Infraestructura de pagos transfronterizos para mercados de alta fricción.

Golden Hedge Capital Corp, a company identified by EIN 33-2357610, located at 1007 North Orange Street, 4th floor, Wilmington, Delaware, Zip Code 19801 (hereinafter "Golden Hedge"), operator of the Xenta brand and the xenta.io website, in compliance with applicable laws and regulations, is responsible for the treatment of the personal data it collects. To this end, it has established this Privacy Policy.

The mechanisms used by Golden Hedge to manage personal data are secure and confidential, ensuring that unauthorized or fraudulent access by third parties is prevented.

1. Scope

This document aims to inform all individuals who have provided or will provide their personal data to Golden Hedge about the Personal Data Treatment Policy, which applies to all databases and the personal data they contain, for which Golden Hedge is responsible, in accordance with applicable data protection laws and regulations.

2. Definitions

For the purposes of this policy, the following terms shall have the meanings as defined by applicable laws:

• Authorization: Prior, express, and informed consent from the data subject for the processing of their personal data.
• Privacy Notice: A verbal or written communication generated by Golden Hedge addressed to the data subject, informing them about the existence of this Privacy Policy, how to access it, and the purposes for which their data will be processed.
• Database: An organized set of personal data subject to processing, whether physical or digital.
• Personal Data: Any information linked or that can be associated with one or more identifiable individuals. Golden Hedge, in compliance with its legal and contractual obligations, processes personal data, including that of its employees, suppliers, customers, and third parties.
• Public Data: Data that is not semi-private, private, or sensitive, and which can be found in public records or official documents.
• Sensitive Data: Data that affects the privacy of the data subject or whose misuse can lead to discrimination, such as data revealing racial or ethnic origin, political opinions, religious beliefs, or health conditions.
• Data Processor: A person or entity, public or private, who processes personal data on behalf of the Data Controller.
• Data Controller: A person or entity that, alone or jointly with others, decides on the processing of personal data.
• Data Subject: The individual whose personal data is being processed.
• Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.

3. Processing of Personal Data

This policy applies to personal data provided to Golden Hedge by data subjects through any means, including verbal, electronic, or physical formats, as well as any data collected through lawful means without requiring prior authorization for its processing.

• Processing of Public Data: Golden Hedge may process public data without prior authorization from the data subjects, obtained from public records or official documents, in accordance with the principles and obligations of applicable laws.
• Processing of Employee Data: Personal data from employees is collected and processed in accordance with this Privacy Policy for purposes related to employment, such as selection, performance evaluations, and legal obligations.
• Processing of Supplier and Contractor Data: Personal data from suppliers and contractors is collected for purposes such as selection, contracting, and compliance with contractual and legal obligations.
• Processing of Customer Data: Personal data from customers is collected for the provision of services, compliance with contracts, and communication of updates or offers related to the services provided by Golden Hedge.
• Sensitive Data: Golden Hedge does not collect sensitive data unless necessary for its operations. If required, express consent will be obtained from the data subject.

4. Third-Party Access to Personal Data

Golden Hedge may share personal data with third parties, including contractors or partners, as necessary for the fulfillment of its services and legal obligations. All third parties will be bound by confidentiality agreements and will only process personal data for the purposes authorized by Golden Hedge.

5. Purposes of Data Processing

Personal data will be processed for the following purposes:

• Employee Data: For recruitment, employment verification, contractual obligations, and legal compliance.
• Supplier Data: For selection, evaluation, contracting, and compliance with legal obligations.
• Customer Data: For communication regarding services, contractual compliance, and legal obligations.

6. Data Subject Rights

Data subjects have the right to:

• Access, update, or correct their personal data.
• Request proof of their consent for data processing.
• Be informed about the use of their personal data.
• Request deletion of their data when the processing does not respect their legal rights, except in cases where a contractual relationship exists.

7. Requests, Queries, and Complaints

Golden Hedge will respond to data subject requests and complaints in accordance with applicable laws. Data subjects can contact Golden Hedge in writing at the company's registered office in Wilmington, Delaware, or by email at contact@xenta.io.

8. Judicial and Administrative Requests

Golden Hedge will provide personal data to judicial or administrative authorities in compliance with legal requirements and following due process.

9. Obligations as Data Controller

As the Data Controller, Golden Hedge commits to:

• Ensure the exercise of the data subject's rights at all times.
• Store data securely and prevent unauthorized access.
• Update or correct data when necessary.
• Ensure third-party processors adhere to security and confidentiality obligations.

