Privacy policy — Mexico

Pursuant to the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), published in the Official Gazette of the Federation on 5 July 2010, its current Regulations, and the Privacy Notice Guidelines issued by the Ministry of Economy in conjunction with the Federal Institute for Access to Information and Data Protection on 17 January 2013 — whose purpose is to guarantee the appropriate use and protection of personal data, recognizing that each individual person is the owner of their data and the only one who may decide the use to be made of it — and in compliance with the Information Principle contained in Article 15 of the applicable Law, its current Regulations, and Chapter II, sixth numeral, of the aforementioned Guidelines, we make our Privacy Notice available to you.

At JANIUM TECHNOLOGY, S.A. DE C.V. ("JANIUM") we know that our most important asset is our clients, which is why we apply guidelines, policies, procedures and privacy programs to protect your information. As a client of "JANIUM", you have the opportunity to choose from a diversity of professional services, knowing that your personal data will be protected. The security of your information is our main objective, which is why we protect it through the use and maintenance of high security measures, in order to prevent unauthorized third parties from accessing it.

The purpose of our privacy notice is to define the scope and general conditions of the processing of your data, as well as to inform you of it in a timely manner, so that you are able to make informed decisions about the use of your personal data, and to maintain control and disposal over it. Likewise, the privacy notice allows us to make said processing transparent and thereby strengthen the level of trust towards JANIUM TECHNOLOGY, S.A. DE C.V. In view of the foregoing, we hereby inform you of the following:

Content of Personal Data

According to the law, "Personal Data" is understood as any information concerning an identified or identifiable natural person. For the purposes of this Privacy Notice, by way of example and not limitation, the following will be understood as "Personal Data":

General data: First and last name, date of birth, age, sex, marital status, address, landline or mobile phone, email, and the data and information that, in accordance with the Law, concern a natural person.

Online transactions: In addition to general data, data related to bank cards will be considered Personal Data — such as the cardholder's name, card number, card type and security code — as well as any other information necessary for online subscription or transactions in the event that transactions are carried out to purchase or receive any of JANIUM's products and/or services on any of our digital platforms, sites and/or microsites that JANIUM uses at that time. When you provide your banking data through any of our means of marketing JANIUM's products or services, it will be understood that at that moment you are granting your prior and express consent for JANIUM to process such personal data in accordance with the purposes of processing established in this Privacy Notice.

Cookies: Cookies are text files that are automatically downloaded and stored on the hard drive of the user's computer equipment when browsing a particular website, and that allow the internet server to remember some data of the user; that is, when a user enters their username and password, a cookie is stored, which prevents the user from having to re-enter that information for each page on the server. However, a cookie does not identify a person alone, but rather a computer-browser-user combination. Accordingly, through this Privacy Notice we inform you that JANIUM uses certain cookies for the purpose of identifying or preventing e-commerce operations that may be fraudulent or of irregular or unlawful origin.

Social networks: Social networks (such as Facebook, Twitter, YouTube, LinkedIn and/or other networks on the market) constitute a platform for communication and interconnection between the digital platforms of the different users, and are therefore external to JANIUM; it is thus considered that they are not under its responsibility. The information provided within social networks in which JANIUM participates as a user does not constitute or form part of the Personal Data subject to the protection of this Privacy Notice, being the responsibility of the company providing that platform and of whoever publishes it. Should JANIUM require any personal data referred to in sections a) and b), or should data be collected as indicated in section c) of this Privacy Notice, by means of and/or through a social network, such data will be processed in accordance with the purposes of Processing described below, according to the type of data concerned. In this case, the personal data will fall under the responsibility of JANIUM. However, being collected through social networks, these may also have access to or ownership of such information, depending on the terms of use, confidentiality and information processing of each of the social networks.

The Personal Data mentioned in sections a) and b) of this Privacy Notice will be collected by completing the forms and/or by gathering the information or documentation required by JANIUM, whether in person or electronically on any of JANIUM's websites, present or future, as well as on JANIUM's sites or platforms located on the social networks on which the latter has, or comes to have, a registration. Ownership of the rights over the websites may correspond to JANIUM TECHNOLOGY, S.A. DE C.V. or to any other company forming part of the group of companies known as JANIUM.

Parties responsible for processing your personal data

The party responsible for processing your personal data will be "JANIUM", through the technical support area, which will collect it to address your request for professional services, or to formalize the execution of any acquisition or request for professional services from "JANIUM" and its subsequent follow-up.

