PRIVACY AND DATA PROTECTION POLICY

This policy (hereinafter, the "Privacy Policy") describes the types of personal data that VICUÑA Corp. and its affiliated companies (hereinafter "VICUÑA") (hereinafter referred to as "VICUÑA") collects from You, through the website www.vicuna.com (hereinafter, the "Website") as well as through all our other communication channels, including our different profiles in social networks and through your registration and participation in the different face-to-face or online events that we organize over time (all together with the Website, the "Services").

 We describe how we process your data, to whom we disclose it, and the rights and choices we make available to you regarding our use of your personal data and the exercise of your rights.

 At the same time, we describe the measures implemented to protect the security of personal data collected and how users can contact us to learn about our privacy practices. Accordingly, this Privacy Policy applies to all personal data that VICUÑA collects from you, directly or automatically, through or in connection with the Services.

 VICUÑA is responsible for the processing of your personal data.

 You expressly, informed, voluntary and unequivocal consent to the processing of your personal data by VICUÑA, in accordance with the terms of this Privacy Policy.

 The Website is not directed to children under the age of 18. If you are under 18 years of age, you should not use the Website or provide us with your personal data, except with the express authorization and consent of your parents or legal representatives.

 BY ACCESSING, LOGGING IN OR OTHERWISE USING THE WEB SITE, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD, CONSENT TO AND AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY.

 IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE WEB SITE.

 This privacy statement applies to the collection and processing of personal data: during the core operation of this website and other business activities of VICUÑA:

 - in the context of a business, pre-contractual or contractual relationship with you or your employer;

- by a local or foreign entity that is contractually bound to VICUÑA

-in the context of a registration form when you directly collect personal data for the purpose of registration for a service or event and therefore present yourself as the relevant controller on this registration page or website by referring to this privacy statement.

-in the context of CV uploading in the "Work with us" and "Opportunities" links.

 In conducting business and operating our various web presences and other communication channels, VICUÑA processes personal data of the people with whom it interacts, including customers, partners, suppliers, candidates and anyone else with whom it interacts.

 In any of these cases, VICUÑA may process personal data for one or more of the following business purposes:

Establishing business relationships with customers, partners, suppliers, subcontractors and others: VICUÑA processes personal data to maintain its business relationships with customers, partners and other users in order to fulfill pre-contractual and contractual business relationships. This may include fulfilling requests for information, processing inquiries, collecting data from suppliers, or customers, or engaging in any other action relevant to establishing, fulfilling and maintaining our business relationships.

 VICUÑA may use your personal data to:

 To provide the products and/or services offered by the Web Site.

 Provide information and/or answer queries related to the activities developed by VICUÑA.

 To confirm the opening of an account, manage contract performance, send you disclosures as required by law, payment notifications and other information about our products and services.

 Improve our initiatives and analyze the pages visited, the searches performed by users, to improve our information offer, personalize such contents, their presentation and services. Respond to related queries and process your comments.

 To carry out all types of promotional activities, including, but not limited to, sending newsletters, bulletins, direct messages, and/or brochures.

 Evaluate you as a candidate if you have provided your CV.

 Customer satisfaction: in an existing business relationship between you or your employer and VICUÑA, VICUÑA processes your personal data to provide you with or request feedback or relevant information about VICUÑA's tasks and services that is relevant and useful.

 Develop products and services.

 To the extent permitted by applicable law, VICUÑA may process your personal data for internal research, demonstrations and technological development and to help VICUÑA create, develop, operate, offer, improve or update VICUÑA's products, services or management processes. VICUÑA may process personal data to create anonymous data sets.

 VICUÑA processes personal data to comply with legal obligations, in order to ensure an adequate level of technical and organizational security of VICUÑA's products, services, online events and facilities. To this end, VICUÑA will take the necessary measures to verify or maintain the quality and safety of products or services that are owned, manufactured by VICUÑA or controlled by VICUÑA. This may include the use of personal data for sufficient identification and authorization of designated users, internal quality control through audits, analysis and investigations, debugging to identify and repair errors affecting existing or intended functionality, account and network security, replication for loss prevention, detection of security incidents, protection against malicious, deceptive, fraudulent or illegal activity, and prosecution of those responsible for this type of activity.

 If necessary, VICUÑA uses personal data to prevent or prosecute criminal activities, such as any form of cybercrime, illegal use of our products and services or fraud, to enforce our rights or defend VICUÑA from legal claims.

 Improving the user experience. VICUÑA processes information related to your visit to our web offerings to improve your user experience, identify your individual or corporate demand and personalize the way we provide you with the information you are looking for. To this end, we collect information regardless of whether you have registered with a user profile or not.

