NOTICE OF PRIVACY

Notice of Privacy

Escartín, Arciniega y Asociados, S.C. Law firm specializing in Commercial Law, and Consumer Law (hereinafter, “Escartín Abogados”), makes available to you this privacy notice (the “Privacy Notice”) that contains the policy under which they will be collected and processed the personal data ("Personal Data") of the natural persons (the "Owners") mentioned in section V of this Privacy Notice.

1. Regulatory Framework

Escartín Abogados, issues this Privacy Notice in compliance with the provisions of: (i) the Federal Law on Protection of Personal Data in Protection of Individuals (“Law”); (ii) the Regulations of the Federal Law on Protection of Personal Data Held by Private Parties (“Regulations”), and (iii) the Privacy Notice Guidelines published in the Official Gazette of the Federation on January 17, 2013 ( “Guidelines” and, in conjunction with the Law and Regulations, the “Ordinances”).

1. Objective

The purpose of this Privacy Notice is to delimit the scope and general conditions of the processing of Personal Data and make them known to their Owners, so that they are able to make informed decisions about the use of such Personal Data, and to maintain the control and disposition over them. Likewise, this Privacy Notice allows Escartín Abogados to transparent said treatment and thereby strengthen the level of confidence of its Holders.

1. Address of Escartín Abogados

Escartín Abogados has its address on Blvd. Manuel Ávila Camacho number 118, floor 16, interior 1602, Colonia Lomas de Chapultepec I Section, Miguel Hidalgo delegation, C.P. 11000, Mexico City (the "Domicile").

1. Personal Data Collected

To comply with this section, based on the twenty-second article of the Guidelines, Escartín Abogados may request and store your Personal Data through the following forms: (i) directly when the Holder provides them to Escartín Abogados either in a form physical or via email, or, (ii) indirectly, through other sources of public information, of the global access network (“Internet”).

The Personal Data that will be treated, according to the different categories of the same, are the ones indicated below:

1. General: All those that identify the Holder.

2. Professionals: All those that allow to know the trajectory, experience, reputation and professional capacity of the Holder, as well as his occupation.

3. Labor: All those that allow to identify the personnel that provides services for the Holder, and the terms related to said services.

4. Patrimonial: All those that allow to know the patrimonial situation of the Holder, as well as those necessary to structure or fulfill the corresponding payment obligations.

5. Financial: All those that allow to know the financial situation of the Holder.

6. Products: All those related to the products and / or services that may be acquired by the Holder, and that are specified and / or referenced in tickets or in the corresponding promotional.

7. Contentious: All those that allow to identify any administrative, civil, labor, commercial, criminal or any other controversy in which the Holder can be found related.

Within the categories of Personal Data provided in subsections a), b), c), f) and g) there may be sensitive Personal Data, as these are shared by the Holder for purposes of the relationship or service required by Escartín Abogados. In the event that they are not necessary for the purposes of the treatment indicated in this Privacy Notice, Escartín Abogados will proceed to its immediate cancellation.

In addition to all of the above, the Holder is informed that the Escartín Abogados website: www.escartin.mx does not use cookies, web beacons or any other type of mechanism in remote or local electronic, optical or other communication media. technology, which allow you to collect Personal Data automatically and simultaneously while the Holder makes contact with them.

1. Purposes of the Processing of Personal Data

Escartín Abogados will treat the Personal Data of the people who carry out operations and request the provision of legal services by Escartín Abogados, as legal advice, including those who represent them, (the “Clients”) for the purposes that are listed continuation but not limited to:

1. Purposes that give rise and are necessary for the existence, maintenance and fulfillment of the legal relationship between Escartín Abogados and the Client:

1. Corroborate the identity of the Client, his address and other information provided for the provision of legal services.

2. Verify that the Client has sufficient capacity and powers to sign contracts with Escartín Abogados as part of the provision of legal services, as well as with third parties of interest to the Client.

3. Verify that the Client has the creditworthiness and / or economic solvency to comply with the payment obligations resulting from his charge.

4. The incorporation of the same in the legal instruments that are required for the celebration, assignment, modification, termination and, where appropriate, registration of civil, commercial, labor contracts, among others, which, where appropriate, intends to celebrate the Client, as well as the legal instruments accessory to them.

5. Manage, where appropriate, the records and / or procedures of the Client before the notary public and corresponding authorities.

6. Keep the Client's file updated.

7. Require payments, returns and / or compensation that, where appropriate, are in charge or correspond to the Client, including through the exercise of judicial or extrajudicial actions that may take place.

