In compliance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter the “Law”), the firm Consultores Rojas, Terán y Asociados S.C. (hereinafter “CRT”) with address at Avenida Paseo de los Cocoteros number 3, Local 2206, Colonia Náutico Turístico, C.P. 63735 in Puerto Vallarta Jalisco, makes this privacy policy available to the “Holders” and expresses its commitment to be responsible for the treatment and protection of all the personal data that will be voluntarily provided by the holders thereof.

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For this policy, it is understood that the owner has given his consent to the treatment of his data when any of the assumptions that are set forth below are updated since in this act the owner manifests in protest to tell the truth that knows, knows and agrees with the provisions of the following grounds:

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1. It will be understood that the owner has accepted the processing of his data when, being this document in written format, stamp his signature, heading, name and/or fingerprint, or at the time that he provides CRT with his personal information.

2. It will be understood that the owner has accepted the treatment of his data when, being the present instrument in digital format, click on the “next” button and/or continue browsing the CRT website, or, at the time that you provide CRT with your data without obstructing how they are forwarded.

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In the same order of ideas, at the time of providing your data, the owner declares under protest, to tell the truth that the data provided to CRT is real, truthful, and complete.

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It is your full knowledge that CRT will be able to obtain, manage, store and/or transfer your personal data through different physical and/or electronic means exclusively to its members and collaborators, except for all authorities, company, body and diverse institution except in those cases in which there is a judgment and/or judicial resolution; data that will be transferred to the aforementioned persons for the correct development of the services requested from CRT by the holders, this acting at all times with strict adherence to the guidelines contained in the Law and other applicable regulations and to this Privacy Policy.

The activities for which the transfer of personal data will be necessary are, but not limited to, the following:

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Relationship with Suppliers or service providers: To carry out the registration and establishment of the relationship with our distributors, consignees, commercial partners and/or service providers. The type of personal data that can be managed in this service is: identification, labor, patrimonial and financial.

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Attention to requests: Specialized support for clients, suppliers and/or individuals or legal entities in general, with attention to requests for legal and accounting advice, as well as to provide a specialized service in matters of tax, agricultural and corporate law. The type of personal data that can be managed in this service is: of identifications and all kinds of personal, labor, academic documents, company deeds (in case of being a legal entity), powers granted to the CRT company for the improvement of the service provided, among others.

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Exchange of information and/or services: For the exchange of legal and accounting information in general, with the partners, lawyers, accountants, advisers and other collaborators belonging to CRT for the promotion of reforms, for the creation of directories to improve performance labor. The type of personal data that can be managed in this service is: identification, labor and academic (includes agreements, treaties, legal/accounting books and links).

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Legal Requirements: To give timely attention to legal procedures, various writings (contracts, agreements, letters in general), inspections or audits ordered or instructed by Courts or Government Bodies. The personal data that can be managed is: Identifications, labor, academic, patrimonial and financial and sensitive of personal characteristics.

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Access to our Facilities: To provide security within our facilities through strict access control and constant monitoring of our facilities. The personal data to be processed is Identification.

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Recruitment and Selection: For valuation and selection of candidates for jobs within CRT and participation in select groups such as colleges of accountants and lawyers. The type of personal data that can be processed during the Recruitment and Selection process is: Identification, Labor, Patrimonial and Financial, for which, your express authorization will be requested.

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Recruitment: To establish the employment relationship with CRT staff, the type of personal data that can be handled during the Recruitment is: identification, employment, academic, property and financial, in this case, express authorizations will be requested.

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If Consultores Rojas, Terán y Asociados SC makes use of personal data for other purposes not described in previous paragraphs, it will always be done considering that said purposes are analogous and compatible and taking care that personal data is processed only for the time necessary to fulfill the aforementioned purposes and/or under the provisions of the applicable legal provisions.

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The personal data that may be processed within each category are the following:

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Identification: name, address, phone number, birth certificate, email, RFC, CURP, date of birth, age, nationality, marital status, sex, language, photograph, image, official identification such as: driver’s license, passport, military card and voter card.

 

Labor: company name, position, work address, work email, work phone; job references and/or personal references.

Academics: educational background, title, ID, certificates and/or recognitions;

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Equity and Financial: : account number, CLABE, income and expenses, benefits and/or socioeconomic level.

Sensitive of Physical Characteristics: height, weight, complexion and disabilities.

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In some cases, some other personal, sensitive and non-sensitive data may be processed, which are not included in the aforementioned list, but always considering themselves of the same nature and respecting the purposes for which they are obtained.

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For the application of those established in previous lines, it will be essential to have the prior written consent of the client, supplier and/or natural or legal person who owns the data.

