Data Privacy Policy - PDVSA ad hoc

The Personal Data Treatment Policy is addressed to all actors directly or indirectly related to PDVSA ad hoc or to those who participate or interact with it. This Policy contains the general guidelines, orientations or aspects that support the handling of Personal Data collected through the website and the newsletter, in order to keep its subscribers informed and guarantee the relevance of the contents. It has been developed in accordance with the applicable ethical and legal principles.

PDVSA’s ad hoc board, appointed by the Venezuelan National Assembly elected in 2015, for the protection of PDVSA’s assets outside the country, may collect minimal personally identifiable information when you visit our site, respond to a survey or interact with our newsletter resources. Data such as your name and email address may be requested; however, you may choose not to provide it and browse our website anonymously.

The following guidelines are declared in development of the Personal Data Processing Policy, Procedures and Security Measures:

Recognizes that at all times the observance of ethical principles shall be paramount.
Will abide by the regulations that may be issued regarding the treatment of Personal Data, with the purpose of not only complying with all applicable regulations, but also to protect the rights of the Data Owners.
Comply with the guidelines issued by PDVSA’s ad hoc board, regarding the Processing of Personal Data.
Guarantee the confidentiality of the information.
Inform its users and, in general, any Data Subject, of the existence of these Policies.
Shall ensure that the storage of the information received follows the regulations on the Processing of Personal Data and shall monitor its follow-up.
Collaborate with the authorities in providing the information that may be requested in the Processing of Personal Data and security measures.
Support and facilitate the fulfillment of any requirement on the handling of information.
Will ensure the correct handling and custody of the information of all the Data Holders.

DEFINITIONS

Personal Data: Any information linked or that can be associated to one or several determined or determinable natural individuals.
Usage Data: Information collected automatically, such as IP addresses, browser and operating system characteristics, details of time of visit, and sequence of pages visited on the platform.
Data Owner: Natural person whose Personal Data is subject to Processing.
Data Processor: Natural or legal person, public or private, that by itself or in association with others, performs the Processing of Personal Data on behalf of the Data Controller. In this case, Vision Americas International, LLC, and the company Si Señor S.A.S. in Colombia, who process personal data on behalf of PDVSA ad hoc.
Data Controller: Natural or legal person, public or private, association or any associative figure, which by itself or in association with others, decides on the Database and/or the Processing of the data. In this case, PDVSA ad hoc, which determines the purposes and means of the processing of personal data.

OPERATION

Data Processors

In the development and execution of the communication strategy of the PDVSA Ad Hoc Board, a transfer of data is made to Vision Americas International, LLC (hereinafter VAI), as the company contracted to manage this service. VAI has in turn appointed SI SEÑOR S.A.S., a company constituted in Colombia, as the subcontractor in charge of the treatment and processing of this data on behalf of the Ad Hoc Board of PDVSA.

Both VAI and SI SEÑOR S.A.S. have policies for the treatment of personal data and implement strict security and protection measures to safeguard this information, in compliance with applicable legal regulations and with the commitment to protect the privacy of users.

Contact and Messaging Management

To manage the contact database and send messages effectively, we use services that allow us to send mass emails, as well as track user interactions, such as message views and link clicks, to improve the relevance and personalization of the content sent. Emails sent include an unsubscribe button so that users can unsubscribe at any time.

HubSpot, as the CRM platform used by PDVSA ad hoc for sending emails, implements different security measures and practices to protect the personal data of users who subscribe to a newsletter.

Data Encryption: HubSpot uses encryption both in transit and at rest to protect sensitive information. This means that data is encrypted while it is being sent and while it is stored on their servers.
Access Controls: The platform allows administrators to set specific access controls to ensure that only authorized personnel have access to personal data. This can be managed by setting permissions in the HubSpot account.
Privacy and Data Processing Policies: HubSpot has clear policies on how personal data is collected, used and protected. These policies are designed to be transparent with users about their handling of information.
Data Deletion Process: HubSpot allows personal data to be deleted when a user requests that it be deleted or when consent is revoked. This is essential to comply with user requests.

Google Analytics usage

Use of a tool called Google Analytics to collect information about the use of this website. This allows your web browser to automatically send certain information to Google, such as the address of the page you are visiting and your IP address. The information collected through Google Analytics is used solely to understand or improve how visitors interact with the website.

User Rights

Users have the right to:

Request Access to their personal data stored by PDVSA ad hoc and receive a copy of it.
Request the rectification of the personal data in case it is not updated or is incorrect.
Request the deletion of the personal data when they wish to revoke their consent and wish to have their data deleted.
Restrict the use of your personal data by limiting its use exclusively to storage when required.

To exercise these rights, users may contact us at info@pdvsa-adhoc.com. However, please note that we may retain certain information for legal reasons.

Personal Data storage

Information collected will be retained for as long as necessary to fulfill the purposes for which it was collected or to meet applicable legal, regulatory or internal policy requirements. Information may be retained for archival, research or historical purposes, unless the law requires its deletion, or the owner exercises his or her right to have all personal information deleted.

Users may contact us at any time to request deletion of their data, and we will comply with such requests in accordance with applicable law and data protection guidelines.

Los usuarios pueden ponerse en contacto con nosotros en cualquier momento para solicitar la supresión de sus datos, y atenderemos dichas solicitudes de conformidad con la legislación aplicable y las directrices de protección de datos.

Political Activities and Registration under FARA

As PDVSA Ad Hoc Board is a foreign principal, information distributed that may influence or is intended to influence any U.S. agency or official, or any public sector within the United States at the state or federal level, must be registered through FARA (Foreign Agents Registration Act) with the U.S. Department of Justice. This includes any activity and publication made through social media, website and/or newsletter that is developed on behalf of PDVSA ad hoc.

Legal Notice

“These materials are being distributed on behalf of PDVSA’s Ad Hoc Board. Additional information is on file with the U.S. Department of Justice in Washington, D.C.”

Changes in the Data Privacy Policy

PDVSA ad hoc reserves the right to make changes to this data processing policy at any time. The changes will be notified to users on this web page. Users are advised to review this page frequently, considering the date of the last modification indicated at the beginning of this policy. In the event that changes affect the processing activities carried out on the basis of user consent, PDVSA ad hoc will request the user’s consent again, when necessary.