8. To comply with the obligations derived from the contracts concluded between the Client and Escartín Abogados.

9. Transfer or transfer to a third party, through any legal form, the rights or obligations derived from the aforementioned contracts, as established therein.

10. Maintain the necessary communication with the Client, in order to achieve the purpose of providing legal services, as well as the contracts that are intended and those that are actually concluded.

11. Comply with applicable regulations.

1. Purposes that do NOT give rise and NOT s1. Purposes that DO NOT give rise to and are NOT necessary for the existence, maintenance and fulfillment of the legal relationship between Escartín Abogados and the Client.

1. Prepare surveys, statistics and reports.

2. Marketing and advertising purposes.

3. Report changes in the applicable legislation, as well as the services of Escartín Abogados.

4. Provide references and / or information to third parties who, in any way, are interested in the legal services of Escartín Abogados.

It is made known to the Client that the mechanism that Escartín Abogados has implemented so that it expresses its refusal to process your personal data in accordance with the purposes included in this subsection B) of section V, consists in sending a request that, Under the heading of “Refusal of Treatment of Secondary Personal Data”, the Holder must direct to the Address or to the email address indicated in section VII of this Privacy Notice, observing the requirements indicated in the first paragraph of said section VII, request that will take effect within 3 (three) business days following receipt of it.

Likewise, in the event that this Privacy Notice is not made known to the Client directly or personally, it is made known to the Client that it has a period of 5 (five) business days so that, if applicable, Express your refusal to Escartín Abogados, for the treatment of your personal data in accordance with the purposes included in subsection B) of section V, by sending a request to Escartín Abogados in the terms and conditions indicated in the previous paragraph.

On necessary for the existence, maintenance and fulfillment of the legal relationship between Escartín Abogados and the Client.

1. Prepare surveys, statistics and reports.

2. Marketing and advertising purposes.

3. Report changes in the applicable legislation, as well as the services of Escartín Abogados.

4. Provide references and / or information to third parties who, in any way, are interested in the legal services of Escartín Abogados.

1. Transfer and Transfers of Personal Data

The treatment that Escartín Abogados carries out of the Personal Data may involve the national or international transfer of these. By virtue of the foregoing, the third party recipients or recipients of the Personal Data are established, indicating for this, their type, category or sector of activity.

1. Legal, accounting and / or advisory firms, which are subsidiaries, subsidiaries, are related and / or associated with Escartín Abogados.

2. Judicial and / or administrative authorities against whom Escartín Abogados is bound in terms of law, as well as for the corresponding administration of justice.

In all cases Escartín Abogados will make known to third parties the content of this Privacy Notice.

V1.1. Purposes that Justify Transfers of Personal Data

The purposes that justify the transfer of Personal Data of the Holders are those provided in numerals 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11 of subsection A) and in numerals 1, 2, 3 and 4 of subsection B), all of section V of this Privacy Notice.

Whenever the transfers update the cases of exception to the consent established in article 37 of the Law, the Privacy Notice does not include the provisions of the Twenty-Seventh of the Guidelines.

All of the above, with the understanding that Escartín Abogados can freely make referrals of Personal Data to its service providers for purposes of Escartín Abogados itself, under the Ordinance, these third parties would be only their managers.

1. Means and Procedure for the Exercise of the Rights of Access, Rectification, Cancellation or Opposition

In accordance with the Ordinances, the Holder may exercise against Escartín Abogados their rights of access, rectification, cancellation or opposition (the “ARCO Rights”), with respect to the Personal Data that concern them. For the purposes of the above, the Holder must submit to Escartín Abogados a request by means of a free letter addressed to the Department of Protection of Personal Data of Escartín Abogados itself must contain and be accompanied by the following: (i) name of the Holder and address or other means to communicate the response to your request; (ii) copy of the identification document of the Holder, as well as the original of the same for comparison or, where appropriate, in the case of the representative of the Holder, in addition to the above, the documents that prove the identity of the representative, as well as the public instrument or power of attorney signed before two witnesses, stating the powers granted, or declaration in personal appearance of the Holder; (iii) clear and precise description of the Personal Data with respect to which one seeks to exercise any of the rights of rectification, cancellation or opposition, and (iv) any other element or document that facilitates the location of the Personal Data. This request must be submitted at the address of Escartín Abogados at a time of 10:00 a.m. to 5:00 p.m. or at any time by email addressed to the following email address: contacto@escartin.mx, provided that the electronic instruments are duly submitted certificates that replace the identification of the Holder or, where appropriate, of his representative. The exercise of the ARCO Rights will be free, and the Holder must cover only the shipping, reproduction (simple copy) and, where appropriate, certification of documents. However, if the same Holder reiterates his request in a period of less than 12 (twelve) months, the costs will be the equivalent of 3 (three) times the Unit of Measure and Update in force, unless there are substantial modifications to this section that motivate new consultations.

