IDENTITY AND ADDRESS OF THE PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

CONSULTORIA LEGAL INVERSION BIENES RAICES MEXICO, S.C. (hereinafter LAFFIRMA) with registered office at AV. ANTEA 1130 PISO 11 OFICINA A-1107 COL. JURICA, C.P. 76100, QUERETARO, QRO., acts in the capacity of responsible for the use and protection of your personal data, in accordance with the terms of this Privacy Notice and in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP, by its acronym in Spanish) and its Regulations, as per which we hereby inform you of the following.

I. PURPOSES OF PROCESSING YOUR PERSONAL DATA.

LAFFIRMA collects personal data directly, by electronic means either by e-mail or telephone and personally from the owner.

The personal data, which LAFFIRMA collects directly from you, is necessary to provide professional legal, administrative, accounting, tax, financial, commercial, and title consulting services in real estate matters, as well as to carry out all necessary actions with entities that are compatible, convenient, and/or indispensable to fulfill the service you have requested. In addition, your complaints will be addressed, if applicable.

The personal information that LAFFIRMA collects from you is used solely for the purposes specified above and is not used for commercial prospecting or marketing purposes.

II. PERSONAL DATA SUBJECT TO PROCESSING.

In order to carry out the purposes described in this Privacy Notice, LAFFIRMA may collect and, where appropriate, process the following personal data: name; marital status; Federal Taxpayers’ Registry (RFC, by its acronym in Spanish); Unique Population Registry Code (CURP, by its acronym in Spanish); place of birth; nationality; date of birth; sex; number of children; highest level of education; profession; home and work address; home telephone number; cell phone number; email address; signature; age; position or job title held or to be held at the company where you work or intend to work, work address, work email address; work telephone number; work history; educational background; professional title; professional license; school or educational certificates; information regarding ownership of movable property; information regarding ownership of real estate; credit history; income; expenses; contact information; employment information; academic information; financial or asset information.

III. SENSITIVE PERSONAL DATA TO BE USED.

In addition to the personal data mentioned above, for the purposes stated in this Privacy Notice, the following personal data considered sensitive and requiring special protection will be used: current, past, or future physical health status and fingerprint.

The personal data will be treated as sensitive data in accordance with the guidelines established by the LFDPPP and its Regulations.

IV. PURPOSES FOR WHICH YOUR PERSONAL INFORMATION MAY BE USED.

We notify you that because of the professional services relationship between you and LAFFIRMA, as well as the actions you have requested LAFFIRMA to take, the latter may use your personal data for the following purposes:

A) Purposes that led to or are necessary for the business relationship:

(i) For the proper provision of the advisory and consulting services requested.

(ii) For the creation of a personal file.

B) Purposes that could not cause the business relationship:

(iv) To conduct studies, records, statistics, and analysis of information regarding the services offered by LAFFIRMA.

(v) For the conservation of records for monitoring services, provision of services in the future, and in general to follow up on any contractual relationship that may have been established between the Data Owner and LAFFIRMA.

(vi) To perform various statistical and market analyses.

(vii) For promotion and marketing of LAFFIRMA’s services.

The purposes mentioned in section B) are not necessary to maintain our business relationship with you but are important for keeping you up to date on our activities and services, and for monitoring and improving the quality thereof. Therefore, you have the right to object to or revoke your consent for LAFFIRMA to continue using your personal data for these purposes, following the procedure set out in this Privacy Notice.

  

You will have a period of 5 days from the next day following the day on which you became aware of the Privacy Notice to express your refusal to allow your personal data to be processed for purposes that are not necessary or in no way caused the business relationship.

For the purposes of the foregoing, before sharing your personal data, LAFFIRMA will inform the corresponding recipients of the content and scope of this Privacy Notice, so that the personal data shared will be protected at all times in accordance with the provisions of this Privacy Notice; the foregoing provided that the legislation applicable to the corresponding government agencies or authorities so permits.

LAFFIRMA may provide your personal data to any civil, criminal, or administrative authority, in accordance with the requirements made by the relevant authority for that purpose.

