ABOUT PRIVACY POLICY AND PERSONAL DATA MANAGEMENT

CINDU DE MÉXICO, SA DE CV, known commercially as CINDU, fully complies with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares), its Regulations and other applicable regulations on the matter, seeking to guarantee at all times the legitimate, controlled and informed treatment of personal data, in order to protect its privacy and ensure the corresponding rights regarding the protection of personal data of anyone who visits or is a user of the website https:// mx.cindu.com/mx_en/, which we make available to the general public.

In accordance with the foregoing, CINDU has prepared this Policy that contains a set of internal actions, with which it is intended to adapt and incorporate CINDU into compliance with the current legal regulations on the Protection of Personal Data.

Likewise, this Privacy and Personal Data Management Policy has the fundamental objective of creating a legal and practical standard in the legitimate and responsible treatment of personal data within CINDU.

IMPORTANT ASPECTS TO CONSIDER

• The personal data can only be used from the moment in which the respective CINDU Privacy Notice has been made available to them by the different established means.
• The personal data can only be used for the purposes communicated in the CINDU Privacy Notice.
• In order to process the personal data, it is necessary to obtain the user’s consent unless it is to be used for the purpose of complying with the obligations derived from a legal relationship or other exceptions provided in the legislation applicable to the matter. However, in doubt, it is preferable to obtain it. Now, if the personal data are patrimonial and/or financial, in that case, obtaining the corresponding consent, which may be expressly and in writing or through any technology, will be required at all times.
• The users of the site, have the right, at all times, to access their personal data, to rectify them when they are inaccurate or incomplete, to cancel them when the treatment is illegitimate, or to oppose their use for certain purposes (ARCO Rights). The CINDU Department of Personal Data Protection will be in charge of processing the holders' requests for the exercise of their ARCO Rights.

1. TERMS AND DEFINITIONS

• Privacy Notice: Physical, electronic document or in any other format generated by CINDU and that is made available to the Holder, prior to the processing of their personal data;
• Confidentiality: Ownership of the information so it is not available or disclosed to unauthorized persons, entities, or processes.
• Consent: Manifestation of the Holder will, through which the processing of their information and personal data is carried out.
• Personal Data: Any information concerning an identified or identifiable natural person. Personal data may be expressed in numerical, alphabetical, graphic, photographic, acoustic, or any other type.
• Sensitive Personal Data: These are personal data that affect the most intimate sphere of its owner or whose improper use may give rise to discrimination or entail a severe risk for it. In particular, sensitive data are those that may reveal aspects such as racial or ethnic origin, present, and future health status, genetic information, religious, philosophical, and moral beliefs, union affiliation, political opinions, sexual preference.
• ARCO Rights: These are the rights of Access, Rectification, Cancellation, and Opposition that a Holder can exercise with respect to their personal data. The exercise of any of them does not constitute a prerequisite, nor does it prevent the exercise of another.
• Exclusion List: Reference is made to the database that aims to record the Owner's refusal to process their personal data for free.
• Policy: Reference is made to this CINDU Privacy and Personal Data Protection Policy.
• Responsible: It refers to any private individual or legal entity who decides on the processing of personal data; in this case, it will be CINDU.
• Holder: The natural person to whom the personal data correspond.
• Treatment of Information and/or Personal Data: Obtaining, using, disclosing, or storing personal data, by any means. The use covers any action of access, handling, use, transfer, or disposition of personal data.

2. WHAT INFORMATION AND DATA DO WE COLLECT?

When you access our website, as part of the corresponding process, we collect the personal information that you provide to us as a user, such as personal identification, contact, transaction, property and/or financial data, as well as browsing data and devices, such as IP address, geographic location, browser type, system type, content, and pages visited.

It is important to note that when you browse our website https://mx.cindu.com/mx_en/, we can make use of Cookies, SDK ("Software Development Kit" or "Software Development Kit") and other technologies, through which it is possible to monitor your behavior as a user of our website, as well as offer you new products and services based on your preferences and consumption habits.

3. INFORMATION SECURITY

We take reasonable precautions to protect your personal information and follow industry best practices to ensure it is not improperly lost, misused, accessed, disclosed, altered, or destroyed.

4. ARCO RIGHTS AND REVOCATION OF CONSENT

You or your legal representative may exercise any of the Access, Rectification, Cancellation or Opposition Rights (hereinafter "ARCO Rights"), as well as Revoke your Consent for the processing of your personal data by sending an email to the Protection Department of Personal Data of CINDU to the email address: alagunes@cindu.com.mx.

