PRIVACY NOTICE

1.- IDENTITY AND ADDRESS OF THE DATA CONTROLLER OF YOUR PERSONAL DATA

Grupo GAROCE S.A. de C.V. (hereinafter GAROCE) indicates as domicile the one located at Calle de Nigromante number 208, first floor, Colonia La Merced, Toluca, State of Mexico, C.P. 50080, and declares that it is responsible for the use, protection and strictly private and confidential treatment of its personal and sensitive personal data, based on the principles of lawfulness, consent, quality, information, proportionality, responsibility, loyalty and purpose, in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Individuals, its Regulations and applicable secondary provisions.

2.- PERSONAL DATA OR PERSONAL INFORMATION THAT WILL BE PROCESSED

Below, we expressly and restrictively indicate the personal data that we may collect from you, in your capacity as a consumer or potential consumer:

  1. Personal identification and contact details. – Name(s), paternal and maternal surname, gender, age, date of birth, address, postal code, nationality, private telephone number (fixed and mobile) and email;
  2. Work data. – Position, work address, institutional email, work telephone and fax, corporate contract, name of employer, employer registration, insurance;
  3. Academic education data. – Educational background, degree, professional license number (if applicable), specialty, types of practice, certificates of study and;
  4. Bank and billing details .. – Bank account number (s), interbank CLABE, credit history, bonds, Federal Taxpayer Registry (RFC) and tax information for the generation of invoices.  

3.- REQUEST FOR EXPRESS CONSENT OF THE HOLDER FOR the PROCESSING OF PERSONAL DATA (where appropriate)

GAROCE must obtain your express consent in advance (expressed verbally) and in writing for the processing of any of the following data:

  1. Financial or patrimonial data.
  2. Sensitive personal data that may reveal aspects such as: a) Racial or ethnic origin; b) Present and future health status; c) Genetic information; d) Religious, philosophical and moral beliefs; f) Trade union membership and; g) Political opinions.

In relation to this point, please indicate the type of data or data that require your consent, and indicate below if you grant your respective processing authorization:

Type of personal data(s)Consent
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4.- PURPOSES OF THE PROCESSING AND/OR USE OF PERSONAL DATA

Necessary purposes.

Regarding the data indicated in points 2 and 3 of this Agreement, GAROCE will collect, use and process your personal data to fulfill the purposes that gave rise to and are necessary for the existence, maintenance and fulfillment of the legal relationship with its consumers, being the following:

  1. Compliance and execution of the legal relationship arising from the professional services contract signed;
  2. Creation and administration of account in our system and/or personal file, as a consumer of services;
  3. Attention to complaints and recommendations of the services provided;
  4. Customer service and sales tracking services to improve satisfaction;
  5. Registration in competitions, congresses, workshops, symposia and events in general, organized by GAROCE and;

Different or secondary purposes.

GAROCE may process your personal data for the following different or secondary purposes, which are not necessary for the existence, maintenance and fulfillment of the legal relationship with its consumers, but will allow us to provide you with better care and service, being the following:

  1. Marketing, advertising, commercial prospecting, as well as the evaluation of products and services related to the company;
  2. Development of new products or services, conducting market research and evaluating the company's performance in the market;
  3. Participation in benefits programs, loyalty programs, awarding of prizes, communications and promotional purposes;
  4. Global bonding process and;
  5. Preparation of surveys, as well as statistical and scientific purposes.

5.- MECHANISMS TO EXPRESS THE REFUSAL TO PROCESS PERSONAL DATA FOR PURPOSES NOT NECESSARY OR SUBSTANTIAL IN THE LEGAL RELATIONSHIP

In case you do not want your personal data to be processed for the different or secondary purposes specified in this Agreement, we kindly ask you to send us an email to the address contacto@garoce.com, in order for our "Personal Data Protection Officer" to document this situation by registering in our exclusion list called "Contacts who do not wish to send advertising".

In the event that this Privacy Notice is not made known to the owner directly or personally, he/she will have a period of five working days to, if applicable, express his/her refusal to process his/her personal data with respect to the purposes that are not necessary, nor did they give rise to the legal relationship with the controller.

It is important to mention that the refusal granted for the processing of your personal data for the different or secondary purposes indicated above, may not be a reason for us to deny you the acquisition or contracting of the products or services offered by GAROCE.

6. SECURITY MEASURES

The personal data that you provide to GAROCE will be processed exclusively for the purposes indicated in point 4 of this Notice, and will be treated confidentially and exclusively to the extent that they are strictly necessary to fulfill the purpose for which they were collected.

In this regard, to prevent unauthorised access to or processing of your personal data, we have implemented technical, physical, electronic and administrative security procedures, as well as the use and implementation of advanced technologies, which restrict their use or disclosure and prevent their damage, loss, alteration, destruction or removal from the offices.

