Data Protection, Information Security & Privacy Policy
Last updated March, 2025

The website you are accessing is owned by Lifeflex Re Corp (“Lifeflex” or the “Company”, interchangeably), in accordance with the Applicable Law (as such term is defined below).

Lifeflex makes this “Data Protection, Information Security & Privacy Policy” (the “Policy”) available to you to provide you with clear, simple and complete information regarding the Processing of your Personal Data (as such terms are defined below) when you use Lifeflex’s services (the “Services”), which include, but are not limited to:

Access to the Website lifexre.com or any other Lifeflex website that links to this Policy.
Communication with Lifeflex in other related ways, including business inquiries or events without limitation.
Reading this Policy will help you understand your rights and choices in relation to your Personal Data. If you do not agree with Lifeflex’s policies and practices, we ask that you do not use our Services. If you still have questions or concerns, you can contact us using the contact details set out in the Contact Details section.

Index
Definitions
Service Agreement
Data Collected
Purpose of Data Processing
Conservation and Proportionality
Data Protection and Security
Rights of the Data Subject
Use of Cookies
Modifications
Governing Law, Jurisdiction and Competence
Contact Details
I. Definitions
For the purposes of this Policy, the terms indicated below and those that are written with a capital initial will have the meanings indicated in this document, whether they are written in singular or in plural form:

“Cookies”: Technologies through which it is possible to monitor the behavior of the owner as an Internet user and his preferences.

“Personal Data”: Any information concerning an identified or identifiable natural person.

“Sensitive Personal Data”: Those Personal Data that affect the Owner’s private sphere, or whose improper use may give rise to any type of discrimination or entail a serious risk for the Owner. This category includes data that may reveal personal aspects of the Data Controller, such as racial or ethnic origin, present and future state of health, genetic information, religious, philosophical and moral beliefs, trade union membership, political opinions, sexual preference or financial situation.

“Biometric Data”: Personal data obtained from specific technical processing, relating to the physical, physiological or behavioral characteristics of a natural person that allow or confirm the unique identification of that person. We refer to personal data collected solely for the know-your-customer process in the contracting of anti-money laundering services, which in this case is facial recognition.

“Personal Data Department”: Area designated by the Responsible Party, which promotes the protection of Personal Data and attends to requests and concerns from the Holders.

“ARCO Rights”: Rights of Access, Rectification, Cancellation and Opposition as defined in the Data Subject Rights section.

“Processor”: The natural or legal person who, alone or jointly with others, processes Personal Data on behalf of the Responsible Party.

“Applicable Law”: Refers to any legal system that regulates the collection, storage and transmission of Personal Data.

“Services”: means any interaction that users have with Lifeflex, including accessing and browsing its website to obtain information about the Company, its products or services, as well as communicating with the Company through business inquiries, requests for information, subscription to newsletters or participation in events organized by Lifeflex. It is not limited to the contracting of reinsurance products or solutions but encompasses any means of interaction with the Company through its website or related communication channels.

“Website”: Means this Website lifexre.com or websites corresponding to Lifeflex.

“Third Party”: The natural or legal person, national or foreign, other than the Owner, the Responsible or the Person in Charge of the Personal Data.

“Owner” or “You”: The natural person to whom the Personal Data corresponds.

“Processing”: Any operation or set of operations on personal data, by any means. Use includes any action of access, collection, storage, circulation, handling, use, transfer or disposition of Personal Data.

“Transfer”: Any communication of data made to a person other than the Data Controller or Data Processor.

“Controller”: The Data Controller of your Personal Data will be Lifeflex, when it directly collects Personal Data for the fulfillment of the purposes applicable to the Services.

“User” or “You”: A natural or legal person, national or foreign, who accesses and makes use of the Lifeflex Services.

II. Service Agreement
For the purposes of the provisions of the Applicable Law, You declare that:

This Policy has been made known to You by Lifeflex;
You have read, understood and agreed to the terms set out;
You consent to the Processing of your Personal Data, and
You give your express consent for Lifeflex to carry out Transfer and/or Remittance of Personal Data in terms of this Policy.
By not objecting to the provisions of this Policy, it is considered that You have given your express consent for Lifeflex to collect, use, Process and Transfer your Personal Data for the purposes described in this Policy, complying with the terms of the Applicable Legislation.

You are hereby informed that Lifeflex does not collect Sensitive Personal Data in any way.

It is reported that You, having full control of your Personal Data and Sensitive Personal Data, may deny consent to the Processing of such Personal Data and Sensitive Personal Data, for which Lifeflex informs you that, by not granting your express consent, you will not be able to provide the Services and functionalities of the Website in accordance with the purposes described herein, the foregoing for all legal purposes that may apply.

