This document constitutes the Complete Privacy Notice «APC» of BEPENSA, S.A. de C.V., as well as its subsidiaries, affiliates, controller and other related companies, (hereby called «Responsible»), with address to hear and receive notifications and applications at Calle 60 Diagonal No. 493 between Calles 59 and 61 in Colonia Parque Industrial Yucatán, Mérida, Yucatán, which is also at the disposition of You (hereby called «Holder») upon the obtaining and treatment of your personal data; and also places at your disposition the following email: datospersonales@bepensa.com

The terms that don’t have a specific definition in this «APC» will have the following meanings that for this purpose are established in the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (“Ley”) y su Reglamento (federal law of protection of personal data in possession of private parties («Ley») and its regulations).

1. Purpose. This “Aviso de Privacidad” (privacy notice) regulates the form, terms, and conditions to which the «Responsible», including its subsidiary and related companies, are empowered and authorized by the «Holder» to obtain, manage and transfer personal data (hereby called «Data») of the «Holder.»
2. Exclusions: The website of the «Responsible» can include links to personal third party websites (hereby called «Third party»), which have no relation whatsoever with the «Responsible». In case the «Holder» obtains access to those links, they will abandon the website of the «Responsible,» for which the «Responsible» assumes no responsibility in relation to these third party websites. If they publish, comment, or share information or personal data, including photographs, in any public forum, social network, blog, or other similar forum, they must have in mind that any personal information that they publish could be read, seen, collected, or used by other users of that forum, and could be used to get in contact with you, send you unsolicited messages, or with purposes that neither the «Holder» or the «Responsible» can control. The «Responsible» will not be in respect to personal information and/or data that the «Holder» decides to send to these forums or social networks.

III. Consent. The «Holder» in this act swears under oath to say it is true that to enter the application and click on «accept terms and conditions»and the corresponding Privacy Notice (called «APS») was sent  to the present «APC,» which constitutes an express manifestation of their consent for the «Responsible» to carry out the treatment of their «Data,» according to this «APC.» The «Holder» at all times has the right to access, rectify, and cancel their «Data,» as well as to oppose the treatment of same or revoke the consent that for this purpose they have provided us, through the procedures established in this «APC.»

IV Obtaining information: The «Responsible» can obtain «Data» from the «Holder» through their direct entry to the Internet site of the «Responsible» or through the sending of electronic files or any other nature, including, but not limited to, direct delivery of information, access to the website of the «Responsible Party» or that of its clients or affiliates (where this «APC» is referred), 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 for our systems to collect «Data» from the «Holder» such as browser type, operating system, visited Internet pages, IP address , etc., through «cookies» or «web beacons», among others. Cookies are text files that are downloaded automatically and stored on the hard disk of the user’s computer when browsing a specific Internet page, which allows the Internet server to remember some «Data» about this user, including their preferences for the display of 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» from the «Holder» by other means, such as information obtained from other commercially available sources, such as telephone directories, labor directories, business cards, databases, public data, etc., in which case, and if you do not agree with the above, you will have the possibility to communicate with the «Responsible» to express your opposition and disagreement with the processing of your «Data». All information and «Data» we collect about the «Holder» can be combined for the purposes permitted under this «APC.»

V.- Use of the 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:

Full name.

Home address.

Email.

Phone, cell phone and / or fax.

Photograph.

Photocopy of official identification.

Bank account number and account information (if applicable).

Income (if applicable).

Expenses (if applicable).

Codes or registration numbers and affiliation with authorities.

Images and sounds of video surveillance cameras.

Information on academic degrees, regarding academic and work history (previous jobs) and data related to interest in jobs, including skills and abilities, contact data, socioeconomic status and job claims (including salary).

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

• Migratory data
• State of present and future physical and psychological health
• Genetic information

The purposes for which your information will be used include:

Improvement of the commercial process and marketing, which includes (i) procuring an efficient service and providing a better service to the user, as well as to improve his experience in the use of certain products and / or services; (ii) sending and presenting goods and / or services that may be relevant or attractive, including their participation in promotions, offers and advertising campaigns; (iii) reporting changes or new products or services that are related to the one contracted or acquired by the client; (iv) complying with obligations contracted with our clients; (v) evaluating the quality of the service, or carrying out internal studies on consumption habits. Follow-up of a credit request, which includes (i) the verification of certain information pertaining to the analysis and viability of granting the credit in favor of the «Holder;» (ii) verification of credit history; (iii) verification of certain personal references or with various credit institutions. Offering and granting of financial products or services, as well as related services, which includes (i) offerings and granting of the products or services that the «Responsible» has, obligations derived from them, attention to legal requirements of competent authorities, notifications about changes of conditions and maintenance of the commercial relationship, the accomplishment of any complementary or auxiliary activity necessary for the accomplishment of the previous purposes. Likewise, as ancillary, personal data may be used to prepare 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». Promotion of labor supply; employment hiring processes or independent service provision; (iii) for the purpose of providing references in case another person or company requests reports on possible candidates for a position, work or commission; (iv) for the purpose of publishing them if required as part of a human resources supply strategy. (v) Due to certain tasks that require physical effort on the part of the worker, current and future health status is requested, as well as genetic information, in order to avoid possible work accidents or damage to the health of the «holders.» In order to determine the type of work in which each worker will perform, psychological health conditions are collected through psychometric studies.

VII.- Storage, disclosure and transfer of Data. The «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 the applicable information 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 «Third Parties» to whom the «Data» is provided, in which the restrictions and other terms and conditions of this «APC» will be incorporated.

If you do not express your opposition or refusal to transfer your «Data», it will be understood that you have given your consent to do so. Regardless of the above, the «Responsible» may also provide part of the «Data» to suppliers of goods or services that require this information. These providers include, but are not limited to, credit card processors, customer support service providers and real-time provided support, marketing, e-mail service providers, automated data processors, and transporters. These service providers are obliged, by contract, to maintain the confidentiality of the «Data» in accordance with this «APC».

VIII.- Storage of the data. Once the «Data» has been 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. «Responsible» has a contract for these purposes. The «Responsible» will incorporate protection mechanisms in order to avoid (to the extent possible) deviations, adulteration, loss, consultation or unauthorized treatment of the «Data», and in case of detecting any situation referred to in this paragraph, it will be informed to 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 such disclosure is required by law or authority order, or by the «Holder».

X.- Access, rectification. The «Holder» will have the right to request from the «Responsible» at any time access, rectification, cancellation or opposition regarding their «Data», for which you must send a request by mail or email according to the «Data» that appears below: Departamento Especializado de Datos Personales, located at Calle 60 Diagonal #493 between Calle 59 and Calle 61, Colonia Parque Industrial Yucatán, in Mérida, Yucatán, or at 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 it 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, these must be made in accordance with the provisions of the previous section. The cancellation of «Data» will result in 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 this treatment. When the «Data» had been transmitted prior to the date of rectification or cancellation and continues to be treated by third parties, the «Responsible» must inform you of such requests for rectification or cancellation, without any additional obligation on your part. The «Responsible» will not be obliged to cancel the «Data» when: it must be treated by legal provision; obstructs judicial or administrative actions linked to fiscal obligations, the investigation and prosecution of crimes or the updating of administrative sanctions; are necessary to protect the legally protected interests of the «Holder;» are necessary to perform an action in the public interest; 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 them to new legislation, jurisprudence, and market practices. The «Holder» agrees that any changes to this «APC» or privacy policies are notified by posting them on the www.bepensa.com web 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.