PRIVACY POLICY

Privacy Policy

EFFECTIVE DATE APRIL 23, 2026        ENTITY SILVERCREST TECH · PANAMA CITY, RP

01

Introduction

Silvercrest Tech is committed to protecting the privacy of our clients, website visitors, and business partners. This Privacy Policy describes how we collect, use, store, and protect personal data in accordance with Law 81 of 2019 on Personal Data Protection of the Republic of Panama and its implementing regulations.

02

Data controller

The data controller responsible for your personal data is Silvercrest Tech, Panama City, Republic of Panama. Privacy inquiries: [email protected].

03

Personal data we collect

Depending on the nature of your relationship with us, we may collect:

Identity data: Full legal name, date of birth, nationality, and government-issued identification;

Contact data: Email address, telephone number, and physical address;

Corporate data: Company name, registration number, jurisdiction, and beneficial ownership information;

Financial data: Bank account details, transaction history, and digital wallet addresses (as required for compliance);

Technical data: IP address, browser type, and website usage data collected via cookies;

Communication data: Records of correspondence and inquiries submitted through the Website.

04

Legal basis for processing

We process personal data on the following legal bases under Law 81 of 2019:

Contractual necessity: Processing required to enter into or perform a contract;

Legal obligation: Processing required to comply with Panamanian law, including AML/KYC regulations under Law 23 of 2015;

Legitimate interests: Processing necessary for fraud prevention, security, and business operations;

Consent: Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

05

How we use your data

To onboard you as a client and conduct KYC/AML verification;

To provide, manage, and improve our services;

To communicate with you regarding your inquiries and transactions;

To comply with legal and regulatory obligations;

To detect and prevent fraud and unauthorized access;

To analyze website usage for operational improvement.

06

Data sharing and disclosure

We do not sell personal data. We may share data with:

Regulatory authorities: Where required by Panamanian law, court order, or the Financial Analysis Unit (UAF);

Service providers: Third parties who process data on our behalf under confidentiality obligations;

Professional advisors: Legal counsel, auditors, and compliance consultants bound by professional secrecy;

Transaction counterparties: Only the minimum data necessary to facilitate a specific transaction.

We do not sell personal data. We may share data with:

07

Data retention

We retain personal data for as long as necessary for the purposes collected and in accordance with legal requirements. Under Panamanian AML regulations, identity and transaction records are retained for a minimum of five years from the end of the business relationship. Technical and website data is retained for up to two years.

08

Your rights under Law 81 of 2019

Access (Habeas Data): Request confirmation and a copy of personal data we hold about you;

Rectification: Request correction of inaccurate or incomplete data;

Cancellation / Erasure: Request deletion where data is no longer necessary, subject to legal retention obligations;

Opposition: Object to processing based on legitimate interest;

Withdrawal of consent: Withdraw consent at any time where processing is consent-based.

To exercise these rights, contact us at [email protected]. We will respond within the timeframes required by Law 81 of 2019.

09

Cookies

Our Website uses cookies to improve user experience and analyze traffic. You may configure your browser to refuse cookies, though this may affect certain functionality. We do not use cookies for advertising purposes.

10

Data security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, or loss. In the event of a breach posing risk to your rights, we will notify you and the relevant Panamanian authority as required by Law 81 of 2019.

11

Changes to this policy

We may update this Privacy Policy periodically. Updated versions will be published on the Website with a revised effective date. We recommend reviewing this Policy regularly.

12

Contact

Privacy inquiries and complaints: [email protected] · Silvercrest Tech, Panama City, Republic of Panama. You also have the right to lodge a complaint with the competent Panamanian data protection authority.