PRIVACY NOTICE

This Privacy Notice applies to personal information collected about the Owner, by Corporación CLC Solutions, SA de CV , a commercial company constituted and existing under the laws of Mexico (hereinafter “ CLC ” or “ us ”), with conventional address located at: Torre Alta, Av. Roble 300, Piso 14, Col. Valle del Campestre, CP 66265, San Pedro Garza García, Nuevo León, México (hereinafter “ CLC ” or “ us ”) and with a portal internet: http://clcsolutions.com.mx

The protection of your privacy and the lawful use of your Personal Data is a matter of the highest priority for us, so we are responsible for the use and protection of your Personal Data that is provided to us through any means, including through the use of the Internet Portal and/or its respective subsites. In view of the above, we have created this Privacy Notice (hereinafter, the “Privacy Notice”), which establishes the terms and conditions under which we will carry out the Processing of your Personal Data for the purposes of protect your privacy and your right to informational self-determination, in accordance with the provisions of the Political Constitution of the United Mexican States, the Federal Law on Protection of Personal Data Held by Private Parties (the “Privacy Law”), the Regulation of the Federal Law on Protection of Personal Data Held by Private Parties (the “Privacy Law Regulations”) and the other legal provisions applicable in Mexico (hereinafter, all of the above will be referred to jointly or indistinctly as, "Applicable Laws").


I. DEFINITIONS.-

For the purposes of this Privacy Notice, the definitions of the terms-concepts that are not specified or provided for in this document will have the same meaning attributed to said terms in the Privacy Law, the Regulations of the Privacy Law. and/or Applicable Laws.

II. CONSENT OF THE OWNER.-

You, in your capacity as 'Owner', declare and guarantee that:

a) This Privacy Notice has been made available to you and consequently made known by CLC prior to the collection and/or Processing of your Personal Data,
b) That you have read, understood and agreed to the terms indicated in this Privacy Notice, therefore you grant your consent regarding the processing of your Personal Data in accordance with the provisions of the Applicable Laws,
c) That it has complied and will comply with all its obligations established in the Applicable Laws and in this Privacy Notice,
d) That the Personal Data provided by the Owner to CLC are clear, correct and updated for the purposes for which they were collected,
e) That you are trained, empowered and/or authorized to provide CLC with said Personal Data,
f) That he is of legal age in full use of his mental faculties,
g) That you grant your express consent for CLC and/or its Affiliates or Subsidiaries, through its Managers, to carry out transfers of Personal Data to third parties, national or foreign, with the understanding that the treatment that said third parties give to your Personal Data must comply with the provisions of this Privacy Notice,
h) That you will not directly or indirectly provide CLC with any Sensitive Personal Data, understood as those personal data that affect the most intimate sphere of the Owner, or whose improper use may give rise to discrimination or entail a serious risk for the Owner, including racial origin. or ethnicity, present and future health status, genetic information, religious, philosophical and moral beliefs, sexual preference, political opinions and/or union membership (hereinafter and collectively, the “ Sensitive Personal Data ”), and
i) That in the event that the Personal Data collected includes sensitive or financial Personal Data, whether provided in printed format or using electronic means, these are acts that constitute your express consent as its owner.
j) That in the event that the Owner does not object to the terms of the Privacy Notice, its content will be considered agreed and consented to and that the Owner's consent may be revoked at any time by the Owner.

The Processing of your Personal Data will be carried out in accordance with this Privacy Notice. From the moment you use the Portal and/or any of its subsites, it is understood and assumed that you are aware of this Privacy Notice and you grant your consent for the Processing of your Personal Data in accordance with it, without prejudice to that said authorization or consent may be recorded or granted through any other forms or means.

III. PERSONAL DATA THAT WILL BE SUBJECTED TO PROCESSING. -

The collection of Personal Data may be carried out by telephone communication with the Controller or with its Managers, employees or by direct delivery to the Controller, through the use of emails and/or short text messages, through the use of their sites. Web, through the use of automatic data capture tools. Which allow us to collect the information that your browser sends to said websites, such as the type of browser you use, the user language and the IP address of the websites you used to access the sites of the Controller or Processors.

The following are examples, but not limited to, of information that the Controller may collect: name and surname; birthdate; address, whether private, work or tax; email address, personal or work; identification name on social networks; telephone number, home or work; cell phone number; bank account number; key to the Federal Taxpayer Registry (RFC); Unique Population Registry Code (CURP).

