a cookie on the information technology system of the affected person. In addition, a cookie already set by Google Analytics can be deleted at any time via the web browser or other software programs.

Furthermore, the affected person has the option to object to interest-based advertising by Google. For this, the affected person must access the link www.google.de/settings/ads from each of the web browsers they use and make the desired settings there.

More information and the applicable privacy policy of Google can be accessed at https://www.google.de/intl/en/policies/privacy/.

  1. DATA PROTECTION POLICY FOR THE USE AND APPLICATION OF GOOGLE ADWORDS

The data controller has integrated Google AdWords on this website. Google AdWords is a service for online advertising that allows advertisers to display advertisements in both the Google search results and the Google advertising network. Google AdWords enables an advertiser to set predefined keywords, under which an advertisement will only be displayed in the Google search results when the user retrieves a search result that is relevant to the keywords. In the Google advertising network, advertisements are distributed across topic-relevant websites by an automated algorithm while considering the previously set keywords.

The operating company of the Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is to promote our website by displaying interest-relevant advertising on the websites of third-party companies and in the search results of the Google search engine, as well as displaying third-party advertising on our website.

If an affected person accesses our website through a Google ad, a so-called conversion cookie will be placed on the affected person's information technology system by Google. What cookies are has been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the affected person. Through the conversion cookie, as long as the cookie has not yet expired, it can be tracked whether certain subpages, such as the shopping cart of an online shop system, have been accessed on our website. Both we and Google can track whether an affected person who has reached our website via an AdWords ad generated a sale, meaning whether a purchase was completed or aborted.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are then used by us to determine the total number of users who have been referred to us through AdWords ads, in order to assess the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other advertisers of Google AdWords receive information from Google that could identify the affected person.

Through the conversion cookie, personal information, such as the websites visited by the affected person, is stored. Thus, with each visit to our websites, personal data, including the IP address of the internet connection used by the affected person, are transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass this personal data collected through the technical process on to third parties under certain circumstances.

The affected person can prevent the setting of cookies through our website, as outlined above, at any time by adjusting the settings of the internet browser used and thereby permanently objecting to the setting of cookies. Such a setting of the internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the affected person. Furthermore, any cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.

Furthermore, the affected person has the option to object to interest-based advertising by Google. For this, the affected person must access the link www.google.de/settings/ads from each of the internet browsers they use and make the desired settings there.

Further information and the applicable privacy policy from Google can be accessed at https://www.google.de/intl/de/policies/privacy/.

  1. LEGAL BASIS FOR PROCESSING

Article 6(1)(a) of the GDPR serves as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations required for the delivery of goods or the provision of other services or consideration, the processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations that are necessary to carry out pre-contractual measures, such as in cases of inquiries about our products or services. If our company is subject to a legal obligation that makes the processing of personal data necessary, such as to fulfill tax obligations, the processing is based on Article 6(1)(c) of the GDPR. In rare cases, processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises, and subsequently, their name, age, health insurance details, or other vital information had to be disclosed to a doctor, a hospital, or other third parties. In such cases, processing would be based on Article 6(1)(d) of the GDPR. Ultimately, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis applies to processing operations that are not covered by any of the aforementioned legal bases, when the processing is necessary for the purposes of legitimate interests pursued by our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not override those interests. Such processing operations are especially permitted to us because they were specifically mentioned by the European legislator. He held the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 of the GDPR).

  1. LEGITIMATE INTERESTS IN THE PROCESSING PURSUED BY THE RESPONSIBLE PARTY OR A THIRD PARTY

If the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is to conduct our business activities for the benefit of all our employees and our shareholders.

  1. DURATION FOR WHICH PERSONAL DATA IS STORED

The criterion for the duration of storage of personal data is the respective statutory retention period. Upon expiration of the period, the corresponding data will be routinely deleted, unless they are no longer necessary for the fulfillment of the contract or for the initiation of a contract.

  1. LEGAL OR CONTRACTUAL PROVISIONS FOR THE PROVISION OF PERSONAL DATA, REQUIREMENT FOR CONTRACT CONCLUSION, OBLIGATION OF THE DATA SUBJECT TO PROVIDE PERSONAL DATA, POSSIBLE CONSEQUENCES OF NON-PROVISION

We inform you that the provision of personal data is partly legally required (e.g., tax regulations) or may also arise from contractual agreements (e.g., information about the contractual partner). Sometimes, it may be necessary for a contract to be concluded that an affected person provides us with personal data that must then be processed by us. The affected person is, for example, obliged to provide us with personal data when our company enters into a contract with them. Not providing the personal data would mean that the contract with the affected person could not be concluded. Before providing personal data, the affected person must contact one of our employees. Our employee will inform the affected person on a case-by-case basis whether the provision of personal data is legally or contractually required or necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences the non-provision of the personal data would have.

  1. EXISTENCE OF AUTOMATED DECISION-MAKING

As a responsible company, we refrain from automated decision-making or profiling.

  1. ADDITIONAL FOR COSTA RICA

Pafru Internacional S.A. is based in Costa Rica. In addition to the GDPR, the processing of personal data is also governed by the Costa Rican Data Protection Law No. 8968 ("Ley de Protección de la Persona frente al Tratamiento de sus Datos Personales").

Last updated: September 15, 2025