We remind you that the ARCO Rights and/or Revocation of Consent can only be exercised by the owner or his legal representative after proof of identity, which is why the digitization of an official identification must accompany the letter you send us, as can be one of the following: INE, Passport or Immigration Document that confirms the legal stay of the foreigner in the country. Likewise, we inform you that for your request to proceed, it is essential to complete all the information that we set out below, which will be used to prove your identity:

• DATA OF THE HOLDER: Full Name, Full Address, Telephone, and Email (where the answer to your request will be communicated).
• REPRESENTATIVE INFORMATION (ONLY IF APPLICABLE): Full Name. In the case of being the holder's legal representative, the corresponding public instrument in original must be attached to the document or, where appropriate, a power of attorney signed before two witnesses.
• ARCO RIGHTS: Indicate the right (s) you wish to exercise: Access, Rectification, Cancellation, and/or Opposition. Likewise, a description of the personal data with respect to which it is sought to exercise the right(s) mentioned above and/or any other comment that will help us better attend to your request must be made.
• OTHER NECESSARY DOCUMENTATION: Please attach the documentation you consider to support your request and help us process it properly. In particular, in the request for the Rectification of personal data (incorrect data, correct data, and document that proves your information).

In the event that the information provided in your writing is erroneous or insufficient, or the corresponding accreditation documents are not accompanied, the Department of Protection of Personal Data of CINDU, within five (5) business days following receipt of the application, may require you to provide the elements or documents necessary to process it. You will have ten (10) business days to meet the request, counted from the day after you have received it. If no response is given within said period, the corresponding request will be deemed not submitted.

The Department of data protection of CINDU will communicate the adopted decision in a maximum lapse of twenty (299 business days counted from the date the request was received so, if it proceeds in the criteria of the aforementioned department, it will enter in effect within fifteen (15) business days counted from the reception of the answer. The answer will be sent, via email, to the address specified in the request.

5. MEANS TO LIMIT THE USE OR DISCLOSURE OF YOUR DATA

You may limit the use or disclosure of your personal data by sending your request to the email address: alagunes@cindu.com.mx; If your request is appropriate, you will be registered in CINDU's own exclusion list. 

Likewise, we inform you that there are other mechanisms to limit your data use and disclosure, such as the Public Registry to Avoid Advertising (REPEP) of PROFECO, which you can access from the web pages of the aforementioned institutions.

6. PRIVACY AUTHORITY AND PROTECTION OF PERSONAL DATA

If deemed necessary, we inform you that you have the right to go to the National Institute of Transparency, Access to Information, and Protection of Personal Data (INAI), to assert any disagreement related to your Right to Privacy and Data Protection Personal.

7. CONTACT FOR DOUBTS OR CLARIFICATIONS

Our Department of Protection of Personal Data is at your service to provide you with any additional information you require or, where appropriate, to resolve any questions that may arise regarding privacy and protection of personal data, for which you can contact us by email. Email: alagunes@cindu.com.mx.

8. ADDITIONAL INFORMATION ON THE POLICY

In compliance with the provisions of the Federal Law on Protection of Personal Data Held by Individuals (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) and in reference to our Privacy Policy and Handling of Personal Data, we inform you of the following:

1. We collect non-personal information, such as the type of browser, operating system, and web pages visited, to contribute to our website's administration.   
2. We use Cookies, SDKs, and other Internet Technologies to administer our website and our email programs, but not to collect or store personal information.   
3. The data you enter in any of the forms within the Website or Platform will not be disseminated, distributed, or commercialized.  
4. If you wish to be removed from our database, you may, at any time, request the removal of the information by email to: alagunes@cindu.com.mx.  
5. Your request or comment can be included in the statistical reports prepared at CINDU. Nevertheless, these reports are purely statistical and do not include information that allows you to be identified individually.     
6. Your personal data may be transferred to third parties in accordance with what is strictly stated in article 37 of the Federal Law on Protection of Personal Data Held by Private Parties. 

9. CHANGES TO THE PRIVACY POLICY AND HANDLING OF PERSONAL DATA

This Privacy Policy and Personal Data Management may undergo modifications, changes, or updates derived from new legal requirements; of our own needs for the services we offer; of our privacy practices; of changes in our business model, for which CINDU undertakes to keep you informed about the changes that it may undergo.

You may request this document at any time from the CINDU Personal Data Protection Department at the email account: CINDUoficial@gmail.com, or you may consult its publication on the website: https://mx.cindu .com / mx_en /.

ATTENTIVELY

-CINDU-

CINDU DE MÉXICO, S.A. DE C.V. 

https://mx.cindu.com/mx_en/

Avenida Miguel Alemán Número 1901 – C, Colonia Cándido Aguilar, Código Postal 91789, Municipio de Veracruz, Estado de Veracruz, México

Last Updated:

November 1, 2021

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