Privacy notice

This Privacy Notice is issued in compliance with the provisions of the Federal Law for the Protection of Personal Data in Possession of Individuals (the "Personal Data Law") and its regulations (the "Regulations").

All capitalized terms not defined in this Privacy Notice shall have the meaning attributed to them in the Personal Data Law and its Regulations.

1. Identity and address of the Processor. The Responsible for the Processing of Personal Data is SAI Derecho & Economía, S.C. ("SAI"), with address at Monte Cáucaso 915 Interior 305, Lomas de Chapultepec, Miguel Hidalgo, Zip Code 11000, Mexico City, Mexicoo.
2. Purposes of Personal Data Processing. The purposes for the Processing of Personal Data carried out by SAI are as follows:
   1. Regarding its employees and service providers, in order to comply with the obligations arising from the legal relationship established with such employees or service providers and to be able to keep adequate internal control and make payments, withholdings and tax payments, as well as to determine the persons to be contacted in case of any emergency with respect to each employee or service provider. The Personal Data that SAI collects from its employees and service providers are name, nationality, date of birth, age, sex, marital status, address, Federal Taxpayers Registry number (RFC), Unique Population Registry Code (CURP), affiliation number to the Mexican Institute of Social Security and bank account information to make payments to be paid by SAI.
   2. Regarding its clients or employees or officers of its clients, for the provision of legal, economic or any other area related to the consulting services it provides and to collect fees generated by the provision of SAI's services. The Personal Data that SAI collects from its clients or employees or officers of its clients are name, address, email, Federal Taxpayers Registry number (RFC) and bank account information
   3. Regarding its potential clients or employees or officers of its potential clients, to evaluate the possibility of providing consulting services and to provide quotations for the provision of such services. The Personal Data that SAI collects from its potential clients or employees or officers of its potential clients are name, address and e-mail address.
   4. Regarding its suppliers, to make requests for products and services, as well as to make payments for the products and services they provide or for the services they provide. The Personal Data that SAI collects from its suppliers are name, address, e- mail address, Federal Taxpayers Registry number (RFC) and bank account information to make payments to SAI.
   5. Regarding its customers and potential customers, in order to inform them of events or news related to SAI or recent and relevant developments in legal and / or economic matters. For this purpose, the Personal Data that SAI collects are name, address and email.

   For the purposes of the provisions of Article 41 of the Regulations, it is hereby stated that the purposes indicated in subparagraphs A, B, and D above are necessary in terms of the legal relationship between the Processor and the Data Holder. The purposes indicated in subparagraphs C and E did not give rise to and are not necessary for the legal relationship between the Processor and the Data Holder.

   In the event that, at the time of collecting Personal Data, there is a purpose for the Processing thereof other than those indicated in this Section II, SAI will inform the Data Holder, so that, if necessary, they may express their Consent to the corresponding purpose.

   Likewise, in those cases in which SAI collects Sensitive Personal Data, it will communicate it to the corresponding Data Holder in order to obtain their express consent and clearly notify them of the purpose of the Processing thereof.

   Pursuant to Section IV of Article 10 of the Personal Data Law, the Data Holder is informed that their consent was not expressly requested to obtain the data from their bank account in the cases indicated in subparagraphs A, B, and D above, since such Personal Data is intended to comply with obligations arising from a legal relationship between the Data Holder and the Processor.

3. Options and means that the Processor offers to the Data Holder to limit the use or disclosure of Personal Data. With respect to the limitation of the disclosure of Personal Data, all persons in charge of the Processing of Personal Data at SAI have signed an agreement by which they are obliged to keep confidential all information of SAI or in possession of SAI to which they may have access for any reason. Databases containing Personal Data are safeguarded within SAI. The Databases stored in electronic support and that allow remote access, can only be consulted by SAI's personnel or service providers, through the use of user keys and passwords that must be modified periodically.

   With respect to the limitation of the use of Personal Data, the Data Holder may stop receiving news or information related to SAI by means of a request submitted to SAI, following the procedure set forth in Section IV below.