JANIUM's address

In compliance with the aforementioned Law and for the purposes of this Privacy Notice, "JANIUM" designates as its address the one located at Av. Insurgentes Sur 4342, Colonia Tlalpan Centro, C.P. 14000, Alcaldía Tlalpan, CDMX, Mexico.

Personal data that may be collected

It is understood between the Parties that "JANIUM" may collect the personal data necessary to address, formalize and/or expand any contracting of professional services that you request, require or currently have; therefore, "JANIUM" may collect the personal data specified in sections a) and b) of this Privacy Notice. In the case of contracting professional services on credit, "JANIUM" has the right to require additional data that allows it to estimate the viability of payment, using for this purpose an analysis based on quantitative and qualitative information that makes it possible to establish your creditworthiness and payment capacity.

Processing of your personal data

In accordance with the provisions of the Law, "Processing of Personal Data" is considered to be the obtaining, use, disclosure or storage of Personal Data by any means. Use covers any action of access, handling, exploitation, transfer or disposal of personal data.

Purposes of processing your personal data

The personal data collected by "JANIUM" will be used to carry out the request, contracting, follow-up, modification, collection or expansion of "JANIUM's" professional services, noting for descriptive purposes the following activities: (i) search for professional services; (ii) carrying out all the procedures, processes, conditions and terms to complete the contracting and development of the professional services offered; (iii) incorporating the data subject's data into the legal instruments required to formalize "JANIUM's" professional services; (iv) using the data received in any type of collection act or proceeding; (v) contacting You to offer other professional services; (vi) preparing statistics and reports on the services provided by "JANIUM" for internal control and precise follow-up; (vii) complying with "JANIUM's" corporate purpose. Likewise, "JANIUM" may use your personal data to offer you, where applicable, other services from "JANIUM" or from any of its associated companies or agents, and to send you promotions of other related services.

For your convenience, the content of the Law may be consulted through the portals that the Federal Government, through the Ministry of the Interior, and the Chamber of Deputies of the Congress of the Union have on the Internet, at: http://www.ordenjuridico.gob.mx and http://www.diputados.gob.mx. Accordingly, in compliance with our Privacy Program and the Law, the personal data we obtain by virtue of the contracting of the professional services you request, execute or carry out with "JANIUM" will be treated confidentially through the systems and schemes provided for such purposes.

Transfer of personal data

"JANIUM" may transfer your personal data to Mexican or foreign third parties that provide it with the services necessary for its proper operation, as well as to its associated companies or agents. In such cases, we inform you that "JANIUM" will adopt the necessary measures so that the persons who have access to your personal data comply with "JANIUM's" privacy policy, as well as with the personal-data-protection principles established in the Law.

Revocation of consent

You may revoke your consent, as well as object to the processing of your personal data for purposes that are not essential to the legal relationship that gave rise to the professional services you requested. To carry out said revocation, you may obtain the relevant form at "JANIUM's" address, through which we will exclude you from our campaigns for marketing, advertising or commercial-prospecting purposes.

ARCO Rights

You or your duly accredited legal representative may limit the use or disclosure of your personal data, as well as exercise, where applicable, the rights of Access, Rectification, Cancellation or Objection provided for by the Law, by means of the form that "JANIUM" provides for such purposes. It is important to mention that the exercise of any of these rights is neither a prerequisite for nor an impediment to the exercise of another right. Likewise, we inform you that you have the right to initiate a Data Protection Procedure before the Federal Institute for Access to Information and Data Protection (www.ifai.gob.mx) within the 15 days following the date on which you receive JANIUM's response, or from the end of the 20-day period counted from the date of receipt of your request to exercise rights.

You have the constitutional right to Access and know the personal data we hold and the details of its processing and use, as well as to Rectify and correct it in the event it is inaccurate or incomplete; to Cancel and delete it when you consider that it is not required for any of the purposes indicated in this privacy notice, or that it is being used for purposes not authorized by you, or the contractual or service relationship has ended; or to Object to its processing for specific purposes.

Modifications to the privacy notice

JANIUM reserves the right to make, at any time, modifications or updates to this Privacy Notice, to address legislative or case-law developments, internal policies, or new requirements for the provision or offering of its products and services. Accordingly, any modification to this notice will be communicated to you through any of the following means: a written communication sent to your address; a message sent to your email; or messages published in widely circulated newspapers. For more information, visit www.ifai.org.mx.