The consent of the Owner will not be necessary for the Processing of Personal Data when:

It is provided for in the Applicable Legislation;
Personal Data is contained in publicly accessible sources;
Personal Data is subject to a prior Dissociation procedure (procedure by which the personal data cannot be associated with the owner or allow, due to its structure, content or degree of disaggregation, the identification of the same);
Has the purpose of fulfilling obligations arising from a legal relationship between the Owner and the Responsible Party;
There is an emergency that could potentially harm an individual in his person or property;
They are essential for medical care, prevention, diagnosis, the provision of health care, medical treatments or the management of health services, while the Owner is not able to grant consent, under the terms established by the General Health Law and other applicable legal provisions and such Data Processing is carried out by a person subject to professional secrecy or equivalent obligation, and
A resolution from competent authority has been issued.
Notwithstanding the foregoing, the Responsible Party undertakes to ensure compliance with the principles of Personal Data protection established by the Applicable Legislation and to adopt the necessary measures for their application, as well as to demand compliance with them from the natural or legal persons to whom access to their Personal Data is transferred or granted in order to give You an adequate service and with the best quality.

III. Data Collected
The Website is purely informational and does not collect Personal Data automatically. However, Lifeflex may collect certain Personal Data in the following cases:

When you contact Lifeflex through forms or means of communication provided on the Website.
When you subscribe to newsletters or request additional information about the Services.
When you establish a business relationship with Lifeflex, in which case only the data strictly necessary for the provision of the Services agreed between the parties is collected.
We do not collect Sensitive Personal Data or share your information with third parties outside the scope necessary for the provision of the Services.
IV. Purpose of Data Processing
The Personal Data that Lifeflex collects, if any, is used solely and exclusively for the following purposes:

Handle inquiries and respond to requests for information.
Provide the Services agreed with You.
Comply with applicable legal and regulatory obligations.
V. Conservation and Proportionality
The Personal Data you provide will be retained or destroyed according to Lifeflex’s needs and in accordance with the provisions of Applicable Law and the purposes of this Policy.

The amount of personal information that will be requested from you will relate only to the data that Lifeflex needs to provide the Services and under the fulfillment of the purposes contained in this Policy.

VI. Data Protection and Security
Lifeflex has implemented appropriate technical and organizational security measures to protect Personal Data against unauthorized access, loss, alteration, or improper disclosure.

Lifeflex does not sell Personal Data to third parties.

VII. Rights of the Data Subject
In accordance with the Applicable Data Protection Legislation, You or your duly accredited legal representative may limit the use or disclosure of your Personal Data; as well as exercise, where appropriate, the following rights:

Access to your Personal Data that are in our possession;
Rectification of any inaccuracies about your Personal Data;
Cancellation at the time when you consider that they are not required for the purposes indicated above, are used for other purposes not established in the terms of this Policy, or the contractual or service relationship has been terminated; and
Opposition to the Processing for specific purposes (collectively, the “ARCO Rights”) that the Applicable Legislation provides, through Lifeflex’s means of contact.
The application must contain and be accompanied by the following:

Your name and email address to receive a response;
Documents that prove your identity and/or that of your legal representative;
The clear and precise description of the Personal Data with respect to which you seek to exercise any of the aforementioned rights;
Any other document or element that facilitates the location of your Personal Data, and
In the case of requests for rectification, it must also indicate the modifications to be made and provide the documentation that supports its request, if it is appropriate.
Lifeflex will have a maximum period of 20 (twenty) business days to inform you about the admissibility of the request for ARCO Rights.

VIII. Use of Cookies
Our website does not use Cookies to collect personal information. In the event of implementing Cookies in the future, this Policy will be updated to inform about their use and configuration.

IX. Modifications
Lifeflex reserves the right to make modifications or updates to this Policy at any time, in response to new legislation or jurisprudence, internal policies, new requirements for the provision or offer of our Services and market practices. Such modifications will be available and will be notified on this Website in the Policy section.

X. Governing Law, Jurisdiction and Competence
This Policy is governed by the applicable and prevailing regulations in the relevant jurisdiction. By accepting this Policy, you agree, where applicable, to submit to the competent courts of the relevant jurisdiction in the event of any dispute and/or claim regarding its content.

XI. Contact Details
Lifeflex provides you with contact of our Personal Data Department in charge of attending to and managing any request for ARCO Rights, as well as any related to the Personal Data of the Owner.