PRIVACY NOTICE INTEGRAL DE FIDELIS TWO S.A. DE C.V.

IDENTITY AND ADDRESS

FIDELIS TWO S.A. DE C.V. with a registered address at Street Robert Schumann 4898, Colonia Lomas del Seminario, C.P.45038, Zapopan, Jalisco Mexico (hereinafter the "Company"); is constituted as responsible for processing the personal data you provide us.  The personal data you provide to Fidelis Two, S.A. de C.V.  will be protected in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Persons (LFPDPPP), (hereinafter the "Law"), it own regulations and other applicable provisions.

PERSONAL DATA TO BE PROCESSED

The personal data that the Company will collect from you through the information and/or documentation provided personally or directly by you, or those obtained indirectly, and exclusively for the purposes indicated in section III of this Privacy Notice are: a) name; b) address c) email d) telephone number; e) contact information;  f) Federal Taxpayer Registry number; g) financial or patrimonial data; h) data related to your occupation.

The Company does not collect or process your sensitive personal data

PURPOSES OF PROCESSING PERSONAL DATA

The personal data collected by the Company from you are used to:

1. The preparation of contracts, agreements, payments, quotes, as well as other commercial matters arising from the agreement and/or main operation.
2. Keep a record of internal processes derived from the policies of the companies of the same corporate group which the Company belongs to.
3. Document the operations and/or transactions that are carried out.
4. To contact you and send you relevant information about different topics.
5. Request products and/or services,
6. Provide payment information.
7. To Comply with the obligations arising from the legal relationship created or that will be created with you. Therefore, your personal data is used specifically for the creation and administration of your account in accordance with our systems data and to contact you.
8. For preparation and monitoring of purchase or service orders; draft agreements; processing payments; send or receive invoices; supplier records, and in case of internal audits. These purposes are necessary for the correct development of the legal relationship with the Company.

 Further, we will use your personal data strictly and exclusively for the following purposes that are not necessary for the legal relationship between the Company and you as the owner of the personal data:

1. To demonstrate the materiality of the operations carried out by the Company in tax matters.
2. To Provide them in case they are required by tax authorities or any other authority.
3. To show them to judicial, administrative, or labor authority in any claim or conflict as required.
4. In addition, the Company may process your personal data to create the database of suppliers, for marketing, advertising, or commercial prospecting purposes. Although these purposes are not necessary to initiate or maintain your legal relationship with the Company, they allow and facilitate customer support.

The Company will only process your personal data as long as it will be necessary to comply with the purposes described in this Privacy Notice and/or in accordance with the provisions of the Law and the applicable legal and regulatory provisions.

THE COMPANY HAS IMPLEMENTED A MECHANISM SO THAT YOU CAN EXPRESS YOUR REFUSAL TO PROCESS YOUR PERSONAL DATA IN RELATION TO THE PURPOSES THAT ARE NOT NECESSARY FOR THE LEGAL RELATIONSHIP BETWEEN YOU AND THE COMPANY.

You are informed that you have at your disposal the email address avisoprivacidad@fidelismg.com to express your refusal or non-authorization for the processing of your personal data, particularly regarding the purposes that are not necessary to create, modify and continue with the legal relationship the Company has with you.

Likewise, for these purposes, you may call the following telephone number 9982516801 of Grupo Fidelis, Monday to Friday from 9:00 a.m. to 6:00 p.m., with the understanding that the refusal expressed by telephone, must be ratified in writing, by sending a communication to the aforementioned email.

TRANSFER OF PERSONAL DATA

The Company does not transfer your personal data to third parties, with the exception of its Head Office, controller, subsidiary, or affiliate under the same control, or any company of the same economic or corporate group that operates under the same internal processes and policies.

Additionally, the Company may send your data to domestic or foreign third parties, providers of services necessary for the maintenance and fulfillment of the Company´s legal obligations, as well as the obligations derived from the legal relationship that you have with the Company.

Specifically, the Company may send all or part of your personal data to internal audit service providers, legal, foreign trade, and customs services, or any other service provided by suppliers of the company on a regular basis, such as transportation services, transfers, among others.

The Company will ensure through the   signing of confidentiality agreements and / or other documents, these  third parties maintain adequate security, administrative, technical, and physical measures to protect your personal data, and  that  third parties only use your personal data for the purposes they were collected in accordance with this Privacy Notice.

Likewise, in the event of an official request, the Company may transfer your personal data to the requesting authority.

Therefore, by ACCEPTING this Privacy Notice, you expressly accept the transfer of your data in the terms referred in this document, with the understanding that your consent is only required for the purposes of the third paragraph of this section in accordance with the articles 36 and 37 of the Law.