10. Policy Modifications

Golden Hedge reserves the right to modify this Privacy Policy at any time. Any changes will be posted on the xenta.io website at least ten (10) business days before taking effect.

11. Law and Jurisdiction

This policy is governed by the laws of the State of Delaware, and any legal action arising from the processing of personal data will be subject to the jurisdiction of Delaware courts.

Golden Hedge Capital Corp (hereinafter "GH"), operator of the Xenta brand, through its website xenta.io (hereinafter the "website"), provides the public with information about the company, its services, as well as general legal content of current interest related to its areas of expertise.

GH requests that website users read these terms and conditions before browsing or using the features available on this web portal. If you do not agree with these conditions, we suggest you refrain from accessing or browsing the website.

Use of the Website, Its Content, and Services

The use of the website for illegal purposes against GH or third parties or for any activity that may harm or disrupt the website's normal functioning is prohibited.

The content included on the website is the exclusive property of GH. The total or partial copying, reproduction, translation, transmission, or storage of this content through digital or any other system without prior written authorization from GH is prohibited.

Links to other websites or social media platforms are provided as a service to the user. However, it is clarified that GH has not been involved in creating such websites and is not responsible for their content or the services offered.

The functionality of the "Map your corridor" contact form is also offered as a service to the user, allowing them to make inquiries, which will be attended to by GH.

All elements and any information protected by intellectual property rights are the exclusive property of GH; therefore, their reproduction or use for any purpose without prior written authorization from GH is prohibited.

Information Provided to GH

The information provided by the user through the website's contact channels will be used to address the user's requests and the services offered by GH and for the purposes informed in the authorizations for personal data processing, following the Privacy Policy published on xenta.io.

GH will request the user's authorization before any personal data is processed, informing the user of the specific purposes of the processing and their rights, in compliance with applicable laws.

Guidelines for Website Navigation

To ensure proper use of the website, the user agrees to comply with the following guidelines:

• Observe these Terms and Conditions, the Privacy Policy, and any other policies established by GH and published on the website.
• Use the content of the website and its services diligently.
• Do not use the website for illegal or unauthorized activities, whether in the U.S. or any other country.
• Do not alter, block, or engage in any activity that impedes the proper functioning of the website, including but not limited to hacking, intercepting communications, identity theft, or falsifying documents.
• Submit requests, complaints, or claims respectfully through the contact channels established by GH, as outlined in these Terms and Conditions and the Privacy Policy.

User Responsibility

The use of the website is the sole responsibility of the user.

The user shall indemnify GH against any legal or extrajudicial claims that may arise due to the user's failure to comply with these terms and conditions.

Rights of GH

As the owner of the website, GH reserves the right to:

• Modify, unilaterally and at any time, these terms and conditions, as well as the design and functionality of the website. GH will inform users of any modifications via the website.
• Any use of the website after such modifications will imply the user's acceptance of the changes.
• Determine the content published on the website and remove it when deemed appropriate.

Responsibility of GH

GH will make every effort to ensure the website functions properly 24 hours a day, allowing users to use its services without interruption, notwithstanding limitations or restrictions previously informed to the user or due to user devices or connection issues.

GH may interrupt or suspend the website's services for technical or security reasons or due to factors such as internet outages, power failures, force majeure, or third-party actions, without assuming responsibility to the user.

Exclusion of Guarantees and Liabilities

GH provides no guarantees and assumes no liability for any damages that may arise from:

• The lack of availability, maintenance, or continuity of the website due to causes beyond GH's control. When possible, GH will inform users in advance of interruptions or limitations to the website's services.
• The lack of utility, suitability, or validity of the website and its services for meeting user expectations.
• Negligent, illegal, or fraudulent use by users that is contrary to these terms and conditions.

Internet Security

GH will make every effort to maintain the security and confidentiality of the website; however, GH does not control or guarantee, and therefore is not responsible for, malicious code or other harmful elements that may appear on the website despite diligent compliance. Such elements may cause alterations to the user's computer systems (software and hardware) or electronic documents stored on the user's system.

Use of Cookies

Cookies are small files stored on the user's electronic device to enable certain functionalities of the website. Any browser visiting the website may receive cookies from GH or third parties such as affiliated entities or service providers.

