Privacy Notice

I.- RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA:

ACEDO SANTAMARINA, S.C., with address at Mario Pani number 400, Piso13-2, Colonia Santa Fe Cuajimalpa, C.P. 05348, Delegación Cuajimalpa, México, Distrito Federal, is responsible for safeguarding the privacy of the data that you provide us as a client or potential client, making you aware that your information will be treated exclusively for the purposes specified below, in accordance with the provisions of the Law.

Our Personal Data Protection and Processing Department is located at:

Domicilio: Mario Pani number 400, Piso 13-2, Colonia Santa Fe Cuajimalpa,
Z.P. 05348, Delegación Cuajimalpa, México, Distrito Federal.
Phone:(55) 59502222
E-mail address: datospersonales@acsan.mx
José Luis Mejía Estrada

SECOND.- PURPOSE FOR WHICH PERSONAL DATA ARE COLLECTED.

In terms of the applicable legal provisions, we will process the personal data we collect for the following purposes:

Primary or necessary:

1. Invoice issuance and collection of invoices.
2. Provision of legal services requested by the client.
3. Issuance and dispatch of an update report on relevant legislative news.
4. Candidate selection and recruitment processes.
5. Video surveillance of ACSAN’s facilities for your safety and the safety of visitors.

Secondary or accessory:

1. To comply with our obligations in terms of the applicable legal provisions; and
2. To carry out any and all transactions and perform any other authorized acts in accordance with the law and our bylaws.

You are hereby informed that if you do not agree with the processing of your personal data for secondary or accessory purposes, you have a period of 5 days from the date on which you disclose your personal data to expressly express your refusal to the Department of Protection and Processing of Personal Data of ACSAN through the means indicated in this notice, since failure to do so will be considered tacit consent.

THIRD.- PERSONAL DATA.

The personal data requested by ACSAN are, among others, those listed below:

• Full name
• CURP
• Contact telephone numbers
• Address
• Company where he works
• Email address
• Contact information
• Images and sounds captured by video surveillance cameras.

We inform you that the data collected by ACSAN are not of a sensitive nature, so it is necessary that in case you do not agree with the treatment that ACSAN will give to your personal data, you expressly express your opposition to the Department of Protection and Processing of Personal Data of ACSAN through the means indicated in this notice, since failure to do so, you will be considered tacitly consented.

FOURTH.- COLLECTION OF PERSONAL DATA.

In ACSAN, to carry out the collection of personal data, we are guided by the principles of legality, quality, consent, information, purpose, loyalty, proportionality and responsibility established by the Law of the matter, being that we collect the owner’s data in person or via telephone or email, among others, to ensure the reliability of the same.

In turn, ACSAN may obtain personal information through lawful means established by law, such as public databases or any other agency or public source of information.

FIFTH.- USE OF COOKIES AND WEB BEACONS

Cookies are text files automatically downloaded and stored on the hard disk of the user’s computer equipment when browsing a specific Internet page, which allow the Internet server to remember some information about the user, including his preferences for viewing pages on that server, name and password.

Web beacons are images inserted in an Internet page or email, 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 that page and the type of browser used, among others.

It is established that the installation, permanence and existence of the Cookies in the computer of the client or user of the site depends on his exclusive will and can be eliminated when he so wishes. To find out how to remove Cookies from your system, you need to check the Help section of your browser.

Please be advised that we may use cookies and web beacons to obtain personal information from you, such as the following:

a) Your browser type and operating system;
b) The Internet pages you visit;
c) The following links;
d) The IP address; and
e) The site you visited before entering any of ACSAN’s sites.

At any time, you may prohibit the use of cookies and web beacons, in order for us to stop using them. To do so, you must expressly express your opposition to the Department of Protection and Processing of Personal Data of ACSAN through the means indicated in this notice, since if you fail to do so, you will be considered as tacitly consented.

SIXTH – MEANS AND PROCEDURE FOR LIMITING THE USE OR DISCLOSURE OF YOUR PERSONAL DATA

In order for you to limit the use and disclosure of the data collected by ACSAN, we provide you with the following means: (i) the registration of the data in the Public Registry, which is in charge of the Procuraduría Federal del Consumidor (“PROFECO”), so that your personal data will not be used to receive advertising or promotions of goods and services companies. For more information on this registry, please consult PROFECO’s website or contact PROFECO; (ii) Your registration in an exclusion list, so that your personal data will not be processed for marketing, advertising or commercial prospecting purposes by ACSAN.

In case you require more information or wish your data to be included in an exclusion list, please follow the following procedure:

I. Make a written request addressed to the Department of Protection and Processing of Personal Data of ACSAN which must contain at least the following information:

a) Full name of the owner.
b) Address of the holder of the personal data or e-mail, by which the response to the request can be sent to him/her.
c) Official documents proving the identity of the owner or his representative, as well as the powers and faculties in which the due representation of the legal representative is evidenced.
d) To expressly request that their data be included in an exclusion list.

II.- Send the application:

a) To the Department of Protection and Treatment of Personal Data located at Mario Pani number 400, Piso13-2, Colonia Santa Fe Cuajimalpa,
Z.P. 05348, Delegación Cuajimalpa, México, Distrito Federal.
b) To e-mail: datospersonales@acsan.mx

SEVENTH.- MEANS TO EXERCISE THE ARCO RIGHTS (Access, Rectification, Cancellation and Opposition).

You have the right to access your personal data in our possession and the details of their treatment, as well as to rectify them in case they are inaccurate or incomplete, cancel them when you consider that they are not required for any of the purposes stated in this privacy notice, when they are being used for non-consensual purposes or when the contractual or service relationship has ended, or to oppose to their treatment for specific purposes.