Among the documentation that can be collected by CLC to verify the identity of the Owner of the Personal Data is the voter ID card; the national military service identity card released; the professional license; passport; migratory form; the registration card in the RFC; the registration card with the CURP; proof of address; the special credit report issued by a Credit Information Society.

IV. SENSITIVE PERSONAL DATA. -

CLC does not knowingly collect or carry out the Processing of Sensitive Personal Data or Personal Data of minors, persons in a state of prohibition or incapacity, and encourages parents and/or guardians to take an active role in online activities. of their children and/or representatives. In the event that any Personal Data is considered to constitute Sensitive Personal Data or has been provided by a minor, an incapacitated person or a person in a state of prohibition in violation of this Privacy Notice, such Personal Data will be deleted immediately. brevity. If you are aware that any Personal Data collected by CLC constitutes Sensitive Personal Data or has been provided by a minor or by an incapacitated person or in a state of prohibition, please contact the Personal Data Department at the email: rights arco privacy notice administration rightsarco@clcsolutions.com.mx or by writing to the following address: Torre Alta, Av. Roble 300, Piso 14, Col. Valle del Campestre, CP 66265, San Pedro Garza García, Nuevo León, México.

V. AUTOMATIC DATA COLLECTION (WHEN BROWSING AND WEB PAGES).-

Among the automatic data capture tools used by CLC on its sites and/or web pages and/or subwebsites, there are cookies, Web beacons and links in emails. Links in CLC emails. Emails that include links that allow CLC to know if you activated said link and visited the destination website, and this information may be included in your profile. If you prefer that CLC not collect information about your interaction with such links, you may choose to modify the format of CLC communications (for example, having the message received in text format and not in HTML format) or You can ignore the link and not access its content.

By the mere fact of visiting and browsing this Website, no data is automatically recorded that allows users to be identified by name. However, certain information is collected that is recorded in CLC systems (e.g., type of Internet browser, operating system, IP address from which the Web pages are accessed) in order to improve user navigation and management of the Web itself. Likewise, the Website may use cookies and similar technologies whose use is subject to the consent of the users in accordance with the Cookies Policy. For more information, visit our cookie policy.


Use of Cookies.- Cookies are small data files transferred by our website to the hard drive of your computer or mobile device when you browse our Portal and/or other website subsites. Cookies allow the Internet server to collect information that will make your use of our Portal and other website subsites easier and more convenient. Cookies add convenience that saves you time when you return to a website. Cookies cannot be used to operate programs or deliver viruses to your computer or mobile device. We use Cookies to obtain non-personal information from online visitors. Cookies track the type of browser, operating system and Internet service provider and allow us to tabulate the total number of visitors to our Portal and other website subsites.

You can disable the use of Cookies on your computer or mobile device, or program them to notify you when Cookies are sent to you, using the preferences icon on your browser. Disabling Cookies may disable various functions of our Portal and/or other website subsites, or cause them not to operate or display correctly.

For the purposes of carrying out the purposes described in this Privacy Notice, we may collect and carry out the Processing of the following Personal Data and information of people who visit our Portal or subwebsites:

a) Identification and contact information. Full name, address (whether home or work), telephone number (whether home or work), cell phone number (whether home or work), email address (whether home or work), employer or company who belongs and job position.

b) Data coming from publicly accessible sources and/or received via consented transfers. Data and information from public registries, directories, social networks and other lawful sources available on the market, as well as Personal Data that has been shared with us by third parties to whom you have previously authorized.

c) Data to access online services. Username, password and other credentials managed by you on our Portal to access our online services.

d) Personal data collected by automatic capture tools on our Portal or subwebsites (Cookies). Type of browser, language, domain and server used to access the Internet, means of identifying the session with the Portal or subwebsites, passwords to access the Portal or subwebsites, the date and time of your visit and the time spent on our Portal or subwebsites, the pages visited on our Portal or subwebsites, your IP address, the reference URL (Uniform Resource Locator), the operating system of the computer system used to access our Portal or subwebsites, information about of the browser and the devices used to access our Portal or subwebsites, and information derived from and/or related to the interaction you have with our emails and/or our Portal or subwebsites.

