1. Identity and Address.

Citcocomex Group, S. de R.L. de C.V. (hereinafter “Grupo Cocomex” or the “Responsible Party”), with address located at Av. Santa Fe 495, Col. Cruz Manca, Cuajimalpa de Morelos, 05349, Mexico City, Mexico, in compliance with the provisions of the Federal Personal Data in Possession of Individuals Protection Law (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the “Law”) hereby makes of your acknowledgement this Privacy Notice (the “Notice”) with the purpose of publicizing the terms and conditions of the treatment of (i) simple personal data, and/or (ii) financial personal data, and/or (iii) sensitive personal data (hereinafter and as general reference to the three kinds of data: the “Personal Data” as detailed below) that are provided by the owner of such data.

  1. Personal Data Submitted to Treatment.

The Personal Data that will be collected will be the following: complete name, corporate name, addresses, country of residence, sex, date and place of birth, e-mail address, telephone number, mobile phone number, bank account data, Federal Taxpayer’s Registry keycode (Registro Federal de Contribuyentes or RFC), Unique Population Registry Keycode (Clave Única de Registro de Población or CURP) (the “Personal Data”).

  1. Sensitive Personal Date Submitted to Treatment and its Purpose.

Grupo Cocomex may gather sensitive personal depending on the contracted service or product. In which case, we will request the client’s authorization for the treatment and transfer of such data in accordance with the provisions of the Law.

  1. Purposes of the treatment.

Primary purposes.-

Grupo Cocomex makes of your acknowledgement that Personal Data provided will be used for the following necessary purposes:

  • Registering you in our database;
  • Provide the products and/or services;
  • Make the collection of the price of the products or services provided;
  • Comply with billing obligations;
  • Keep you updated of our products and/or services;
  • Comply with the obligations and exercise the rights derived from our legal relationship;
  • Carry out procedures and comply with legal requirements before authorities;
  • Comply with the applicable laws, regulations and legal provisions;
  • Perform consultations, investigations, audits and revisions regarding any complaint or claim for the services rendered;
  • For the record and update of our administration system;
  • Contact you with the purpose of providing customer service and answer the questions and comments made through the means indicated for contact;
  • Analyze the veracity of the information provided in order to be able to perfect the legal relationship and, if applicable, execute the contract or issue the corresponding order;
  • Verify that the provider can comply with the product and/or service required as well as having the capacity of generating the electronic invoice in accordance with the standards established by law;
  • Make the corresponding charges or payments to the customer for the service required; and
  • To control the entry and exit records of our facilities.

Secondary purposes.-

Additionally, we may use your personal information for the following secondary purposes that are not necessary are not necessary to maintain the legal relationship, but that allows and facilitates providing you better attention:

  • For purposes of communication, promotion and diffusion of products and/or services through advertisement;
  • Manage your access to our website and applications;
  • Provide information about our distributors; and
  • Improve our communication and relationship with customers.

In case you do not want your personal data to be used for the secondary purposes listed above, we provide you with the e-mail office@grupococomex.com so you may express your refusal to the use of your personal data for such purposes.

The refusal for the use of your personal data for these purposes will not be a reason for us to deny the services and products requested or contracted.

  1. Data transfer.

The Responsible Party makes of your acknowledgement that, with the purpose of complying with its contractual, administrative, tax, civil and/or commercial obligations, the Responsible Party may transfer your Personal Data to affiliate and/or subsidiary companies, national or foreign, in the understanding that they share internal procedures and policies and are obliged to maintain the confidentiality of the Personal Data provided and to observe compliance of the terms and conditions of this Notice.

Likewise, the Responsible Party informs that the Personal Data will be recorded in a database in order to: (i) integrate your file as a customer and/or provider; (ii) obtain the information necessary to render the services that may be or have been contracted; (iii) send invitations to events and activities; (iv) sending advertising, marketing or commercially prospective information.

Yes ¨ No ¨ I authorize my personal data to be transferred in accordance to the terms and conditions of this Notice.

Additionally, we inform you that, in order to comply with the purposes mentioned in this Privacy Notice, the Responsible Party may transfer your personal data without your consent in the following cases established in article 37 of the Federal Personal Data in Possession of Individuals Protection Law (Ley Federal de Protección de Datos Personales en Posesión de los Particulares):

  1. When the transfer is established in a law or treaty to which Mexico is a party.
  2. When the transfer is made to subsidiary or affiliate companies of the Responsible Party, or to any company of the same group of the Responsible Party that operates under the same internal procedures and policies.
  3. When the transfer is necessary by virtue of a contract celebrated or to be celebrated in the interest of the owner, by the Responsible Party and a third party.
  4. When the transfer is necessary or legally required for safeguarding a public interest, or for the procurement or administration of justice.
  5. When the transfer is necessary for the recognition, exercise or defense of a right in a judicial process.
  6. When the transfer is necessary for the maintenance or compliance of a legal relationship between the Responsible Party and you.

