Notice of privacy

1. Person responsible for personal data

Iterando S.A.P.I. de C.V. (the “Company”), with its registered address at Xola 611 PH3A, Del Valle Centro, Benito Juárez, 03100, Mexico City, Mexico, is committed to protecting the personal information provided by its users (“Personal Data”) and is responsible for its Processing (as defined below) when collected through the website www.iterando.mx (the “Website”), or through printed and/or telephone means (“Other Means”).

2. Processing of personal data

The Company may request and/or collect Personal Data through the Website and Other Means for commercial use, disclosure, and/or storage by any means (the “Processing”) for the purposes set forth below. The Company and/or any third party that participates in any stage of the Processing of Personal Data shall maintain confidentiality with respect to such data when it is confidential in nature, in accordance with the applicable laws and regulations of the United Mexican States (“Mexico”).

3. Consent

Accessing and/or registering through the Website and/or Other Means constitutes the users’ full and unconditional consent to the Processing of their Personal Data in accordance with this Privacy Notice.

4. Personal data to be collected and purpose

The Personal Data that users provide and/or register when accessing and/or registering on the Website and/or that is provided through Other Means is intended to enable the Company to provide the services that it customarily and professionally provides and may include, without limitation, the following:

• Sending the user information and/or documentation related to the services provided by the Company;
• Entering into agreements with the user for the provision of services by the Company;
• Sending the user advertising, promotions, and/or communications related to the services provided by the Company;
• Marketing;
• Creating, modifying, and storing files and records;
• Personalizing the service.

If the Company does not have the aforementioned information, it would not be able to provide the service requested by the user and/or in which the user is interested in engaging.

5. Means to limit the use or disclosure of personal data

The Company has physical, technical, and administrative security measures in place to protect the Personal Data provided by users. If a user wishes to stop receiving promotional messages by email and/or in printed form and/or by telephone from the Company, the user may request this by contacting [email protected], without prejudice to any electronic mechanisms that may be established for such purpose in the messages received by the user.

6. Site disclaimer

The Website may contain hyperlinks or hypertext “links,” banners, buttons, and/or search tools on the “World Wide Web” that, when used by users, direct them to other portals or Internet sites that may be owned by third parties. Personal Data that users may provide through such portals or Internet sites is not covered by this Privacy Notice, and its Processing is not the responsibility of the Company.

Users may find within the Website pages, promotions, microsites, online stores, surveys, job boards, and other services that may be shared with third parties and that may request their Personal Data (“Third-Party Sites”). Any information relating to Personal Data provided through Third-Party Sites shall be subject to the respective privacy notices contained on each such site, unless otherwise indicated by the Company.

The Company advises its users that certain services available through the Website may include, without limitation, discussion forums, personal web pages, classified advertisements, emails, chat rooms, and other similar services. Therefore, Personal Data disclosed through such means may, in certain cases, be accessible to third parties. The Company shall not be responsible for the use, publication, disclosure, and/or dissemination of Personal Data that is used, published, disclosed, and/or disseminated through the aforementioned means.

Accordingly, users are required to exercise caution and responsibility with respect to any personal information they provide through such means.

7. Transfer of personal data

The Company may disclose, share, and/or transfer, within and outside Mexico, the Personal Data provided by users to third parties, including, without limitation, its affiliates, subsidiaries, and/or related companies, as well as suppliers, sponsors, advertisers, contractors, and/or business partners, for the purpose of improving, modifying, and/or personalizing the service provided to the user. Third parties that receive information relating to users’ Personal Data shall be required to comply with the provisions of this Privacy Notice, as well as the Website’s Terms and Conditions and the applicable laws and regulations in Mexico.

The owner of the Personal Data provided through the Website accepts the transfer of such data under the terms described in this Privacy Notice.

8. Means of exercising data subject rights and revoking consent

Users may request the exercise of their rights to:

• Access their Personal Data;
• Rectify their Personal Data when it is inaccurate or incomplete;
• Cancel their Personal Data;
• Object, on legitimate grounds, to the Processing of their Personal Data; and/or
• Revoke their consent to the Processing of their Personal Data at any time, in order to cease its use.

The exercise of the rights of Access, Rectification, Cancellation, or Objection with respect to Personal Data, as well as the revocation of consent, must be requested from the Company and must contain at least the following:

• The data subject’s name, address, and email address to which the response to the request should be sent;
• Documents evidencing the identity or, where applicable, the legal representation of the data subject;
• A clear and precise description of the Personal Data in respect of which any of the aforementioned rights is sought to be exercised (in the case of rectification, the requested modifications must be specified and supporting documentation must be provided);
• Any other information or document that may facilitate the location of the Personal Data.

For the foregoing purposes, the Company makes the following email address available to users: [email protected].

The Company shall respond to users’ requests within no more than 15 business days from the date on which the corresponding request is received, through the email address provided for such purpose.

The exercise of the aforementioned rights by users shall be subject to the laws and regulations applicable and in force in Mexico.

9. Cookies and web beacons

In order to improve the experience of its users on the Website, the Company may use “cookies.” For purposes of this Privacy Notice, “cookies” shall mean information text files that a website transfers to users’ computer hard drives for the purpose of storing certain records and preferences. The Company may use “cookies” to better understand users’ interaction with the Website and the services provided. The Website may allow advertising or third-party features that send “cookies” to users’ computers or devices. Through the use of “cookies,” users are not personally identified; rather, only their computers and/or devices are identified.

“Web beacons,” on the other hand, are images embedded in a website or email that may be used to monitor a visitor’s behavior, such as storing information regarding the user’s IP address, the duration of the user’s interaction with the Website, and the type of browser used, among other information.

Users may change the settings on their computers and/or browsers to stop accepting “cookies” and/or “web beacons,” or to confirm whether or not they accept them.

10. Sensitive personal data

In accordance with applicable Mexican law, “Sensitive Personal Data” is understood to mean “data that may reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and/or moral beliefs, trade union membership, political opinions, or sexual preference.”

If the Company requires Sensitive Personal Data from users, users must provide their express consent.

11. Changes to the privacy notice

The Company reserves the right to modify the content of this Privacy Notice at any time. Any changes to the Privacy Notice will be communicated to users through the Website. Once the Privacy Notice is published on the Website, it shall automatically become effective.