Privacy notice

This document conforms the Complete Privacy Notice "APC" of BEPENSA, S.A. de C.V., as well as its subsidiaries, affiliates, controller and other related companies, (hereinafter the "Responsible"), with address to hear and receive notifications and requests at 60 Diagonal street number 493 between 59 and 61 streets of Colonia Parque Industrial Yucatán, de Mérida, Yucatán, Privacy Notice delivered to you (the "Owner") prior to obtaining and processing your personal data; likewise, available at the following email address: datospersonales@bepensa.com.

The terms that do not have a specific definition in this "APC" will have the meanings established for this purpose in the Federal Law on Protection of Personal Data Held by Private Parties (the "Law") and its Regulations.

I. - Object. This "Privacy Notice" regulates the form, terms and conditions under which the "Responsible", including its subsidiaries and related companies, are empowered and authorized by the "Holder" to obtain, process and transfer personal data ( hereinafter the "Data") of the "Holder".

II. - Exclusions. The website of the "Responsible" may include links to personal third-party websites (hereinafter "Third Parties"), which have no relationship with the "Responsible". In the event that the "Holder" obtains access to said links, he will leave the "Responsible" website, for which the "Responsible" does not assume any responsibility in relation to those "third party" websites. If you post, comment or share personal information or data, including photos, in any public forum, social network, blog or other such forum, you should be aware that any personal information you post may be read, viewed, collected or used by others users of said forums, and could be used to contact you, send you unsolicited messages or for purposes that neither the “Holder” nor the “Responsible” can control. The "Responsible" will not be responsible for the personal information and/or data that the "Holder" decides to send to these forums or social networks.

III. - Consent. The "Holder" in this act declares under protest to tell the truth that when entering the application and "clicking" on "accept the terms and conditions" and the corresponding Simplified Privacy Notice "APS", you sent to this "APC", which constitutes an express manifestation of your consent for the “Responsible” to process your “Data”, in accordance with this “APC”. The "Holder" at all times has the right to access, rectify and cancel her/his "Data", as well as to oppose the treatment of the same or revoke the consent that for this purpose has been granted to us, through the procedures established in this "APC".

IV. - Obtaining data. The "Responsible" may obtain the "Data" from the "Holder" personally, by entering directly into the Internet site of the "Responsible" or by sending electronic files or of any other nature, including but not limited to, direct delivery of information, access to the website of Internet of the "Responsible" or of its clients or affiliates (where this "APC" is referred to), telephone or telemarketing calls, requests by email, seminars, congresses or events, etc. In case of use of, or access to our Internet sites or other electronic means, we inform you that it is possible that our systems collect "Data" from the "Holder" such as browser type, operating system, Internet pages visited, IP address, etc., through “cookies” or “web beacons”, among others. Cookies are text files that are automatically downloaded and stored on the hard drive of the user's computer when browsing a specific Internet page, which allow the Internet server to remember some "Data" about this user, including their preferences for viewing the pages on that server, name and password. On the other hand, web beacons are images inserted in an Internet page or email, which can be used to monitor the behavior of a visitor, such as storing information about the user's IP address, duration of interaction time on said page and the type of browser used, among others. The "Holder" accepts that the "Responsible" may also obtain "Data" of the "Holder" from other means, such as information obtained from other commercially available sources, such as telephone directories, employment directories, business cards, public databases, etc., in which case, and if you do not agree with the foregoing, You will have the opportunity to communicate with the "Responsible" to express your opposition and disagreement with the treatment of your "Data". All information and “Data” that we collect about the “Holder” may be combined for the purposes permitted under this “APC”.

V. - Use of data. The "Holder" understands, accepts and acknowledges that the "Data" that will be collected and the purposes for which they will be used are the following:

In an illustrative but non-limiting manner, the "Data" that could be collected and, where appropriate, processed are the following:

Full name
Home
Email
Telephone, cell phone and/or fax
Photography
Photocopy of official identification
Bank account number and asset information (if applicable)
Financial data
Income (if any)
Expenses (if applicable)
Passwords or registration and affiliation numbers with authorities
Images and sounds from video surveillance cameras
Information on academic degrees, academic and work history (previous jobs) and data related to interest in jobs, including skills and abilities, contact details, socioeconomic status and job expectations (including salary).