The Personal Data described in the sections provided in this section are collected through the use of the Portal and/or any of the following methods: (i) the voluntary and direct provision of your information through our printed or digital formats, ( ii) the voluntary and direct provision of your information through the Portal or any of our subsites or those of the other companies of the corporate group to which CLC belongs, (iii) the voluntary and direct provision of your information by email or by telephone, (iv) the use of publicly accessible sources and other sources available on the market, including public records and social networks, and (v) the transfer by other companies of the corporate group to which CLC belongs, and other transfers consents made by third parties. The Personal Data and other information described in the previous paragraphs may be contained in different documents, whether printed or digital. CLC may ask you to show original documentation and/or provide a copy of it as evidence to support the information you provide.

VI. BASIS. -
The basis for the processing and transfer of personal data is article 4, 5, section I, 7, 21, 22, section V, 27, 28 and other relatives of the Federal Law on Protection of Personal Data Held by Private Parties, the Regulations of the Federal Law on Protection of Personal Data Held by Private Parties and the other legal provisions applicable in Mexico.

VII. PURPOSES OF THE TREATMENT. -
We will use the Personal Data that we collect from you for the purposes detailed below:
a) Confirm your identity and contact details,
b) Manage your access to our Portal and other website subsites,
c) Create and manage your user profile with the information necessary to offer you our products and/or services,
d) To review and respond to your requests and/or comments,
e) To analyze the way you interact with our brand, products and/or services through various channels, including our Portal and other subsites, applications, social networks and marketing messages,
f) To comply with the obligations arising from the legal or commercial relationship between you and us,
g) Request, purchase, contract, change or cancel services or return products, offered by CLC,
h) Make payments online; request an invoice or digital tax receipt; request a quote, on products and services; request delivery, repair or warranty fulfillment of products; contact Customer Service; participate in surveys; use the different services of their corresponding Websites including downloading content and formats,
i) Share your comments or suggestions about products and services,
j) Process payments and any other activity of a nature analogous to those described in the previously mentioned sections. to comply with the applicable legal provisions, as well as meet and comply with the requirements of competent authorities, and
k) To send you notifications regarding changes to this Privacy Notice.

Additionally, we will use your personal information for the following secondary purposes, which are not necessary for the requested service, but which allow and facilitate us to provide you with better service:

a) To evaluate the quality of the service and carry out the improvement of our products and services,
b) Carry out studies on the interests and behavior of your clients, consumers, suppliers, and those third parties with whom you deal,
c) For marketing and consumer purposes (marketing, retargeting and advertising) in order to acquire and offer personalized, advertising or commercial prospecting products and services, including to communicate news, promotions and/or to invite you to events,
d) Prepare internal statistics that indicate the services and products most appreciated by the different segments of its clients, consumers, suppliers,
e) To send you our newsletter or alerts ( newsletter ),
f) Formalize the transactional process with your clients, consumers, suppliers and other third parties with whom you deal,
g) To communicate changes or news regarding our products and/or services,
h) If applicable, verify the credit and/or payment capacity of the Holder, which may be done through credit information companies, in terms of the Law to regulate Credit Information Companies, and
i) Check the commercial transactions carried out by the Owner with the Controller.

If you do not want your Personal Data to be used for these secondary purposes, please contact our Personal Data Department in accordance with the procedure provided in section VI of this Privacy Notice. The refusal to use and Process your Personal Data for these secondary purposes may not be a reason for us to deny you the services and/or products requested.

Your Personal Data may be used for purposes other than those indicated above as long as said purposes are analogous and compatible with those described above. In the event that CLC requires to use your Personal Data for purposes other than those provided for in this Privacy Notice, it will be notified in writing, by telephone, electronically or by any optical, sound, visual or by any other means that technology allow now or in the future, explaining the new uses and/or purposes that are intended for your Personal Data in order to obtain your corresponding consent, whether express or tacit.

VIII. TRANSFER OF PERSONAL DATA. -

Having read, understood and agreed to the terms set forth in this Privacy Notice, the Owner expresses his consent for the Controller or any Processor to transfer Personal Data to national or foreign third parties, with the understanding that the treatment that said third parties give to The Personal Data of the Owner must comply with the provisions of this Privacy Notice.

Your Personal Data may be transferred, inside and outside the country, with the following people and for the following purposes:

Recipient of Personal Data:
Other companies in the same corporate group to which CLC belongs.