4. Means to exercise ARCO rights. To exercise the rights of access, rectification, cancellation or opposition ("ARCO Rights"), in accordance with the provisions of the Personal Data Law, the Data Holder may submit the corresponding request at SAI's address indicated in Section I above, by writing to Bruno Puerto Salazar. The request for access, rectification, cancellation or opposition ("ARCO Request") must contain and be accompanied by the following:
   1. The Holder's name and address or other means of communicating the response to your Arco Request.
   2. The documents proving the identity or, as the case may be, the legal representation of the Holder in terms of the Regulation.
   3. The clear and precise description of the Personal Data with respect to which it is sought to exercise any of the Arco Rights.
   4. Any other element or document that facilitates the location of the Personal Data.
   5. In the case of ARCO Requests for rectification of Personal Data, the Data Holder shall indicate, in addition to what is indicated in this section, the modifications to be made and provide the documentation supporting his/her request.

   SAI will communicate to the Holder, at the address indicated by the latter in its ARCO Request, in terms of paragraph A. above, within a maximum period of twenty Days, counted from the date on which the ARCO Request was received, the determination adopted, so that, if it is appropriate, the same becomes effective within the fifteen Days following the date on which the response is communicated.

   The aforementioned terms may be extended only once for an equal period, provided that the circumstances of the case so justify.

5. Transfers of Personal Data. SAI does not carry out Transfers without having previously obtained the Consent of the Data Holder, when such Consent is required accordance with the Personal Data Law. In the event that, at the time of collecting Personal Data, there is a need to carry out a Transfer for which the Personal Data Law requires the Consent of the Data Holder, SAI will inform the Data Holder. In case the Data Holder does not object, it shall be understood that they has given their Consent to carry out the Transfer. SAI will communicate to the Third Parties to whom, if applicable, it transfers Personal Data this Privacy Notice and the purposes to which the Data Holder subjected its treatment. If applicable, the Processing of Personal Data by the Third Party shall be carried out in accordance with what is agreed in this Privacy Notice and the Third Party shall assume the same obligations that correspond to SAI as the Processor.
6. Procedure and means by which the Processor will communicate to the Holders of changes to the Privacy. SAI reserves the right to make changes or updates to this Privacy Notice. Any change to this Privacy Notice will be communicated to the Holders through publication on the website https://www.sai.com.mx/.
7. Mechanism to revoke Consent. If you wish to revoke your Consent with respect to the Processing of your Personal Data by SAI at any time, you must request it by the means and procedures set forth in Section IV above. It should be noted that the revocation of the Consent will not have retroactive effects and that the revocation of the Consent is not applicable when the Processing has the purpose of fulfilling obligations arising from a legal relationship between the Data Holder and the Processor, when such Processing is established by law or when any of the assumptions of exception to the Consent provided in the Personal Data Law is actualized.
8. Mechanisms to express refusal for the Processing of Personal Data for purposes that are not necessary or have not given rise to the legal relationship with the Processor. In the event that the Data Holder does not want their Personal Data to be Processed for the purpose indicated in item E of Section II above, please indicate it as follows:

   In the event that this Privacy Notice is not made known to the Data Holder in a direct or personal manner, the Data Holder has a period of 5 (five) days to express their refusal to the Processing of their Personal Data for the purpose indicated in paragraph E of Section II above, by means of a written notice to the address of the Processor, addressed to Bruno Puerto Salazar. Such notice shall clearly indicate: (i) the identity of the Data Holder; (ii) their refusal to the Processing of Personal Data related to the purpose indicated in paragraph E. of Section II above; and (iii) the address details for notifications of the Data Holder. In any case, the rights of the Data Holder to exercise their rights to revoke the Consent or opposition remain unaffected.

If you are a Holder of Personal Data collected by SAI and wish to obtain more information about this Privacy Notice and about the policies of compliance with the Personal Data Law that SAI has adopted, please send an e-mail to Bruno Puerto Salazar at the e-mail address avisodeprivacidad@sai.com.mx, or a letter to the address of SAI indicated in Section I above, and indicate Bruno Puerto Salazar as the addressee.