VI. - Sensitive data “DPS”. In addition to the personal data mentioned above, for the purposes informed in this privacy notice we will use the following personal data considered sensitive, which require special protection:

Migratory data
Current and future physical and psychological health status
Genetic information
Biometric data: fingerprints, facial recognition

Your personal data may be used to create customer profiles, analysis of your needs, analysis for the design of products, to send you advertising to promote the services that we consider to be of your interest. If you are a natural person supplier, if you are acting on behalf of a legal entity or a natural person with business activities, your data may be used to request or provide recommendations or reference regarding the quality, safety and legality of the products and services you sell.

The processing of your personal data is for the purpose of verifying and confirming your identity, carrying out the necessary activities for the contracting, administration and operation of the services that you have contracted with us, identification of risk in the contracting, start-up, maintenance and end of the legal relationship, as well as to meet the requirements established by the competent authorities. In an illustrative but non-limiting manner, the following assumptions are described:

Offering and granting of financial products or services, as well as related services, which includes (i) Offers and granting of the products or services available to the "Responsible", obligations derived from them, attention to legal requirements of competent authorities, notifications about changes in conditions and maintenance of the commercial relationship, the performance of any complementary or auxiliary activity necessary to carry out the aforementioned purposes.
Follow-up of a credit application, which includes: (i) the verification of certain information tending to the analysis and feasibility of granting the credit in favor of the "Holder" (ii) Verification of her/his credit history, (iii) Verification of certain personal references or with various credit institutions.
Analyze the credit capacity of the holder;
Incorporate them in the legal instruments that are required for the formalization of the financing and/or lease that, if applicable, is granted, as well as the legal instruments;
Use them in any type of judicial and/or extrajudicial collection act or diligence,
Contact the holder to offer financial products and services,
Prepare statistics and reports of the services provided by the person in charge in order to keep an internal control of said services, as well as to give timely follow-up;
To use personal information for funding purposes, before the financial institutions with which a confidentiality agreement has been formalized,
To carry out the insurance process of the leased or financed assets, before the insurance and bonding institutions that are deemed appropriate.
For the installation of satellite location equipment, before providers that grant this service; To promote the use of our services through specific campaigns established with our equipment suppliers.

They will also serve for the Improvement of the commercial process and marketing, which includes:

Seek an efficient service and provide better attention to the user, as well as to improve their experience in the use of certain products and/or services;
Send and present goods and/or services that may be relevant or attractive, including your participation in promotions, offers and advertising campaigns;
Inform about changes or new products or services that are related to the one contracted or acquired by the client;
To comply with obligations contracted with our clients;
Evaluate the quality of the service, or carry out internal studies on consumption habits.

Likewise, in an ancillary way, personal data may be used for the preparation of customer profiles for the development and offering of new products, conducting surveys, creating or implementing necessary or convenient analytical and statistical processes related to the operations and services of the “Responsible". Job offer promotion; Labor contracting processes or the provision of independent services; For the purpose of providing references in the event that another person or company requests information on possible candidates for a position, job or commission; For the purpose of publishing them in case it is required as part of a human resources offer strategy. Due to certain tasks that require physical effort from the worker, the present and future state of health is requested, as well as genetic information, in order to avoid possible accidents at work or damage to the health of the "holders", for the identification of the worker when carrying out certain activities that, due to their nature and for their performance, require certainty of their identity. In order to be able to determine the type of work in which each worker will perform, psychological health states are collected through psychometric studies.

VII. - Data storage, disclosure and transfer. “Data” may be transferred, stored and processed in a country other than where it was provided, in which case we transfer the information in accordance with applicable data protection laws.

The "Holder" understands and accepts that the "Responsible" is authorized to use, store, disclose, transfer, as well as to use or in any other way treat or transfer the "Data". In this case, the "Responsible" will enter into contracts with the "Third Parties" to whom it will provide the "Data", contracts in which the restrictions and other terms and conditions of this "APC" will be part of.

