CCLA Group Privacy Notice

 

Date of last update: March 2nd, 2021

 

Responsible party´s identity and address: Multifamily Holdings México, S. de R.L. de C.V. (hereinafter “CCLA”, “us” or “we”), with address at Jaime Balmes 8, office 101, Polanco, Polanco I Secc, 11510, Miguel Hidalgo, Mexico City, Mexico, will be responsible for the processing of personal data (including financial data), related to you or that of the individual represented by you, which has been disclosed as of this date or which may hereinafter be disclosed to CCLA, either resulting from, or as a consequence of, your/their legal relationship with us (hereinafter referred to simply as “Personal Data”). Should you require any information regarding this privacy notice or in relation to the exercise of any of your rights derived from the aforementioned Personal Data, including, without limiting your access, rectification, cancellation and objection rights, as well as to limit its treatment or revoke the consent that has been granted to us, please contact us at our email info@ccla.edsoft.com.mx.


What Personal Data do we collect from you? The general Personal Data that CCLA may request from you is that which is necessary to identify you and address your questions, requests, and complaints, as well as that relating to the execution and/or compliance of your relationship with CCLA. Specifically, the Personal Data that we may request from you is the following: (i) full name and copy of your official identification with photograph; (ii) address and proof of address; (iii) date of birth; (iv) marital status; (v) RFC and CURP; (vi) profession; (vii) landline and/or mobile contact telephone number; and (viii) email address.


By signing this privacy notice, you grant your express consent for us to process the above-mentioned Personal Data. In case you do not provide your express consent to the processing of your Personal Data (including financial), we may be unable to establish a legal relationship with you.


How do we obtain your Personal Data? CCLA, may collect your Personal Data either directly when you provide it to us and/or through other means such as email and/or CCLA´s website.


Likewise, we inform you that CCLA´s websites automatically obtain data through cookies. “Cookies” are small pieces of information that your browser stores on your computer´s hard drive to check your activity on our site, browsing preferences, information that can help us determine problems on our website or inform and provide us with statistics on which areas of our site are most interesting to you. You can prevent the use of cookies on your computer through the appropriate settings on your browser, but please note that this may hinder the functionality of CCLA´s websites.


For what purposes do we collect and use your Personal Data? Your Personal Data, including, but not limited to financial and/or patrimonial data, as well as all that which is embodied in the documentation provided by you to us, may be used by CCLA, its personnel or any of its affiliates or subsidiaries for the following purposes that give origin to and are necessary for our legal relationship: (i) to comply with and carry out the purposes and development of the contractual obligations between you and CCLA, its affiliates or subsidiaries; (ii) to contract our products or services; (iii) to create databases for administrative and organizational purposes; (iv) to provide information required by governmental entities or authorities in compliance with laws or regulations applicable to CCLA´s business in Mexico or abroad; (v) to attend and follow up on any request, question, comment, complaint or contact request you make to us, and (vi) to send you notifications of changes to this privacy notice. The purposes are considered to originate, and are necessary for, the existence, maintenance, and fulfillment of the legal relationship between CCLA and you.


Additionally, your Personal Data will be used for the following ancillary purposes: (i) to send you notifications, notices, propaganda or advertising on our products or services; (ii) to send you invitations to events organized by CCLA, information, our Newsletter, magazines and news regarding our industry or topics that we believe may interest you; (iii) to provide your information to third parties interested in doing business, granting financing, acquiring CCLA´s shares or assets or those of its shareholders or affiliates or interested in merging with CCLA; (iv) to carry out CCLA´s advertising or commercial prospecting purposes, its affiliates and shareholders in Mexico or third parties, and (v) to create databases for research, statistical or market purposes, as well as to measure the quality of CCLA´s services. The purposes are not considered strictly necessary for the existence, maintenance, and fulfillment of the business relationship between CCLA and you, so you can express your refusal to the processing of your Personal Data by checking the following box:


☐ I do not want CCLA to use my Personal Data for the purposes referred to in the previous paragraph.


How do we protect your Personal Data? We are committed to treating your Personal Data under the administrative, physical, and technical security measures established by the Federal Law for the Protection of Personal Data in Possession of Individuals (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (“Law”) and its Regulation, to avoid its damage, loss, destruction, theft, loss, alteration and/or unauthorized treatment.


Given that CCLA stores and carries out the processing of your personal data through computer systems or through the Internet, we inform you that since electronic communications are not totally secure, and that any computer system is exposed to possible vulnerabilities that may affect its operation or security, CCLA cannot guarantee that there will be no damage, loss, destruction, loss, alteration, or unauthorized processing. CCLA will comply with administrative, physical, and technical security measures in accordance with data protection regulations and any other applicable regulations.


Your rights – How can you access, rectify, cancel, or object to the processing of your Personal Data? As the owner of the Personal Data provided to us, you will have the right to access the personal data we hold as well as to the details of the processing thereof; rectify it if it is incomplete or inaccurate; cancel it if you consider that it is not required for any of the purposes set forth in this privacy notice, is being used for purposes that have not been consented to, or object to the processing thereof for specific purposes.


If you wish to exercise your rights of access, rectification, cancellation and/or objection to the processing of your personal data, or have any questions or comments regarding the same, you may contact us at the physical address or email address listed in our contact details.


