VINKOS TECNOLOGÍA, S.A. de C.V, (hereinafter “Vinkos”) with address at Homero street, number 203, 2nd floor, Chapultepec Morales neighborhood, Miguel Hidalgo Territorial Demarcation, C.P. 11570, Mexico City, in compliance with the Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares), and other related and applicable provisions (hereinafter collectively “The Law”), in its capacity as the data controller for the Personal Data provided to it, hereby informs you through this document (the “Privacy Notice”) of its privacy policy, as well as the treatment it will give to Personal Data collected directly: (i) at Vinkos’ address; (ii) by telephone; (iii) by email; and/or; (iv) through its website https://vinkos.com (the “Portal”); guaranteeing that the processing of Personal Data you provide through the aforementioned means will be carried out in a legitimate, controlled, and informed manner, preserving your right to privacy and informational self-determination, through the use and implementation of technical, physical, and administrative security measures, aimed at preventing any damage, loss, alteration, destruction, unauthorized use, access, or processing.

PERSONAL DATA SUBJECT TO PROCESSING

In accordance with The Law and for the purposes of this Privacy Notice, personal data shall be understood as information concerning an identified or identifiable natural person (the “Personal Data”). The types of Personal Data that will be collected from you (hereinafter the “Data Subject”) are as follows: full name of the data subject, company for which they work or represent, telephone number, and email address.

SENSITIVE PERSONAL DATA

Vinkos will not request or collect sensitive personal data, understood as personal data that affects the Data Subject’s most intimate sphere or whose improper use may lead to discrimination or pose a serious risk to them. In particular, those considered sensitive are those that may reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union affiliation, political opinions, sexual preference (the “Sensitive Personal Data”).

PURPOSES

The Personal Data provided by the Data Subject to Vinkos will have the following purposes:

1.     To establish a commercial relationship and identify you as a client.

2.     To verify the information you have provided.

3.     To create your client file.

4.     To establish, suspend, or terminate the commercial relationship.

5.     To guarantee the confidentiality of Vinkos’ information.

6.     To comply with legal obligations derived from the commercial relationship.

7.     To offer products and services, either physically, by telephone, electronically, or by any other technology or means available to Vinkos.

8.     To inform you of new products or services that may be of interest in relation to the contracted service.

9.     To carry out any type of collection management for outstanding payments derived from the commercial relationship.

10.  For internal analysis and statistical preparation.

The Data Subject may, in accordance with the mechanisms established herein, deny, revoke their consent, as well as object to the processing of their Personal Data for purposes other than those strictly necessary for the fulfillment of the established purposes.

DATA TRANSFER

Vinkos will not transfer your Personal Data. In the event that a service requiring the transmission of Personal Data is requested, the Data Subject will be informed if their consent is required for their Personal Data to be transferred for the purpose of providing the requested service.

Notwithstanding the foregoing, Vinkos may at any time reveal and transmit the Information when:

1.     The transfer is provided for in a Law or Treaty to which Mexico is a party.

2.     The transfer is made to controlling companies, subsidiaries, or affiliates under the common control of Vinkos, or to a parent company or any company of the same Vinkos group that operates under the same internal processes and policies.

3.     The transfer is necessary by virtue of a contract concluded or to be concluded in the interest of the Data Subject, by Vinkos and a third party.

4.     The transfer is necessary or legally required for the safeguarding of a public interest, or for the procurement or administration of justice.

5.     The transfer is precise for the recognition, exercise, or defense of a right in a judicial process.

6.     The transfer is precise for the maintenance or fulfillment of a legal relationship between Vinkos and the Data Subject.

ARCO RIGHTS

The Data Subject of the Personal Data provided to Vinkos is responsible, in any case, for the veracity, accuracy, validity, and authenticity of the information provided, and undertakes to keep it duly updated.

The Data Subject shall have the right to: i) Access their Personal Data held by Vinkos and details of its processing. ii) Request the rectification or correction of their Personal Data when it is inaccurate, incomplete, or not updated. iii) Request the cancellation of their Personal Data from Vinkos’ files, records, files, and systems, so that they are no longer in its possession. iv) Object to the processing or demand its cessation, subject to the provisions of Article 26 of the Federal Law on Protection of Personal Data Held by Private Parties.

Likewise, the Data Subject may at any time revoke the consent granted for the processing of their Personal Data, so that its use is discontinued.

In the event that the Data Subject requires: to revoke their consent; to limit the use and/or disclosure of their Personal Data; or to exercise any of their rights of access, rectification, cancellation, or opposition (“ARCO Rights”), they must send a request: (i) to the email mariam@vinkos.com, needing to confirm the reception of said document at the phone number 55 2624 1785, Monday to Friday from 10:00 to 13:00 hours, on business days, as applicable.

For the above, the Data Subject must inform Vinkos, clearly and precisely, the Personal Data they wish to be rectified, canceled, or reviewed, as well as the purpose for which they provided it, and generally comply with the requirements mentioned in Article 28 of the Federal Law on Protection of Personal Data Held by Private Parties:

•       Full name of the Data Subject and their address, or any other means to receive notifications.

•       Documents that prove the identity of the Data Subject or, where appropriate, the legal representation and identity of their representative.

•       A clear and precise description of the Personal Data regarding which one seeks to exercise any of the ARCO Rights, unless it is the right to access.

•       A description of the ARCO Right to be exercised, or what the Data Subject requests.

•       Any other element or document that facilitates the location of the Personal Data.

Vinkos will have a period of no more than 20 business days after the reception of the referred request to respond to it, and 15 more business days to make the exercise of the requested right effective, if it is appropriate.

The aforementioned deadlines may be extended for an equal period, provided that the circumstances of the case justify it.

MODIFICATIONS

Any changes or updates to this Privacy Notice may be consulted directly on the Portal in the “Privacy Notice” section.

CONSENT

By providing their Personal Data through the Portal, the Data Subject confirms and accepts that they have read and grant their consent to comply with the stipulations in this Privacy Notice. Likewise, in case of providing Sensitive Personal Data and/or patrimonial and/or financial data, their consent will be collected expressly and in writing, with their handwritten signature, electronic signature, or any authentication mechanism established for that purpose, serving as proof.