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Privacy Policy.

What information we collect, what we use it for, and the control you have over it when you use our website, our products and our services.

Last updated — August 10, 2026

Contents
1. Who we are2. What information we collect3. How we use the information4. Legal bases for processing5. Cookies and similar technologies6. Who we share information with7. International transfers8. Data retention9. Information security10. Your rights11. Data processed by our products12. Minors13. Changes to this policy14. Contact

1. Who we are

FindHolding ("FindHolding", "we", "us") builds and deploys applied artificial intelligence solutions for enterprises, including the Polar and Enkel products. This policy describes the processing of personal data we carry out as a data controller through this website and our commercial activities.

When we process data on behalf of a customer inside a deployment of our products, we act as a data processor and do so under that organisation's instructions and the agreement signed with them. See the "Data processed by our products" section.

2. What information we collect

We collect only the information we need to answer enquiries, deliver our services and improve the site:

  • Contact details you provide voluntarily in forms: first name, last name, email, phone, company and the content of your message.
  • Commercial relationship data: proposals, communications, meeting history and documentation related to a project.
  • Technical browsing data: IP address, device and browser type, language, pages visited, referral source and access date and time.
  • Interaction data from the site assistant, if you choose to use it: the queries you type and the responses generated.
  • Data received from third parties, such as advertising platforms or industry events, where you have agreed to be contacted.

3. How we use the information

We use the information for specific, limited purposes:

  • Answering enquiries, preparing proposals and arranging product demonstrations.
  • Providing, maintaining and supporting the services you have contracted.
  • Improving the performance, security and usability of the site and our products.
  • Sending commercial communications about products and news where a prior relationship exists or you have given consent. You can opt out at any time.
  • Meeting legal, accounting and regulatory obligations, and defending our rights against claims.

4. Legal bases for processing

We process personal data on the basis of: (a) your consent, given when you complete a form or subscribe to our communications; (b) performance of a contract or pre-contractual steps requested by you; (c) compliance with applicable legal obligations; and (d) our legitimate interest in operating, securing and improving our business, where your rights and freedoms do not override it.

In Argentina this processing is carried out under Law No. 25,326 on the Protection of Personal Data and its supplementary regulations. Where we process data of individuals located in the European Economic Area or the United Kingdom, we also apply the principles of the General Data Protection Regulation (GDPR).

5. Cookies and similar technologies

We use first-party and third-party cookies to keep the site working correctly, remember your language preference and understand in aggregate how the site is used.

Strictly necessary cookies cannot be disabled because the site would not work without them. Analytics and marketing cookies are only activated with your consent, and you can withdraw it at any time through your browser settings, which also let you block or delete cookies already stored.

6. Who we share information with

We do not sell personal data, nor do we disclose it for third-party advertising purposes. We may share it, to the minimum extent necessary, with:

  • Infrastructure, hosting, email, analytics and support providers acting as processors under contract.
  • Artificial intelligence model providers, where the contracted service requires it and under terms that prohibit using the data to train general-purpose models.
  • Professional advisors, auditors and insurers, subject to confidentiality duties.
  • Public or judicial authorities, where there is a legal obligation or a valid order.
  • Third parties involved in a corporate reorganisation, merger or acquisition, maintaining the terms of this policy.

7. International transfers

Some of our providers operate outside the country where the data originates. Where an international transfer takes place, we make sure an adequate level of protection is in place through adequacy decisions, standard contractual clauses or other valid mechanisms, and we contractually limit the use of the data to delivering the service.

8. Data retention

We retain personal data for as long as necessary to fulfil the purposes described and afterwards for the periods required by tax, accounting and statute-of-limitation rules. Commercial contact data that does not lead to a contractual relationship is purged periodically. Once data is no longer needed, we delete it or irreversibly anonymise it.

9. Information security

We apply technical and organisational measures proportionate to the risk: encryption in transit, least-privilege access control, environment segregation, audit logging, backups and periodic vendor review.

No system is completely infallible. If we detect a security incident affecting your personal data, we will notify the competent authorities and the affected individuals where applicable, within the timeframes set by applicable law.

10. Your rights

You may exercise at any time your rights of access, rectification, update, erasure, objection, restriction of processing and portability, as well as withdraw any consent you have given.

To exercise them, write to hello@findholding.com describing your request. We will respond within the legal timeframes and may ask for additional information to verify your identity.

You can also request the deletion of your data from our data deletion page at findholding.com/en/legal/data-deletion. There you fill in a form and receive a confirmation code; if you need to ask us anything about your request, email us quoting it.

The Agency for Access to Public Information, as the supervisory authority for Law No. 25,326, is empowered to handle complaints and claims relating to breaches of personal data protection rules.

11. Data processed by our products

When a customer organisation deploys Polar, Enkel or another FindHolding solution, the data loaded or processed in that deployment belongs to that organisation, which defines the purposes of the processing. We act as a processor and only handle that data to deliver the contracted service.

In those cases, personal data enquiries should be directed to the controlling organisation. We do not use customer content to train general-purpose models, nor do we share it with other customers.

12. Minors

Our services are aimed at organisations and at adults. We do not knowingly collect data from minors. If we become aware that we have received data from a minor without the corresponding authorisation, we will delete it.

13. Changes to this policy

We may update this policy to reflect regulatory, technical or service changes. The version in force will be published on this page with its update date and, where changes are material, we will communicate them through our usual channels.

14. Contact

For any question about this policy or about the processing of your personal data, write to us at hello@findholding.com.

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