GERARDO TAPIA CEREZO or ACIERTO CAPITAL, hereinafter “THE RESPONSIBLE PARTY”, with address at Sierra Candela No. 51, Lomas de Chapultepec, C.P. 11000, Miguel Hidalgo, Mexico City, in the terms of the Federal Law on Protection of Personal Data Held by Private Parties, hereinafter the LAW, hereby communicates the following:

PRIVACY NOTICE

The personal data that is the object of this privacy notice shall be all the data delivered by its holder, hereinafter “THE HOLDER” to “THE RESPONSIBLE PARTY” by any means. By providing the data requested, “THE HOLDER” is accepting that it is aware of this notice and that it grants its consent for its treatment.

“THE RESPONSIBLE PARTY” is committed to observing the legal, consent, information, quality, purpose, loyalty, proportionality, and responsibility principles stated by the LAW.

 

  1. What use will be given to the personal data?

“THE RESPONSIBLE PARTY” shall be in charge of managing the personal data provided by “THE HOLDER” for reason of the relevant service provision, as well as of the use given to it and of its protection. Therefore, based on this notice, it can, among other actions, manage, share, store, transfer, and make available to the authorities or to third parties this data.

The personal data that “THE HOLDER” provides shall be used to: provide the services required by “THE HOLDER”, comply with the responsibilities assumed with “THE HOLDER”, communicate new services or products offered by “THE RESPONSIBLE PARTY” or changes in the services or products already provided, contact “THE HOLDER” with communications or reminders, assess the quality of the service provided by “THE RESPONSIBLE PARTY”, which can be performed through third parties, perform market studies with marketing, advertising, or business prospection purposes and, in general, create administrative files.

  1. What personal data of “THE HOLDER” shall be collected and used?

The personal data includes the following without limitation:

Name, date of birth or incorporation, age, gender, marital status, nationality, address, e-mail, copy of government-issued identification with photograph (passport, voter’s card, professional license, federal voter’s ID with differential code), financial information, operating information, internal policies of the company, personal references, among others.

The personal data collected shall be protected, incorporated, and treated in the physical and digital files of “THE RESPONSIBLE PARTY”. The purpose of this information is to create a file before providing the corresponding professional services.

  1. Consent statement

It is understood that “THE HOLDER” has granted its consent for the treatment of its personal data in accordance with the terms and conditions described in this Notice when:

  1. It does not state any objection about this Notice.
  2. It grants its consent by any of the means (including electronic) indicated by “THE RESPONSIBLE PARTY”.
  3. It states its desire through the execution of a contract or legal act with “THE RESPONSIBLE PARTY”.
  4. It has any legal or commercial relationship in force with “THE RESPONSIBLE PARTY”.

“THE RESPONSIBLE PARTY” is obliged to collect the consent in writing of “THE HOLDER” whenever the data treatment refers to the treatment of financial and/or patrimonial sensitive personal data.

  1. Who will the personal data be shared with?

Derived from the legal relationship that binds them, “THE RESPONSIBLE PARTY” shall have the possibility to share the personal data of “THE HOLDER” with third parties, such as employees and collaborators, business allies, service providers, and any other competent authority in the area of the services provided by “THE RESPONSIBLE PARTY”, who are obliged and shall observe the legal data privacy provisions.

In any case, this privacy notice shall be communicated to the recipients of its personal data so that they respect its terms.

By virtue of the above, “THE HOLDER” expressly states its consent so that the information collected (its personal data) can be transferred.

  1. How can THE HOLDER” access, rectify, or cancel its personal data or oppose to its use?

“THE HOLDER” is entitled to know what personal data “THE RESPONSIBLE PARTY” has that belongs to it, what it is used for, and its use condition (Access). Likewise, it is entitled to request the correction of its personal information in the event it is dated, inaccurate, or incomplete (Rectification); that it is eliminated from the records or databases when it considers that it is not used in accordance with the principles, tasks, and obligations considered in the regulations (Cancellation); as well as to oppose to the use of its personal data for specific purposes (Opposition). These rights are known as ARCO rights.

“THE HOLDER” can access, rectify, or cancel its personal data, or oppose or revoke its consent for its use, by submitting the corresponding request. To have access to the request and learn about the procedure and requirements for the exercise of the ARCO rights, “THE HOLDER” can get in touch with “THE RESPONSIBLE PARTY”, which shall process the requests for the exercise of these rights, and it shall answer any question it may have about the treatment of its information. The contact data is the following:

Address: Sierra Candela No. 51, Lomas de Chapultepec, C.P. 11000, Miguel Hidalgo, Mexico City, TELEPHONE +52 1 (55) 7587 0981, E-MAIL info@aciertocapital.com.

To exercise the ARCO rights in accordance with what is mentioned in the previous paragraph, the request must include:

  1. Name, full address (street, interior and/or exterior number, neighborhood, zip code, city, and state);
  2. The documents that support the identity (copy of voter’s card, passport in force, professional license, or migratory document) or, if applicable, documents that support the legal representation (copy of voter’s card, passport in force, professional license, or migratory document);

III. A clear and accurate description of the personal data for which it wants to exercise any of the ARCO rights, and;

  1. Any document or information that makes it easier to locate the personal data;
  2. In case of requesting data rectification, it must also indicate the modifications that shall be made and provide the documentation that supports the request (birth certificate, proof of address, etc.).

 

  1. How can the consent to use personal data be revoked?

“THE HOLDER” can revoke the consent that it has granted to treat its personal data. However, it is important that it takes into account that its request cannot always be dealt with or conclude the use immediately, as it is possible that it has a legal obligation that requires it to continue treating the personal data. Likewise, “THE HOLDER” shall consider that for certain purposes, the consent revocation shall imply that the relationship that binds it with “THE RESPONSIBLE PARTY” cannot be continued and that it must be terminated.

To revoke its consent, “THE HOLDER” shall submit its request. To have access to the request, learn of the requirements to revoke its consent, “THE HOLDER” can contact “THE RESPONSIBLE PARTY”. The contact data is the following:

Address: Sierra Candela No. 51, Lomas de Chapultepec, C.P. 11000, Miguel Hidalgo, Mexico City, TELEPHONE +52 1 (55) 7587 0981, E-MAIL info@aciertocapital.com.

 

  1. How is it possible to learn of any changes made to this privacy notice?

Modifications, changes, or updating can be made to this privacy notice derived from legal requirements. In this case, “THE RESPONSIBLE PARTY” is committed to keeping you informed of the changes made to this privacy notice, through the following web page: www.aciertocapital.com or by any other means that “THE RESPONSIBLE PARTY” uses for its dissemination.

If “THE HOLDER” considers that its personal data protection right has been affected by any behavior or omission of “THE RESPONSIBLE PARTY” or assumes any infringement to the provisions considered in the Federal Law on Protection of Personal Data Held by Private Parties, its Regulation, and other applicable regulations, it may file its disagreement or claim before the Federal Institute of Access to the Information and Data Protection (IFAI). For further information, you can visit its official web page www.ifai.org.mx

“THE HOLDER” accepts the terms of this Privacy Notice; otherwise, it shall communicate it to “THE RESPONSIBLE PARTY” in the terms of section 5 herein.

Latest updating date of this Privacy Notice: March 1, 2019.