 Talent Search: VICUÑA may collect and process personal data of qualified individuals and persons interested in our professional opportunities from various sources. Applicants and candidates are requested to apply and VICUÑA collects personal data through the Career Portal for the purpose of application procedures and screening applicants.

 Keep you updated. In an existing business relationship between you or your employer and VICUÑA, VICUÑA processes your personal data to inform you about VICUÑA's activities. VICUÑA will inform you by e-mail or telephone about such news only to the extent permitted by law, or if VICUÑA has collected such information in the context of the business relationship. You have the right to object to the use of VICUÑA for this purpose at any time by selecting the opt-out option at the bottom of each marketing-related procedure.

 Advertising ID. Provided that you have given your consent or to the extent permitted by applicable law, VICUÑA may create an encrypted user ID to provide to social networks operated by third parties or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google). This information is compared with the third party's own user database to show you more relevant VICUÑA content.

 What personal data does VICUÑA process?

 VICUÑA processes various types of personal data about the people we interact with in running our business or operating our various web presences and other communication channels.

 Depending on the individual case, this may include the following types of personal data:

 Contact information.

VICUÑA processes the following categories of personal data as contact data: first name, last name, e-mail addresses, postal address/location (country, state/province, city), telephone numbers and your history of dealings with VICUÑA.

 Personal data related to the commercial relationship with VICUÑA.

 In the context of established business relationships, VICUÑA processes the company name, industry, position and role, department and function of business partners and your company's relationship history with VICUÑA. If you provide a credit card number or bank details in connection with any engagement with VICUÑA, VICUÑA will collect this information for processing in connection with that engagement and future engagements.

 Personal data related to compliance.

 If required by law or legal regulation, VICUÑA may process categories of data such as date of birth, academic credentials, identity cards or other ID numbers, geolocation, relevant business partner information on, for example, significant litigation or other legal proceedings, and other information relevant to customized compliance or export control.

 Data generated through your use of or participation in the Internet pages, the VICUÑA online website.

 You authorize VICUÑA to process certain user-related information, for example, information related to your browser, operating system or IP address when you visit VICUÑA web properties. We also process information related to your use of our websites, such as the pages you visit, the amount of time you spend on a page, the page that referred you to our site, and the links you select on our sites.

 Registration Data. VICUÑA may process your contact details as set out above and other information that you may provide directly to VICUÑA if you register for any of VICUÑA's events or other web services.

 Participation Data. When you participate in webinars, webinars, events or other VICUÑA web services, VICUÑA may process your interactions with the relevant web service to organize the event, including your sessions, surveys or other interactions between VICUÑA and/or its participants. Depending on the event and subject to appropriate notification to participants, VICUÑA may collect audio and video recordings of the event or session.

 Links to other websites:

 The Website may contain links to other websites for your convenience and information. Those sites may be operated by companies that are not affiliated with VICUÑA. Typically, linked websites have their own privacy policies or notices, which you should read if you visit them. We assume no responsibility for the content of websites other than ours, nor for the use made of such websites, nor for their privacy practices. You access these links at your own risk. We recommend that you read the privacy policies and terms and conditions of those sites.

 With whom do we share your data?

 The data we collect may be shared with third parties as described in this Privacy Policy.

 Service Providers. We share information with other companies that we hire to provide services to us or to provide services on our behalf, following our instructions and in accordance with the provisions of this Privacy Policy. These Service Providers access the information necessary to provide the agreed services, and may not use such information for purposes other than those agreed with VICUÑA.

 Public authorities. We share information with administrative and judicial authorities that, in the exercise of their jurisdiction, require information from VICUÑA, our service providers and/or our business partners, even if there is no executive or judicial order or subpoena to that effect, for the purposes of: (a) collaborating in the investigation and reporting of fraud, piracy, intellectual or industrial property violations or any other illicit activity, as well as any activity or circumstance that could generate legal liability for VICUÑA and/or its users; (b) safeguarding a public interest, the procurement or administration of justice, the recognition, exercise or defense of a right in a judicial or administrative process, and/or the resolution of disputes; and (c) complying with any applicable law, regulation or legal provision, or any mandate from a competent authority duly founded and motivated.

 On the other hand, we also share information to: (a) protect and defend our rights or property; (b) protect the personal safety of our employees or agents, or members of the public; and/or (c) protect the integrity of the online community of our services.

 Judicial, government and conflict resolution officials. We share information with authorities, amiable compositeurs, courts or entities involved in dispute resolution in order to resolve disputes that may arise.

 Likewise, VICUÑA may share your personal data to entities or third parties when there are sufficient grounds to consider that your activity is suspected of attempting or committing a crime or attempting to harm others.

 In the event that you disclose personal information through the use of our services, communities, forums, events, chats, webinars and messaging features or other social or interactive features, this information may be collected, used and disclosed by third parties over whom VICUÑA has no control or responsibility.

