Privacy

Personal Information Privacy Notice

1. General and contact data

ATC Costa Rica (“American Tower”) addressed at Escazú, San José, Costa Rica, informs you that for everything related to the processing of your personal data, that you disclose to us (hereinafter “Personal Data”), American Tower will be the data controller and will be committed to the protection of your privacy.

You may contact ATC for any purpose concerning this Privacy Notice by leaving e-mail for the Privacy Officer and/or Data Protection Officer at privacy.officer@americantower.com, or contacting that Officer at +1-617-375-7500 or 116 Huntington Avenue, 11th Floor, Boston, MA 02116.

The user declares having previously read and accepted expressly this policy agreeing to its terms and grants his/her consent for data collection and other practices described in this Privacy Notice.

2. Personal Data Collected

Personal Data that American Tower may request you those necessary in order to comply and/or fulfill your relationship with American Tower and/or your principal and which may be: i) complete name; ii) address; iii) telephone; iv) e-mail or website, and v) company that your represent.

American Tower will not request data considered as sensible databy Law 8968, Data Protection Law and its complimentary norms (“Law”). In case of the request of sensible Personal Data, we will request your express and written consent for its obtaining and processing, as it is provided by the Law.

In case that you do not grant us your express consent for the processing of your Personal Data, we may not be able to establish a relationship with you.

For any doubt or comment in relation of your Personal Data, you may contact our Privacy Department through our contact data provided in this Privacy Notice.

3. Obtaining your Personal Data

American Tower may obtain your Personal Data, directly by you or when you disclose it to us by other authorized ways, such as this website or via our e-mail.

Likewise, we inform you that American Tower’s websites obtain automatically Personal Data through cookies. “Cookies” are small pieces of information stored automatically on your hard drive by your web browser. You can avoid of using cookies in your computer by configuring it, please bear in mind that this action could limit the functionality of American Tower’s websites.

4. Purposes to Collect and Use your Personal Data

Your Personal Data will be used for the purposes that are considered necessary for the commencement, existence, maintenance and fulfillment of the legal relationship between American Tower and you. The purposes for which American Tower will obtain and use your Personal Data are: i) the fulfillment and development of the contractual obligations or commercial agreements that you have or may enter into with American Tower or any of its affiliates or subsidiaries; ii) create data banks for providing our services; iii) give information requested by bodies or government authorities or to comply the provisions related to American Tower’s business in the Republic of Costa Rica or abroad, and iv) contact and attend any of your comply, questions or suggestions.

Additionally, your contact Personal Data will be used for: i) advertising and/or commercial-research purposes; ii) create data banks for research, statistics or marketing; iii) evaluate the quality of American Tower’s services; iv) send notifications, ads or publicity about our products or services; v) send information, magazines and news that we consider that may interest you, as news, communications and advertisements of American Tower and its related companies. The aforementioned purposes are not considered as strictly necessary for the existence, maintenance or compliance of your commercial relationship with American Tower, you may deny your consent for the processing of your Personal Data for such purposes by sending us an e-mail.

5. How do we protect our Personal Data?

We are committed to protect your Personal Data with the organizational, physical and technical security measures provided by the Law and its Regulations, to avoid its damage, lost, destruction, theft, alteration and/or its unauthorized processing.

American Tower uses different technical security mechanisms to protect your Personal Data from unauthorized access. Notwithstanding, American Tower is not responsible for illegal interceptions or violations of its systems of data banks by unauthorized persons nor for the misuse of the information illegally obtained, or for any illegitimate intrusion that is out of American Tower’s control.

6. Your rights – How may you access, rectify, suppress or reject the processing or transference of your Personal Data?

As the data owner of your Personal Data, in accordance with the Law and its Regulations, you may access the Personal Data that we possess and to the detail of how we process such data; rectify in case that such data is incomplete or inexact; suppress in case that such data is no longer required for any of the purposes mentioned in this Privacy Notice, or are being used for purposes that have not been consented by you, or reject to their processing for specific purposes.