Purpose:
For corporate management and/or operational support of the corporate group of companies to which CLC belongs; for statistical purposes; and for commercial analysis or prospecting purposes.

Recipient of Personal Data:
Competent authorities

Purpose:
To comply with any legal requirements or requests from competent authorities; to safeguard a public interest; for the procurement or administration of justice; for the recognition, exercise or defense of a right in a judicial process; as well as in other cases permitted by Applicable Laws and other regulations in force.

Recipient of Personal Data:
Prospective buyers or acquirers

Purpose:
In the event of a merger or acquisition of CLC or of other companies in the same corporate group to which it belongs, so that the prospective acquirer or buyer can analyse the legal and/or commercial situation of CLC.

Recipient of Personal Data:
Merger/Acquirer

Purpose:
In the event of a merger, spin-off or acquisition of CLC, so that the acquiring company can use the data in the same way that CLC used it.


IX. LIMITATION OF USE AND DISCLOSURE OF INFORMATION.-

The Controller and/or its Managers will retain the Owner's Personal Data for as long as necessary to process their requests for information, products and/or services, as well as to maintain accounting, financial and audit records in terms of the Law of Privacy and current commercial, fiscal and administrative legislation. In addition to controlling the disclosure of such data or information to business partners. The Personal Data of the Owner collected by the Controller and/or its Managers will be protected by appropriate administrative, technical and physical security measures against damage, loss, alteration, destruction or unauthorized use, access or treatment, in accordance with the provisions in the Privacy Law and the administrative regulation derived from it.

Notwithstanding the above, CLC does not guarantee that unauthorized third parties cannot have access to the physical or logical systems of the Owners or the Controller or to the electronic documents and files stored in their systems. Consequently, CLC will in no case be responsible for any damages that may arise from such unauthorized access.

X. ARCH RIGHTS.-

You may at any time (i) access your Personal Data that is in our possession, (ii) rectify your Personal Data when it is inaccurate or incomplete, as long as it is not impossible or requires disproportionate efforts, (iii) cancel your Personal Data. , except in the cases provided for in the Applicable Laws or in this Privacy Notice, (iv) oppose the Processing of your Personal Data for legitimate reasons and for specific purposes, except in those cases in which said Personal Data is necessary for CLC comply with your legal obligations, and (v) decline or revoke your consent and oppose the Processing of your Personal Data, except in those cases in which said Personal Data is collected and/or processed for purposes that are necessary to receive our products and/or or services, and/or to comply with the obligations derived from the legal or commercial relationship between us and you (collectively, the “ARCO Rights”).

XI. PROCEDURE TO EXERCISE ARCO RIGHTS AS THE OWNER OF PERSONAL DATA.

You have, at all times, your ARCO Rights by submitting a request that must contain the following information and documentation:

1. Name of the Owner, address, telephone number and email address or any other means of contact to communicate the response to your ARCO Request.

2. Documents that prove your identity (simple copy in printed or electronic format of your voter ID, professional card, passport or Immigration Form) and, where appropriate, simple copy in printed or electronic format of the public deed or power of attorney. corresponding of their legal representative, along with a copy of their respective voter credentials or passports, valid, on both sides, if applicable.

3. The clear and precise description of the ARCO rights and Personal Data with respect to which you seek to exercise any of the Rights.

4. Any other element or document that facilitates the location of the Owner's Personal Data.

In the case of rectification requests: they must indicate the modifications to be made and provide the documentation that justifies said modification (when appropriate).

For the purposes of requests for cancellation of Personal Data, in addition to the provisions of this Privacy Notice, the provisions of the Privacy Law will apply , including the exception cases for cancellation of Personal Data indicated therein.

The Responsible Person or persons in charge of CLC will respond to the respective Owner within a maximum period of 20 (twenty) business days, counted from the date on which the request was received to inform the Owner whether said request is appropriate or not. If the ARCO Application is accepted, it will become effective within 15 (fifteen) business days following the date on which CLC has communicated the corresponding acceptance to the Owner. The aforementioned deadlines may be extended only in terms of the Privacy Law.

In the event that the documents and/or information provided in your ARCO Application are erroneous or insufficient, or the corresponding accreditation documents are not accompanied, we may ask you to provide the necessary elements or documents to process it. You will have 10 (ten) business days following the date on which you receive our request for documents and/or additional information to provide said documents and/or additional information, with the understanding that if you do not provide the requested documents and/or information during this period, your ARCO Application will be considered not submitted.