Moreover, we inform you that the Responsible Party may send your personal data to third party service providers necessary for the compliance of the legal, accounting, regulatory or contractual obligations undertaken by Grupo Cocomex or its affiliates, as well as to third parties that render services related to information, operation and administration technologies.

In such cases, we inform that the Responsible Party makes this Privacy Notice available for such third parties so it is respected at all times and the necessary measures are adopted so the persons who have access to your personal data comply with this Privacy Notice, as well as with the principles of personal data protection established in the Law.

Except for the exceptional cases provided in the Law, the Responsible Party shall not transfer your personal data to third parties unless you have previously consented to said transfer.

  1. Navigation and Cookies.

It is hereby reported that cookies may be used on the WEB site. Cookies are small text files that the browser stores on the hard drive, during the time it is connected to the WEB. On the other hand, web beacons are images inserted in an internet site or e-mail, which can be used to monitor the behavior of a visitor, such as storing information about the user’s IP address, duration of interaction time on such page, and the type of browser used, among others.

We inform you that we use cookies and web beacons to obtain personal information, such as your type of browser and operative system; the websites you visit; the links you follow; or your IP address. These cookies and other technologies can be disabled. To do this, you can configure your browser to notify and reject the installation of cookies, without affecting the ability to access the contents.

  1. Means and Procedures to exercise the Access, rectification, cancellation and opposition rights.

If you have any question or concern about how the Responsible Party processes Personal Data, or if you wish to access, rectify, suppress, copy, limit, cancel the use or delete Personal Data, if you oppose to the use of the latter or if you wish to revoke your consent to the treatment of these in accordance with the provisions of this Notice, please contact the administration department of Grupo Cocomex (the Administrator), by sending an e-mail to the address office@grupococomex.com specifying your name, address and the purpose of your request. As well as to exercise your rights of Access, Rectification, Cancellation and Opposition (hereinafter “the ARCO Rights”) provided in the Law, by sending your request to the following address: office@grupococomex.com.

Once the Administrator receives the corresponding request, it will carry out an analysis of it in accordance with the Law, its Regulations and the internal privacy policies. The person in charge will respond to your request no later than 3 (three) business days after the day it was received, being able to issue said response in an affirmative or negative sense and duly justified.

Consider however, that certan Personal Data may be exempt from such Access, rectification, suppression, copy and delete in accordance with data protection laws or other laws and regulations.

  1. Limits to the use or disclosure of personal data.

You may, at any time, revoke your consent for the treatment of your Personal Data, as well as limit the use or disclosure thereof. In addition to the procedure contemplated in the section immediately above, you may limit the use or disclosure of your Personal Data in accordance with the following:

  • Register in the Public Registry to Avoid Publicity of the Federal Consumer’s Attorney Office. For more information regarding this option, contact PROFECO
  • Send an e-mail to the Administrator with the request for your registration in the “Advertising Exclusion List,” with the purpose of not receiving promotional information of our products and services.
  • Following the link that will appear in the advertisement sent for such purposes.
  1. Personal Data Department.

The Responsible Party will take the appropriate measures to protect Personal Data and Financial and/or Sensitive Personal Data that are compatible with the laws and regulations on data security and privacy, including administrative, technical and physical security measures, including obliging third parties with whom a relationship is established in terms of this Notice, to have the appropriate measures to protect the confidentiality and security of Personal Data and Financial and/or Sensitive Personal Data. It is made of your acknowledgement that the security measures are identical to those used by the Responsible Party to keep its own information and all this information is confidential derived from the nature of the services provided by the Responsible Party.

For any consult you may have in relation to the protection of your Personal Data, contact the Administrator at: office@grupococomex.com.

All communication sent to such address shall have a corresponding acknowledgement of receipt of the same by e-mail to the e-mail address we have as part of your information, otherwise it will be deemed as not made.

  1. Procedure and means for modifications in the privacy notice.

The Responsible Party may modify this Notice in order to implement improvements, incorporate new measures provided for in the Law, its Regulations and other regulatory provisions. Any modification to this Notice will be notified through our website http://grupococomex.com/cocomex/privacynotice, including the updated privacy notice, no later than 7 (seven) business days after the implementation of the new privacy notice.

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