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You, as the owner of personal data, may at any time exercise your rights of access, rectification, cancellation or opposition (ARCO rights in Spanish) concerning your data, requesting Consultores Rojas, Terán y Asociados SC, through the customer service telephone number 209-21-99, or with the free written presentation at the CRT offices or via email to pvcrt10@teranrojas.mx, indicating at least the following:

1. Name, address and email address;

2. Documents that prove your identity, or where appropriate, legal representation;

3. A clear and precise description of the personal data regarding which you seek to exercise any of the aforementioned rights;

4. Any other element or document that facilitates the location of the respective personal data.

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Within a maximum period of twenty business days from the date we receive your request, we will attend to your request and we will let you know about the origin of it, through the email address you have provided in your request.

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Likewise, you, as the owner of personal data, may at any time limit the use and disclosure of the information you have provided to Consultores Rojas, Terán y Asociados, S.C. through a request sent to the ARCO rights applications manager following the procedure established above.

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Under the provisions of articles 10, 37 and others related to the Law, Consultores Rojas, Terán y Asociados, S.C. will be exempt from the obligations regarding obtaining the consent of the owner for the treatment and transfer of personal data, in the cases that are related as follows:

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In the case of treatment:

1.- Is provided for in a Law;

2.- The data appears in sources of public access;

3.- The personal data is submitted to a previous decoupling procedure;

4.- Have the purpose of fulfilling obligations derived from a legal relationship between you as the owner of personal data and Consultores Rojas, Terán y Asociados, S.C .;

5.- There is an emergency that could potentially harm an individual in his person or his assets;

6.- The competent authority resolution is issued;

In the case of transfer of personal data:

1.- When the transfer is provided for in a Law or Treaty to which Mexico is a party;

2.- When the transfer is made to cooperating companies with CRT for a better result of the required work;

3.- When the transfer is necessary by a contract concluded or to be celebrated in your interest, by CRT and a third party;

4.- When the transfer is necessary or legally required for the safeguarding of public interest, or the procurement or administration of justice;

5.- When the transfer is necessary for the recognition, exercise or defense of a right in a judicial process and;

6.- When the transfer is necessary for the maintenance or fulfillment of a legal relationship between CRT and you as the owner of personal data.

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IN CHARGE OF ATTENDING ARCO REQUESTS

Our manager in dealing with requests to exercise the rights of access, rectification, cancellation or opposition of personal data (ARCO rights in Spanish) is Mr. Luis Alfonso Licona Ortiz, who may be located at the address of the firm Consultores Rojas, Terán and Asociados, SC, and who can be contacted at the following email address: pvcrt10@teranrojas.mx.

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It should be noted that ARCO rights are contained in article 16 of the Political Constitution of the United Mexican States and refer, precisely, to the right that holders have to safeguard their personal information, as well as to decide on access, rectification, cancellation and opposition of this to third parties who have them in their possession.

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In the same sense, it is made known that your personal data can be transferred and processed inside and outside the country, by national subsidiary companies and/or can be shared with third parties who act as managers on behalf of Consultores Rojas, Terán y Asociados SC; This with the commitment not to transfer your personal data without your prior consent, except for the exceptions contained in number 37 of the Law. Therefore, we extend our commitment to ensure, as far as possible, that your personal data are protected by taking the appropriate security measures in compliance with the Law and with this Privacy Policy.

It is necessary to inform that when electronic means are used to collect information, there are auxiliary applications such as browsers that can store cookies on computers and/or other devices used by the holders of personal data; Cookies are small pieces of information that are sent by the website to your browser and are stored on your computer’s hard drive and are used to provide greater efficiency in the service as well as to track certain behaviors or activities carried out by the holder of personal data within our sites.

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In some sections of our site, we may require that the client have cookies enabled as some of the functionalities require them to function. Cookies allow us to

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a) Recognize you when you enter our sites and offer you a personalized experience,

b) Save the personal data that was issued for the first time to fill out a format;

c) Calculate the size of our audience to our site and measure some traffic parameters to make the service more efficient.

The use of cookies will not be prosecuted to personally identify users, except in cases where possible fraudulent activities are investigated. For the assumption of the information that could be collected by tools such as Cookies, it is important to inform you that such programs are normally used by browsers and not directly by Consultores Rojas, Terán y Asociados S.C.; reason why CRT is not responsible for the use that browsers or any other internet users give to personal data that is collected and/or stored by cookies.

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If you do not want these tools to be stored on your computer, all browsers can disable them or limit their use, however, some applications or page features may not work properly.

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Consultores Rojas, Terán y Asociados S.C. reserves the right to make modifications or updates to this Privacy Policy at any time, to deal with new legislation, internal policies or new requirements for the provision or offering of our products.

These modifications will be available through our Internet page www.teranrojas.com.

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The date of the last update to this privacy policy is: April 2023.

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To whom can you present your complaints and claims for the improper treatment of your personal data?

If after requesting any clarification from us by the means that we provide in this document; considers that your personal data is being treated improperly; You can file the corresponding complaint or denunciation with the Federal Institute of Access to Information (IFAI), for more information visit www.ifai.org.mx

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The information collected by tools such as cookies is used only by Consultores Rojas, Terán y Asociados S.C. to better understand our visitors, to determine their areas of interest and for statistical purposes.