To exercise your rights of access, rectification, cancellation or opposition, it is necessary to follow the following procedure:

I. Make a written request addressed to the Department of Protection and Processing of Personal Data of ACSAN which must contain, at least, the following information:

a) Full name of the owner.
b) Address of the holder of the personal data or e-mail, by which the response to the request can be sent to him/her.
c) Official documents proving the identity of the owner or his representative, as well as the powers and faculties in which the due representation of the legal representative is evidenced.
d) Clear and precise description of the personal data, with respect to which you are seeking to exercise any of your rights.
e) Any other element or document that facilitates the location of the personal data, as well as any other document required by the legislation in force at the time of submitting the request.

II.- Send the application:

a) To the Department of Protection and Treatment of Personal Data located at Mario Pani number 400, Piso13-2, Colonia Santa Fe Cuajimalpa,
Z.P. 05348, Delegación Cuajimalpa, México, Distrito Federal.
b) To e-mail: datospersonales@acsan.mx

ACSAN will have a term of twenty working days following the date of receipt of the request, to decide whether or not the request is admissible or inadmissible.

ACSAN shall at all times have the right to extend the aforementioned term for one single occasion for an equal period, provided that it is justified and the circumstances of the case so warrant.

In the event that the request is declared inadmissible, the respective evidence must be attached to the request, and therefore, when the request is admissible, the exercise of the right requested shall be effective within fifteen working days following the date of communication of the resolution adopted.

The exercise of the rights of access, rectification, cancellation or opposition may be denied in the following cases:

I. When the applicant is not the owner or the legal representative of the legal entity does not prove the legal existence of the represented party or its powers and faculties are not sufficient to exercise the rights in question.
II. When ACSAN’s databases do not contain the applicant’s personal data.
III. When the rights of a third party are violated.
IV. When there is a legal impediment or resolution of a judicial or administrative authority.
V. When the rectification, cancellation or opposition has been previously made in such a way that the request lacks subject matter.

Likewise, ACSAN will not be obliged to cancel your personal data in any of the following cases:

I. That refer to the parties to a private, social or administrative contract and are necessary for its development and performance.
II. When they must be treated by law.
III. When judicial or administrative proceedings related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions are hindered.
IV. When they are necessary to protect the legally protected interests of the owner.
V. Are necessary to carry out an action in the public interest.
VI. Are necessary to comply with an obligation legally acquired by the holder, and
VII. Are the subject of treatment for prevention or for medical diagnosis or the management of health services, provided that such treatment is carried out by a health professional subject to a duty of confidentiality.

In case you consider that your personal data have been violated, or that your request to exercise your ARCO Rights was not duly attended by ACSAN, in accordance with the Law, you have the right to go to the National Institute of Access to Information to initiate a data protection procedure.

EIGHTH.- REVOCATION OF CONSENT FOR THE PROCESSING OF PERSONAL DATA.

At any time, you may revoke the consent you have given to ACSAN for the processing of your personal data by following the procedure below:

I. Make a written request addressed to the Department of Protection and Processing of Personal Data of ACSAN which must contain at least the following information:

a) Full name of the owner.
b) Address of the holder of the personal data or e-mail, by which the response to the request can be sent to him/her.
c) Official documents proving the identity of the owner or his representative, as well as the powers and faculties in which the due representation of the legal representative is evidenced.
d) Expressly state the request to revoke consent for the processing of personal data, stating the reasons why you wish to do so.

II.- Send the application:

a) To the Department of Protection and Treatment of Personal Data located at Mario Pani number 400, Piso13-2, Colonia Santa Fe Cuajimalpa, C.P. 05348, Delegación Cuajimalpa, México, Distrito Federal.
b) To e-mail: datospersonales@acsan.mx

Within a maximum period of twenty days we will respond to your request and will inform you of the origin of the request through the means indicated in your request.

Notwithstanding your request, ACSAN may treat certain information as permitted or required by law.

NINTH – DATA TRANSFER

ACSAN hereby informs you that your personal data will not be transferred or shared with any third party.

TENTH.- MODIFICATIONS TO THE PRIVACY NOTICE.

The holder agrees that ACSAN reserves the right to make changes or updates to this privacy notice at any time, which may be given in order to meet new legislation, internal policies or new requirements for the provision or offering of our services.

These modifications will be available to the public through the following means: (i) through our website www.acsan.mx; or (ii) physically at the address of ACSAN’s Personal Data Protection and Processing Department, which shall be at ACSAN’s discretion. The amendments shall take effect immediately upon the occurrence of any of the three events set forth in this paragraph.

ELEVENTH.- BLOCKING AND DELETION OF PERSONAL DATA.

You are hereby informed that once the purpose or purposes of the processing have been fulfilled, and when there is no legal or regulatory provision to the contrary, we will proceed to the cancellation of the data after blocking them, for their subsequent deletion.

TWELFTH – SECURITY AND STORAGE

ACSAN has implemented physical, technological and administrative security measures to protect your personal data from unauthorized processing, for this, the information you provide is stored in databases that have the highest security technology necessary to prevent information leaks.

ACSAN will use its best efforts to protect the privacy of your personal information and data. It may happen that by virtue of court orders, or legal regulations, ACSAN may be required to disclose information to authorities or third parties, or in cases where third parties may intercept or access certain information or data transmissions in which case ACSAN will not be liable for information that is disclosed in such forms.

THIRTEENTH.- LEGAL PROVISIONS.

This Privacy Notice complies with all current provisions stipulated in the Federal Law for the Protection of Personal Data in Possession of Individuals, its Regulations, and other applicable legal provisions.