MEANS FOR THE EXERCISE OF “ARCO” RIGHTS

In the cases provided for by the Law, you can exercise your rights of Access, Rectification, Cancellation or Opposition (ARCO rights) at any time regarding the use that the Company gives to your personal data. To   exercise any of your ARCO rights you must:

1. Submit the respective request by filling out the Sole Format for the Exercise of ARCO Rights, the request must be sent to the email: avisoprivacidad@fidelismg.com, attaching the documents established in the format.
2. Confirm your identity by sending a copy of your official identification document, also show the original, or the authority of your legal representative through a public instrument, proxy letter signed before two witnesses or your statement in personal appearance and.
3. In case of a request for rectification of your personal data, submit the documentation that supports your request.

You are informed that the Company may deny access to personal data, make the rectification or cancellation, or grant opposition to process them, whether totally or partially, in the following cases:

• When you are not the owner of the personal data, or your legal representative is not duly accredited to act as such.
• When in our database, your personal data is not found.
• When the rights of a third party are infringed.
• Where there is a legal impediment, or the of a competent authority, that restricts access to personal data or does not allow the rectification, cancellation, or opposition thereof, and
• When the rectification, cancellation, or opposition has been previously made.

The Company will respond to your request not-exceeding a 20-day term, will communicate you in writing the corresponding determination at the address indicated above, or to the email  through which you submitted your request, as the case may be. Our response may include simple copies, electronic documents in editable or PDF format, recordings or videos, or any other means of reproduction that the Company deems relevant to give a timely response to your request.

In the event of a refusal of access to your personal data, you will be informed of the reason for our decision within the term indicated in the previous paragraph, with the evidence we deem appropriate.

In case you have doubts about how to exercise your ARCO rights, you can contact our legal department through the email  avisoprivacidad@fidelismg.com; or at the address, Monday to Friday 9:00 hrs. to 18:00 hrs.

 

MECHANISMS AND PROCEDURES FOR THE REVOCATION OF CONSENT

Furthermore, when the Law allows it, you may limit or revoke the consent that, you have granted to the Company for processing your personal data.

To limit or revoke your consent, you must submit the respective request and prove your identity, or if applicable, your representative’s authority, in accordance with the provisions and complying with the requirements referred to in the previous clause of this Privacy Notice. The Company will analyze your request and will let you know its determination within a period not exceeding 20 days at the address to which you filed your request, or to the email through which you submitted your query, as the case may be.

OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA

You are informed that the Company has designed and implemented very strict internal policies and measures to limit the use and disclosure of your personal data. The Company on a regular basis conducts informative seminars aimed at the staff who oversees the personal data processing for the purposes set out in this Privacy Notice are aware of such limitations and comply with the principle of responsibility as provided by the Law and its regulations.

Likewise, in case you decide not to receive or limit the periodicity to receive promotions or communications through our advertising campaigns, you can contact the legal department of the Company through the email address avisoprivacidad@fidelismg.com or at the address mentioned in section V of this Privacy Notice. The Company will analyze your request and let you know its determination within a period not exceeding 20 days at the address to which you filed your request, or to the email address through which you submitted your query.

USE OF COOKIES AND WEB BEACONS

The Company’s websites and online services are based on using Cookies and Web beacons. For this Privacy Notice, Cookies are defined as the data file stored on the hard drive of a user’s computer equipment or electronic communications device when browsing a specific website, which allows the exchange of status information between the website and the user´s browser. Status information may reveal session identification means, authentication, or user preferences, as well as any data stored by the browser regarding the website.

Additionally, Web beacons are defined as the visible image inserted within a website or email, which is used to monitor user behavior in these media. Through these, you can obtain information such as the source IP address, browser used, operating system, time when the website was accessed, and in the case of email, the association of the above data with the recipient.

By accessing and continuing to browse our websites, or by receiving and interacting with our emails, you consent that the Company collects and processes your personal data. The use of this technology is necessary for the proper functioning of our website, to fulfill the purposes of processing your personal data, as well as for operational, technical, and security reasons.

The Company will process your personal data solely and exclusively in accordance with this Privacy Notice, as well as to comply with the obligations arising from the legal relationship you have with the Company.

However, if you wish to disable such technologies, you are informed that you may contact the Company´s legal department through the email avisoprivacidad@fidelismg.com, or at the address mentioned in section V of this Privacy Notice. The Company will analyze your request and let you know its determination within a period not exceeding 20 days at the address to which you filed your request, or to the email through which you submitted your query, as the case may be

CHANGES TO THIS PRIVACY NOTICE

The Company may make changes to this Privacy Notice, in which case, you may know the modifications and/or updates to it at the website https://www.fidelismarketinggroup.com/privacy-policy or by requesting it directly to the Company’s legal department following the route specified in this Privacy Notice.

I state that I have read and agree with the terms and conditions of this Privacy Notice made available to me by the Company so, in accordance with article 11 of the Regulations of the Law I grant my express consent for the processing of my personal data in terms of what is established herein.

This document comes from its Spanish language version, and it is translated into the English language in good faith by Fidelis, however, it is understood and accepted that, in case of doubt or controversy regarding its interpretation, the Spanish version will prevail in all cases.

Last update October 26, 2022.