In the case of requests for access to Personal Data, the disclosure of said Personal Data must be made after verification of the identity of the Owner of the Personal Data and, where applicable, that of his legal representative. Access to your Personal Data will be considered to have been granted when it is made available to you, regardless of the medium or format.

Regarding the revocation of your consent, please keep in mind that this will only proceed in certain cases in accordance with the provisions of the Applicable Laws and this Privacy Notice, with the understanding that said revocation of consent will not have retroactive effects. and may not have the effect of preventing us from complying with our obligations.

The delivery of Personal Data will be free, you will only be responsible for covering the justified shipping costs or the cost of reproduction in copies or other formats. In the event that the Owner reiterates his request in a period of less than twelve months, he must cover the corresponding costs equivalent to 1.5 days of the Measurement and Update Unit (UMA) in force in terms of the Privacy Law, unless there are modifications. material to the Privacy Notice that motivate new queries.

XII. SECURITY MEASURES.-

CLC is committed to using its best efforts to safeguard the confidentiality of your Personal Data; Therefore, in compliance with the provisions of the Applicable Laws, CLC maintains the security measures reasonably necessary in order to protect your Personal Data to prevent its loss or unauthorized destruction, its theft, misplacement or unauthorized copy, its use, access or unauthorized treatment, or its damage, alteration or unauthorized modification.

Only those people strictly authorized by us will have access to your Personal Data, including our representatives and employees, and the representatives and employees of the other companies of the same corporate group to which CLC belongs, as well as those third parties who, individually or jointly in their as Processors carry out the processing of your Personal Data on behalf of CLC.

CLC undertakes to allocate authorized resources to implement personal data protection programs and policies, develop mandatory and enforceable personal data protection policies and programs within the organization of the person responsible, implement a training program and updating personnel on obligations and other duties regarding the protection of personal data, periodically reviewing personal data security policies and programs to determine the modifications that are required, establishing an internal and/or external supervision and surveillance system, including audits, to verify compliance with personal data protection policies, establish procedures to receive and respond to questions and complaints from the owners, design, develop and implement their public policies, programs, services, computer systems or platforms, electronic applications or any other technology that involves the processing of personal data, in accordance with the provisions set forth in the applicable Law and the others that are applicable in the matter and strive to ensure that its public policies, programs, services, computer systems or platforms, electronic applications or any other technology that involves the processing of personal data, complies with the applicable Law and the others that are applicable in the matter.

Likewise, CLC will seek to create a management system for the processing of personal data, to document and contain security measures for the processing of personal data, and thus, establish, implement, operate, monitor, review, maintain and improve the treatment and security of personal data, in accordance with the provisions of the applicable Law and the others that may be applicable in the matter.

XIII. TRANSPARENCY UNIT.-

For any communication about our Privacy Notice and/or exercising your ARCO rights, either directly or through your legal representative, please contact our Personal Data Department by email: arco rights privacy notice administration rightsarco@clcsolutions.com.mx or at the address located at: Torre Alta, Av. Roble 300, Piso 14, Col. Valle del Campestre, CP 66265, San Pedro Garza García, Nuevo León, México.

XIV. CHANGES TO THE PRIVACY NOTICE.-

CLC reserves the right to modify and/or update this Privacy Notice periodically and/or at any time to reflect changes in our information practices, our operations or any of the applicable Laws. It is the Owner's responsibility to periodically review the content of the Privacy Notice on the site http://clcsolutions.com.mx and/or on subwebsites, where the changes made will be published together with the date of the last update. In scope, but without obligation for CLC, changes and/or updates may be sent to the email address provided. The Controller will understand that if you do not express otherwise, it means that the Owner has read, understood and agreed to the terms set forth therein, which constitutes your consent to the changes and/or updates regarding the processing of your Personal Data. The client/supplier declares to have read and understood the Privacy Notice that, in compliance with the provisions of the Law on Access to Information and Protection of Personal Data Held by Private Parties, is available on the website http://clcsolutions. .com.mx and that you agree to submit to the same regarding the management of the data that you have provided to CLC, and that remain in its custody, in the terms of what is indicated in said Privacy Notice.

Last update: August 5, 2024.