For purposes of the foregoing, you may request to exercise your rights of access, rectification, suppression or rejection to the processing of your Personal Data (“ARCO rights”) before American Tower according to the established in the Law, and through a written request sent to our physical address or e-mail, indicating: i) name of the owner of the personal data or its duly credited representative, ii) copy of a valid official identification of the owner of the personal data or its duly credited representative; iii) personal data to which the request is referred; iv) specific petition of the right that wants to be exercised; v) documents that support your request, if applicable; vi) address or e-mail where the response to the request may be sent; vii) date and signature of the requestor, considering that the name indicated in the e-mail account will be considered as the requestor’s signature; viii) proxy legalized by notary in case of a representative; ix) any other requisite established in the Law and/or any other applicable rules.

American Tower will record any request received. In case the owner of the personal data has not proven his/her identity according to the requisites mentioned above, American Tower will present its observations within 5 business days as of the following day the request was presented giving the owner of the personal data 5 business days to amend his/her request. If the request is not amended in the term granted the request will be deemed null.

American Tower will give a response of any complete request in the following terms:

• The maximum term for a right of information request will be replied in 8 days from the following day the request is presented with no observations.
• The maximum term for a right of access request will be replied in 20 days from the following day the request is presented with no observations.
• In the case of the exercise of other rights such as rectification, cancellation or opposition, the maximum response term will be 10 days from the following day the request is presented with no observations.

The terms may be extended in accordance to the Law. American Tower will provide electronic copies of your Personal Data in case you exercise your access right.

7. Limit the use or disclosure of your Personal Data

You have the right to limit the use or disclosure of your Personal Data for the purposes that are not necessary for our legal relationship. Therefore, if you do not want to receive any communications or advertisements of our company, please send us an e-mail or mail addressed to our Privacy Department, indicating us of that situation and we will include you in the no-contact registry of American Tower, and we will give you proof of your registration thereof, as requested.

8. Revoke your consent for processing your Personal Data

You may, at any time, revoke your consent granted for the processing of your Personal Data by contacting our Privacy Department, by contacting us through our contact data. We inform you that in the event you revoke your consent for the processing your Personal Data, we may not be able to continue our legal relationship.

9. Transfer of your Personal Data – With who do we share your Personal Data?

As of the activities related to the management and administration of American Tower, we may transfer your Personal Data with our holding company or/and some or all of our affiliates, subsidiaries, licensees and/or the same economic group in Costa Rica or abroad, whenever they operate through the same processes and internal policies; in such cases, American Tower may transfer your Personal Data for which you grant your express consent. Likewise, American Tower reserves the right to share your Personal Data with any administrative or governmental authorities in Costa Rica or abroad, whenever a law or a judicial so provides. American Tower will not require your consent for these transfers. American Tower will share your information when subcontracting third parties; including lawyers, auditors, accountants or technical staff that need to process your information on behalf of American Tower and pursuant to its instructions.

Likewise, your Personal Data may be shared to any prospect, potential buyer or acquirer. Likewise, we may share your Personal Data to third parties interested in executing business or a legal relationship with us, grant financial services, acquire shares or assets of American Tower or its shareholders or affiliates in Costa Rica or abroad, or interested in merging with American Tower. You may deny your consent for the transfers mentioned in this paragraph by letting us know through any of our contact data.

Except of the mentioned cases, American Tower will not transfer your Personal Data to third parties, with exception to the cases provided in the Law or any other applicable provision.

10. Storage of your Personal Data

American Tower, directly or through any other of its affiliates or subsidiaries, may store your Personal Data in data banks located in the Republic of Costa Rica or abroad, with no limitation, except for the time periods provided by the applicable provisions, as well as to comply the purposes provided in this privacy policy and the provisions of the Law, its regulations and any other applicable provisions.

11. Modifications to the Privacy Notice, Legislation and Jurisdiction

The company shall have right to modify or update, at any moment, this privacy notice to respond to legal developments, internal policies or new requirements for the provision and offer of our products.

In case of modifications to this privacy notice, it will be notified through your email. It may be communicated on our website or through communications posted on our offices. At any case, you will have the right to cancel or rectify your Personal Data, as to limit its use or diffusion in case of amendments to the terms of this Privacy Policy.

This Privacy Notice and the processing of your Personal Data are governed by the Law and its complementary regulations. The acceptance of this Privacy Notice and/or the mere continuance in the rendering of your services after this Privacy Notice is delivered to you, implies an express written acceptance, of its terms and conditions as well as your express consent to it and waving of competence in favor of the Courts of Lima, for any claim or dispute resultant from this Privacy Notice.