GH may use persistent cookies to recognize the user and facilitate the use of the website's services. The user must authorize the use of cookies by clicking "Accept" on the website, which constitutes the user's knowledge and acceptance of the use of cookies. See the Cookies Policy for full detail.

If the user wishes to reject or delete cookies, they can configure their browser (e.g., Chrome, Safari, Firefox, Edge) to block them, which may affect the website's functionality.

User Support

The user may request assistance or submit inquiries, complaints, or claims in writing through the following contact channels:

• The "Map your corridor" section on the website: xenta.io/#contact
• By sending an email to contact@xenta.io

Applicable Law and Jurisdiction

These terms and conditions are governed by the laws of the State of Delaware. If any provision of these terms and conditions becomes invalid, all other provisions will remain in full force and effect.

Any dispute, action, or claim arising from the interpretation or application of these terms and conditions shall be subject to the jurisdiction of the courts of the State of Delaware.

Golden Hedge Capital Corp ("we," "us," or "our"), operator of the Xenta brand, uses cookies and similar tracking technologies on our website xenta.io to enhance your browsing experience, improve performance, analyze traffic, and deliver relevant content. This Cookies Policy explains what cookies are, how we use them, and the choices you have regarding cookies.

1. What are Cookies?

Cookies are small text files that are stored on your device (computer, tablet, or mobile) when you visit a website. Cookies allow the website to recognize your device and remember certain information about your visit, such as your preferences, browsing activity, and previous interactions with the website.

2. Types of Cookies We Use

We use the following types of cookies on our website:

• Strictly Necessary Cookies: These are essential for the website to function properly. They enable core functionalities such as security, network management, accessibility, and remembering your cookie-consent choice and language preference (EN/ES). You cannot opt out of these as they are necessary for the website's operation.
• Performance and Analytics Cookies: These help us understand how visitors interact with our website by collecting information such as the pages you visit, time spent on the website, and any error messages. The information collected is aggregated and anonymized. We use Google Analytics 4 (Measurement ID G-H11WY74XTD) for this purpose, and only after you click Accept on the cookie banner. Until you accept, no analytics data is sent.
• Functionality Cookies: These allow our website to remember your preferences, such as language settings, to provide enhanced and personalized features.
• Targeting or Advertising Cookies: We do not currently use targeting or advertising cookies. If this changes, this policy will be updated and a clear opt-in will be surfaced through the cookie banner.

3. Third-Party Cookies and Sub-Processors

We may allow third-party service providers to place cookies on your device to provide services such as analytics. These third-party cookies are subject to their own privacy policies, and Golden Hedge Capital Corp does not control or have access to these cookies. Current third parties:

• Google Analytics 4 — page-view and engagement measurement, loaded only after your consent. IP addresses are anonymized; ad-personalization signals are kept off (Google Consent Mode v2: ad_storage, ad_user_data, and ad_personalization remain denied even after acceptance).
• Netlify — site hosting. Netlify receives standard request logs (IP, timestamp, URL) for security and abuse prevention.
• Google Forms — the contact form submits to a Google Form under our Workspace account; Google acts as our sub-processor for that intake.
• rss2json — used to pull our Substack article feed for the Insights section.

4. How We Use Cookies

We use cookies to:

• Enhance your experience on our website.
• Remember your preferences and settings (language, cookie consent).
• Analyze traffic and user behavior to improve website performance, only after you have consented.
• Measure the effectiveness of our communications.

5. Your Choices Regarding Cookies

You have several options for managing your cookie preferences:

• Cookie Banner: When you first visit our website, you will see a cookie banner informing you about our use of cookies. You can choose to Accept or Reject non-essential cookies through this banner. You can change your mind later by clearing site data for xenta.io in your browser — the banner will reappear.
• Browser Settings: Most web browsers allow you to control cookie settings. You can choose to block or delete cookies through your browser settings. However, please note that blocking or disabling cookies may affect your experience and limit certain functionalities of the website.

For more information on managing cookies, visit the help pages of your browser:

• Chrome: support.google.com/chrome/answer/95647
• Firefox: support.mozilla.org
• Safari: support.apple.com

6. Updates to This Cookies Policy

We may update this Cookies Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post any updates on this page, and the revised version will be effective as soon as it is accessible.

7. Contact Us

If you have any questions about this Cookies Policy or our use of cookies, please contact us at:

Golden Hedge Capital Corp
1007 North Orange Street, 4th floor
Wilmington, Delaware, Zip Code 19801
Email: contact@xenta.io