7. TRANSFERS OF PERSONAL DATA, THIRD PARTY RECIPIENT and PURPOSES (where applicable)

In accordance with the provisions of article 37 of the Federal Law on the Protection of Personal Data Held by Individuals, GAROCE has the possibility of transferring those identification and contact data (non-sensitive) in favor of national or foreign third parties with whom they have a legal or commercial relationship (such as their subsidiaries, affiliates, related companies or service providers, etc.), without the need to request consentby the holder.This situation will be specifically applicable to the following cases:

  1. When the transfer is provided for in a Law or Treaty to which Mexico is a party;
  2. When the transfer is necessary for prevention or medical diagnosis, the provision of health care, medical treatment or the management of health services.
  3. When the transfer is performed to holding companies, subsidiaries or affiliates under common control of the holder of the information, or to a parent company or any company in the same group responsible for operating under the same processes and internal policies;
  4. When the transfer is necessary by virtue of a contract concluded or to be concluded in the interest of the provider of the Personal Data, by the controller and a third party;
  5. When the transfer is necessary or legally required to protect the public interest, or to the enforcement or administration of justice;
  6. When the transfer is necessary for the establishment, exercise or protection of a right in judicial proceedings, and
  7. When the transfer is necessary for the maintenance or enforcement of a legal relationship between the provider of the Personal Data and the person responsible of the Data.

In the event that none of the legal exceptions provided for is updated, it will be necessary for GAROCE to specify the recipient of the personal data and the purpose it pursues, and for the holder to indicate whether he gives his consent to carry out the corresponding processing, through the following boxes:

Addressee:Purpose TRANSFER-IN CONSENT
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8. MECHANISMS AND PROCEDURES FOR THE REVOCATION OF CONSENT TO THE PROCESSING OF PERSONAL DATA AND THE EXERCISE OF ARCO RIGHTS

At any time you may revoke the consent you have given us for the processing of your personal data, so that we stop using them. However, it is important that you bear in mind that not in all cases we will be able to respond to your request or terminate its use immediately, as it is possible that due to some legal obligation we may be required to continue processing your personal data. Additionally, you must bear in mind that, for certain purposes, revoking your consent would mean that we cannot continue providing the service you requested or we may have to end your relationship with us.

Likewise, you have the right to access, rectify, cancel or oppose the processing of your personal data (ARCO rights), which implies: 1. Know what personal data we have about you, what we use it for and the conditions of use we give it (Access); 2. Request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); 3. Instruct us to delete it from records or databases when it considers that it is not being adequately updated, is excessive or unnecessary for the purposes described that justified its obtaining, or that it is not being used in accordance with the principles, duties and obligations provided for in the applicable regulations (Cancellation) and; oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

To carry out any of the aforementioned procedures, you must go to our offices and request the "Request form for revocation of consent" or "ARCO rights request form" (as applicable), which are also available on our website garoce.com, and attach to said request the documents proving their identity (official identification) or, where appropriate, that of the person legally representing them. Likewise, you can request the forms from our "Personal Data Protection Officer", through the email protection.datos@garoce.com or (52) 722 2386262.

GAROCE will comply with your request within the times stipulated in the applicable laws and will inform you of the consequences that must occur due to the exercise of your right.

If you consider that you have not received a response from GAROCE or that the response given to you is not satisfactory, you have the right to go to the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI) to submit a data protection request within fifteen days following the date on which the deadline for GAROCE to respond to your request expires, in accordance with the Federal Law on Personal Data Protectionin the Possession of Individuals and its Regulations, as well as the procedure we have established for this, or the response we would have given to it.

Means to limit the use or disclosure of the Personal Data

GAROCE informs you that, in order for you to limit the use or disclosure of your personal data, we make available the email address contacto@garoce.com in order to be registered in our exclusion list called "Contacts who do not wish to send advertising", so that their personal data are not processed for marketing, advertising or commercial prospecting purposes, as well as for the evaluation of our related products and services.

Use of cookies, web beacons or other technologies

We inform you that on our website we use cookies, web beacons or other communication technologies, through which it is possible to collect personal data automatically and simultaneously to monitor your behavior as an Internet user and to be able to provide you with a better service and experience when browsing the web portal. The personal data we obtain from these tracking technologies are as follows: 1. Information such as source IP address; 2. Browser used and computer operating system; 3. When the page was accessed; 4. In the case of email, the association of the above data with the recipient; 5. User-preferred language; 6. Region in which the user is located and; 7. Phone

The personal information that we collect through these technologies, we use for the following purposes:

  1. Contact him via email
  2. Know if you received and opened the email sent
  3. Know if you accessed the link or URL contained in the email
  4. Statistical purposes and review of results, without the possibility of transferring the results to third parties.

Changes to the Privacy Notice.

This privacy disclaimer may be modified, changed or updated derived from new legal requirements; because of our own needs or because of the change in products or services that we offer; our privacy practices, our changes in business model, or because of other causes. By virtue of this, GAROCE undertakes to keep you informed and notify you of any changes or updates to the Privacy Notice through our web portal garoce.com

12. CASES WHERE A NEW PRIVACY NOTICE IS REQUIRED

GAROCE will be obliged to make available to the holders a new privacy notice, in accordance with the provisions of the Law, its Regulations and these Guidelines, when:

  1. Change your identity;
  2. Requires to collect sensitive personal, patrimonial or financial data in addition to those reported in the original privacy notice, when they are not obtained personally or directly from the owner and consent is required;
  3. Changes the purposes that gave rise to or are necessary for the legal relationship between the controller and the holder; or, new ones are incorporated that require the consent of the holder, or
  4. Modify the conditions of the transfers or transfers will be made not initially foreseen, and the consent of the holder is necessary.

I consent to my personal data being processed in accordance with the terms and conditions reported in this Privacy Notice.

Name and signature

Date of Signature: 08 of 09 of 2023

Date Issued: 08/09/2023

Last Updated Date: 08/09/2023

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