If you do not express your opposition or refusal for your "Data" to be transferred, it will be understood that you have given your consent for it.

In an illustrative but non-limiting manner, the "Responsible" may transfer the data in the following cases:

I. When it is decided to transfer to a third party through any legal form, the collection rights that it has against the owner.

II. When it’s required from a third party a provision of services or advice regarding the credit capacity of the owner, including investigation of the assets and debts of the latter.

III. When it’s required a third party to provide legal advice services.

IV. For securitization and funding purposes with financial institutions.

V. Third parties that offer verification services and documentation verification.

VI. Third Party Providers of Credit and Background Investigation Services. Third parties derived from a corporate restructuring, including the merger, consolidation, sale, liquidation or transfer of assets of the person in charge.

VII. Competent authorities, when required.

VIII. To subsidiaries, affiliates, controller and other related companies.

Regardless of the foregoing, the "Responsible" may also provide part of the "Data" to suppliers of goods or services that need to know this information. Such providers include, but are not limited to, credit card processors, real-time support and customer service providers, marketing, email service providers, automated data processors and carriers. Such service providers are required by contract to maintain the confidentiality of the “Data” under this “APC”.

IX. Data storage. Once the "Data" is received, it will be processed and stored in a database that can be managed by the "Responsible" or by a "Third Party", inside or outside the country where the "Data" was provided with which the "Responsible" has a contract for such purposes. The "Responsible" will incorporate protection mechanisms in order to avoid (as far as possible) deviations, adulteration, loss, consultation or unauthorized treatment of the "Data", and in case of detecting any situation referred to in this paragraph , will do so to the knowledge of the "Holder" of the information that has been violated, so that the latter takes the precautionary measures it deems necessary.

IX. - Confidentiality. The "Responsible" will not disclose the "Data" to unauthorized third parties except when said disclosure is required by law or order of authority, or by the "Holder".

X. - Access, rectification. The "Holder" shall have the right to request the "Responsible" at any time access, rectification, cancellation or opposition regarding their "Data", for which they must send a request by mail or email according to the "Data" that appears below: Specialized Department of Personal Data, located at Calle 60 Diagonal #496 between Calles 59 and 61 Colonia Parque Industrial Yucatán, in Mérida, Yucatán, to the email datospersonales@bepensa.com The request for access, rectification, cancellation or opposition must contain and accompany the following: The name of the "Holder" and address or other means to communicate the response to your request; The documents that prove the identity or, where appropriate, the legal representation of the "Holder" The clear and precise description of the personal data with respect to which one seeks to exercise any of the aforementioned rights, and any other element or document that facilitates the location of the personal data of the “Holder”.

XI.- Cancellation or Revocation. In case of requests for total cancellation of "Data" or revocation of consent, they must be made in accordance with what is indicated in the previous section. The cancellation of "Data" will give rise to a blocking period after which the Data will be deleted. The "Responsible" may keep the "Data" exclusively for the purposes of the responsibilities arising from the treatment. When the "Data" had been transmitted prior to the date of rectification or cancellation and continue to be processed by third parties, the "Responsible" must inform of said request for rectification or cancellation, without any additional obligation on his part. . The "Responsible" will not be obliged to cancel the "Data" when: They must be treated by legal provision; obstruct judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions; They are necessary to protect the legally protected interests of the “Holder” They are necessary to carry out an action based on the public interest; They are necessary to comply with a legally acquired obligation.

XII.- Modifications. The "Responsible" reserves the right to make changes to these privacy policies at any time and adapt it to new legislation, jurisprudence, as well as market practices. The "Holder" agrees and agrees that any changes to this "APC" or to the privacy policies are notified by posting them on the www.bepensa.com page. It is the obligation of the "Holder" to periodically visit said site in order to verify the most current version of the Privacy Notice.

I hereby expressly authorize BEPENSA, S.A. de C.V., as well as its subsidiaries, affiliates, controller and other related companies (hereinafter "BEPENSA") to use, maintain, manage and in general treat the information provided, even before third parties outside "BEPENSA", in case of be required to properly integrate the reference analysis.

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