If you do not want your personal data to be transferred to the individuals, agencies, or government institutions, you have the right to express this by requesting the document entitled “Request to Exercise ARCO Rights.” The above information must be sent to LAFFIRMA’s address or by email to the account datospersonales@laffirma.com which must be completed and signed by you, and delivered to LAFFIRMA’s address to the person designated by LAFFIRMA for Personal Data Protection, or sent to the aforementioned email address, together with the information and documentation established in the said request, in order to verify your identity and resolve your request.

In addition to the above, you may express your refusal to allow your personal data to be processed for purposes that are not necessary or that did not cause the legal relationship with LAFFIRMA, which may be requested through the “Request for Exercise of ARCO Rights” in the terms specified in the paragraph immediately above.

The disclosure and transmission of your personal data, which is configured, is subject to your express written consent provided through this Privacy Notice.

With respect to transfers of personal data that require your consent, you may give or withhold your consent.

In cases where your personal data is obtained indirectly and there is a change in the purposes for which you consented to the transfer of data, we will provide you with the corresponding Privacy Notice prior to using your personal data. Likewise, when this Privacy Notice is not made known to you directly, by electronic means, either by email or by telephone or in person, you will have a period of five days to, if applicable, express your refusal to the processing of your personal data for purposes other than those necessary and giving rise to the business relationship between you and LAFFIRMA. If you do not express your refusal to the processing of your data in accordance with the above, it will be understood that you have given your consent to the processing thereof.

V. WAYS TO ACCESS, RECTIFY OR CANCEL YOUR PERSONAL DATA, OR OPPOSE ITS USE.

You have the right to know your personal data provided to LAFFIRMA, what it is used for, and the conditions of its use (Access).

Likewise, you have the right to request the correction of your personal data if it is outdated, inaccurate or incomplete (Rectification), to have your records or databases deleted when you consider that they are not being used appropriately (Cancellation), and to oppose the use of your personal data for specific purposes (Opposition).

These rights are known as ARCO rights.

To exercise any of your ARCO rights, you must submit the corresponding request to LAFFIRMA. To access the “Request to Exercise ARCO Rights” form and learn about the procedure and requirements for exercising your ARCO rights, you can send an email to the following address datospersonales@laffirma.com or call the telephone number 56-4050-6090, so that your request to exercise your ARCO rights can be processed and any questions you may have regarding the processing of your personal data can be answered and resolved.

VI. WAY TO REVOKE YOUR CONSENT TO THE USE OF YOUR PERSONAL DATA.

You may revoke the consent, if any, that you have given us for the processing of your personal data. However, it is important to note that in all cases we will not be able to fulfill your request or terminate the use immediately, as we may be required by law to continue processing your personal data. Likewise, you should consider that for certain purposes, revoking your consent will mean that we will no longer be able to provide you with the service you requested, or that your relationship with us will be terminated.

To revoke your consent, you must submit your “Request to revoke consent to the processing of Personal Data”. To access the corresponding request and to know the requirements for the revocation of consent, you may call the following telephone number 56-4050-6090

VII. WAY TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL INFORMATION.

In order for you to limit the use and disclosure of your personal information, you must contact LAFFIRMA  at 56 4050 6090 or send an e-mail to datospersonales@laffirma.com, in order for your data to be excluded for the aforementioned purposes, after verification of your identity, providing us with the documentation that proves it.

VII. HOW TO LEARN ABOUT CHANGES TO THIS PRIVACY NOTICE.

This Privacy Notice may be modified, changed, or updated due to new legal requirements, our own needs for the professional services we provide, our privacy practices, or other causes beyond the control of LAFFIRMA.

We undertake to keep you informed of any changes to this Privacy Notice by sending an email to the address you provided, through our Personal Data Protection Officer or through our WEB www.laffirma.com

IX. RIGHT TO CONTACT THE ANTI-CORRUPTION AND GOOD GOVERNANCE SECRETARIAT.

We would like to inform you that you are free to contact the Anti-Corruption and Good Governance Secretariat at any time if you deem it to be in the best interests.

X. YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA.

You may grant or deny your consent for your personal data to be processed in accordance with the terms and conditions set forth in this privacy notice.