Escartín Abogados will notify the Holder within a maximum period of 20 (twenty) business days from the date on which the corresponding ARCO application has been received, the determination adopted so that, if it is appropriate, it will be effective within 15 (fifteen) business days following the date on which the response is communicated. The term may be extended only once, for each request, up to an additional period of 15 (fifteen) business days, provided Escartín Abogados justifies the extension to the Holder, which must be notified before the expiration of the original term. For this purpose, Escartín Abogados will write down in the acknowledgment of receipt that the Holder delivers the corresponding date of receipt.

The period indicated in the previous paragraph will be interrupted in the event that Escartín Abogados requires additional information from the Holder, since the information originally provided is insufficient or erroneous to meet the request, or the documents indicated above are not accompanied. For this purpose, Escartín Abogados may require the Holder, for one time and within 5 (five) business days following the receipt of the request, provide the necessary elements or documents to process it, counting, by party, the Holder with 10 (ten) business days to meet the requirement, counted from the day after it was received. If the Holder does not respond within that period, the corresponding request will be deemed not submitted. On the contrary, in case the Holder meets the request for information, the period for Escartín Abogados to respond to the request will begin to run the day after the Holder has met the request for additional information.

The answers given by Escartín Abogados to the Holders that have exercised their ARCO Rights, will be made by the same means in which the request was made, dealing only with the Personal Data that have specifically been indicated in the application in question and must be submitted in readable and understandable format.

When the access to the Personal Data is in a physical place designated by Escartín Abogados, the latter will grant the Holder a period of 15 (fifteen) business days so that he can present himself to consult them. After this period, without the Holder having come, it will be necessary to submit a new application.

When Escartín Abogados denies the exercise of any of the ARCO Rights, it must justify its response, informing the Holder of the right that assists him to request the start of the procedure before the National Institute of Transparency, Access to Information and Protection of Personal Data.

1. Revocation of Consent

The consent granted by the Holder to this Privacy Notice may be revoked at any time, without being attributed retroactive effects. The revocation of the consent that the Holder intended to perform must do so in accordance with the means and procedure set forth in section VII above.

1. Options and Means to Limit the Use or Disclosure of Personal Data

In order to limit the use or disclosure of Personal Data, Escartín Abogados safeguards said Personal Data under computer equipment and programs with limited access only to people who, because of their functions, are granted powers to do so.

With regard to physical documents that contain Personal Data, Escartín Abogados keeps them in locked files, to which only the personnel who have the power to do so are granted access.

Both in the case of Personal Data contained in electronic media and in physical documents, Escartín Abogados uses the same security measures as those applied in its own information.

In turn, Escartín Abogados has implemented internal policies and processes applicable to its personnel, through which Personal Data is used by a minimum of people, limiting the use of the means of reproduction, and generating the obligation to destroy all those copies or reproductions of documents containing Personal Data that are not strictly essential for the proper performance of the functions of Escartín Abogados staff.

Finally, Escartín Abogados, by this section, informs the Holders that are holders of the Personal Data, which may, where appropriate, limit the use and disclosure of their Personal Data, other than the exercise of the ARCO Rights or the revocation of the consent, through the registration you decide to make in the Public Registry to Avoid Advertising (REPEP) in accordance with the Federal Consumer Protection Law.

1. Changes to the Privacy Notice

Escartín Abogados has the right to make changes or updates to this Privacy Notice at any time, due to legislative reforms, internal policies or new requirements for the provision or offer of its services. These modifications will be made and will be available to the Holders through generalized and visible publications addressed to the Holders in the Address and may be available in the following media: the Escartín Abogados website: www.escartin.mx and / or notifications via email to the addresses that in each case are shared with Escartín Abogados.

For more information visit http://inicio.inai.org.mx/SitePages/ifai.aspx

By accepting this Privacy Notice, the Holder expressly grants his consent for the processing of his Personal Data, Personal Data of a patrimonial and / or financial nature, Sensitive Personal Data, in accordance with the content of section IV of this Privacy Notice and transfers referred therein, except as previously provided.

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Efraín Toledo Santiago