In terms of the applicable law, any request to exercise the aforementioned rights must necessarily provide and indicate: (i) your name and address; (ii) a copy of your official identification (passport, voter´s credential or driver´s license), (iii) the clear and precise description of the Personal Data to which you wish to access or that you wish to rectify, cancel or object and any other element that facilitates the location of your data, as well as (iv) any other requirement established by the Law and/or other applicable provisions.


CCLA will respond to any complete request within a maximum of a 20 business days-term, or the maximum permitted by law. CCLA´s response will indicate whether the request for access, rectification, cancellation, or objection is appropriate and, if so, CCLA will make the determination effective within 15 business days following the date in which it communicates the response to the owner of the personal data or its representative, if any. The deadlines may be extended under the terms set forth in the applicable regulations. CCLA will provide electronic copies of your personal information in case you exercise your right of access.


How can you limit the use or disclosure of your Personal Data? You have the right, at any time, to totally or partially limit the use or disclosure of your personal data for purposes that are not necessary with respect to our legal relationship, for this purpose, please send us an email or post mail, indicating either one or all the purposes for which you wish to limit the use or disclosure of your personal data, in order for you to be included in an exclusion list from which you will be given an electronic or physical record, as requested.


Also, in terms of the Federal Consumer Protection Law (Ley Federal de Protección al Consumidor), you may register within the Consumers´ Public Registry (Registro Público de Consumidores) to prevent us from contacting you by telephone to send you advertising or information. For more information on this Registry, visit www.profeco.gob.mx or call 9628 0000 from Mexico City or 01 800 962 8000 from the rest of the Mexican Republic.


How can you revoke your consent to the processing of your Personal Data? You may revoke the consent you have given us for the processing of your personal data, at any time, by contacting us through our email or in person at our offices and informing us know such situation. We inform you that in case you revoke your consent for the treatment of your Personal Data (including patrimonial and financial), we will be unable to continue with our legal relationship.


Transfer of your Personal Data – With whom do we share your Personal Data? As part of the management and administration of the services to be provided by CCLA, we may transfer your Personal Data with our parent company and/or all or any of our affiliated companies, subsidiaries, licensees, and/or those belonging to the same economic group in Mexico and/or abroad if they operate under the same internal processes and policies. Likewise, CCLA reserves its right to share your Personal Data with administrative, judicial, or governmental authorities of any kind in Mexico or abroad, if this is established by judicial or administrative mandate or is so determined by law. CCLA will share your information when subcontracting with third parties, whether lawyers, auditors, accountants, or system administrators who are required to process your information on behalf of CCLA and under the instructions of CCLA.


CCLA does not require your consent to make the above transfers of data.


Your Personal Information may be shared with any company´s prospect, potential buyer, or acquirer of CCLA´s holding company or any of its assets. Also, your Personal Data may be shared with third parties interested in doing business or establishing a legal relationship with us, granting financing, acquiring CCLA´s shares or assets or those of its shareholders or affiliates in Mexico or worldwide, or merging with CCLA.


☐ I do accept the transfer of my Personal Data in the terms provided in the immediately preceding paragraph.


Storage of Your Personal Data. CCLA, by itself or through any of its affiliates or subsidiaries, may keep your Personal Data in databases located in the United Mexican States or abroad, without any limitation, except for the periods indicated by the applicable legislation, as well as to comply with the purposes indicated in this privacy notice, as stipulated in the Law, its Regulations, and other applicable regulations.


Social Media. CCLA may have a profile, either of the company or its developments, in social media (hereinafter, the “Social Media”). The Social Media will serve solely and exclusively as an immediate communication channel with the company´s followers or its products, as well as an electronic means of information and marketing of new products, offers and promotions made by CCLA exclusively in its profile and which will be accessible therethrough to its followers. CCLA will only be able to know the Personal Data that is allowed by the Social Media and in no case will extract its follower´s personal data which may be known to it without their prior consent. We inform you that the Social Media will be the owners of the databases corresponding to them, thus we encourage you to read the privacy policies and conditions of use thereof.


Amendments to the Privacy Notice, Legislation and Jurisdiction. We reserve the right to amend or updates this privacy notice at any time, in response to new legislation, internal policies or new requirements for the provision or offering of our products or services. In case of amendments to this privacy notice, you will be notified through the email provided by you at the time of contracting with us, our offices or website. In any case, you will have the right to cancel and/or rectify your Personal Data as well as to limit its use and disclosure or revoke your consent, in case of amendments to the terms thereof.


This privacy notice, the treatment of your Personal Data and/or all related documents are governed by the Law and other United Mexican States´ regulations. The acceptance of this privacy notice or the entering a contract of any nature with CCLA, once made available, implies an express acceptance, in writing of its terms and an express submission to the courts of Mexico City, in case of any dispute or claim arising therefrom, so hereby and thereby waive any other jurisdiction which by reason of domicile, present or future may otherwise be applicable to you. If you consider that your right to protection of personal data has been violated by our conduct, you may file a complaint or grievance before the National Institute of Transparency, Access to Information and Personal Data (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales), for more information please visit www.ifai.org.mx.


I, the undersigned, personally and, if applicable, on behalf of the individuals represented by me, hereby represent that I understand and accept the terms of this privacy notice, and consent to the processing and transfer of my personal financial data in accordance with the terms set forth herein.