 Security of your personal data.

 The data collected will be kept confidential and reserved. VICUÑA will only use the data for the purposes and in the manner informed in this Privacy Policy. VICUÑA complies with personal data protection regulations and, in particular, with Law No. 25,326 and its complementary regulations such as, for example, Resolution No. 47/2018 (hereinafter, the "Personal Data Protection Regulations"). To ensure the security of the personal data that You provide to VICUÑA, the same criteria and the same degree of diligence that VICUÑA applies to safeguard its own information will be applied.

 However, you acknowledge that existing technical means of providing security are not foolproof, and that even when all reasonable security precautions are taken, it is possible to suffer tampering, destruction and/or loss of information.

 VICUÑA processes your personal data only for as long as necessary:

  -in order for VICUÑA to comply with legal obligations to retain personal data, such as, for example, applicable export, financial, tax or commercial laws;

- to fulfill VICUÑA's legitimate business purposes as described in this Privacy Policy, unless you object to VICUÑA using your personal data for these purposes;

- until you revoke the consent previously granted to VICUÑA to process your personal data.

VICUÑA may process your personal data for product or service development until it is no longer necessary or until VICUÑA is informed that your relationship with VICUÑA's customer has changed.

VICUÑA may retain your personal data for additional periods if necessary to comply with legal obligations to process your personal data or if VICUÑA needs the personal data to defend itself against legal claims. VICUÑA will retain your personal data until the end of the relevant retention period or until the claims in question have been resolved.

 What are your data protection rights?

 Right to access, correct and delete. You may ask VICUÑA, at any time, for access to information about which of your personal data it processes and, if necessary, to correct or delete such personal data. However, VICUÑA may delete your personal data, and will do so, only if VICUÑA has no legal obligation or enforceable right to retain it. If you request that VICUÑA delete your personal data, you will no longer be able to use any VICUÑA service that requires the use of your personal data.

 Right to receive personal data from VICUÑA. If VICUÑA uses your personal data in reliance on your consent or to fulfill a contract with you, you may ask VICUÑA for a copy of the personal data you provided to VICUÑA. In this case, please send an email to dataprivacy@vicuna.com and specify the information or processing activities related to your request. VICUÑA will carefully consider your request and discuss with you how best to deal with it.

 How can you exercise your data protection rights?

 VICUÑA presumes and you guarantee the veracity of all information provided by you. Consequently, VICUÑA does not verify, nor does it assume the obligation to verify the veracity, validity, sufficiency, legality and authenticity of the data you provide. You assume the responsibility to keep such information updated at all times.

 You may access, modify, delete and update your personal data at any time you wish by contacting us as set forth in the following sections.

You may access the information you provided to VICUÑA, free of charge, at intervals of no less than six months, unless you can prove a legitimate interest to that effect, in accordance with the provisions of the Personal Data Protection Regulations.

If your data is incorrect, you wish to update and/or delete it, we will correct, update and/or delete that information at your request at no cost. To exercise your rights of access, rectification, updating or deletion, as provided in the Personal Data Protection Regulations, you must send an email to dataprivacy@vicuna.com indicating which right you want to exercise and proving your identity.

The information provided by you will be stored for as long as the relationship with VICUÑA is in force and also to fulfill other legitimate purposes for which VICUÑA must keep your personal data. Your information will also be retained if required by applicable law, even after the termination of your relationship with VICUÑA.

 THE AGENCY OF ACCESS TO PUBLIC INFORMATION, in its capacity as Control Agency of Law No. 25.326, is responsible for dealing with complaints and claims filed by those whose rights are affected by non-compliance with the regulations in force regarding the protection of personal data.

 How will VICUÑA verify requests to exercise data protection rights?

 VICUÑA will take steps to ensure that it verifies your identity to a reasonable degree of certainty before processing the data protection right you wish to exercise. If possible, VICUÑA will compare the personal data you provided when submitting a request to exercise your rights with information already updated by VICUÑA. This may include comparing two or more data points you provide when submitting a request with two or more data points already updated by VICUÑA.

 VICUÑA will refuse to process requests that are manifestly unfounded, excessive, fraudulent, represented by third parties without duly representing the corresponding authority or that are not required by local law.

 Updates to this Privacy Policy.

 VICUÑA may modify or update this Privacy Policy at any time without prior notice, to reflect changes in our personal data practices, as required by current legislation, and in particular the Personal Data Protection Regulation, or to reflect changes in our own policies. In the case of material changes, we will inform you by posting them on the Web Site. Any changes to this Privacy Policy will be effective from the time of its publication.

 For all purposes of this Privacy Policy, you agree to submit to the jurisdiction of the Ordinary Courts of the City of Buenos Aires, excluding any other jurisdiction that may apply.

 Last update October 2025.