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Privacy Policy

1.- IDENTITY AND ADDRESS OF THE RESPONSIBLE. This Privacy Policy (hereinafter referred to as "Notice") establishes the terms and conditions under which Ingenia Group Internet Desarrollo, S.A.P.I. de C.V., (hereinafter referred to as “INGENIA”), domiciled to receive notifications at Avenida Homero, 1425, 903 A, Colonia Polanco V Sección, 11560, Alcaldía Miguel Hidalgo, Ciudad de México; In its capacity as Responsible, it will treat the personal data of its Holder, protecting and safeguarding their personal data to avoid damage, loss, destruction, theft, alteration, as well as unauthorized treatment.

2.- CONSENT OF THE HOLDER. For the purposes of the provisions of the Federal Law on Personal Data Protection Held by Private Parties (hereinafter the "LFPDP") and other applicable legislation, the owner of the personal data is understood to be the natural person to whom the data correspond, delivers and authorizes their treatment to INGENIA by virtue of any legal relationship that binds them either by virtue of commercial, labor, collaboration and any other that implies an interaction between INGENIA and the owner who expressly states:

That this Notice has been made known to you by the Responsible;
Having read, understood, and agreed to the terms set forth in this Notice, therefore granting your consent regarding the processing of your personal data;
In the event that the personal data collected includes patrimonial or financial data, consent has been granted by signing the corresponding contract, either in printed format or using electronic mediums and their corresponding processes for the formation of consent or even have carried out acts that constitute the express consent of the owner, without any written opposition from it;
That you grant your consent for INGENIA or its Managers to carry out transfers and/or referrals of personal data in terms of section 6 of this Notice.
That in terms of the provisions of article 8 of the "LFPDP", the owner has tacitly consented to the processing of his personal data every time this notice has been made known to him either by his handwritten signature in person or for access to the electronic platforms of INGENIA such as its website www.ingenia.com

3.- PERSONAL DATA COLLECTED. INGENIA may collect personal data from the Owner by any medium of contact between the Owner and the Responsible or their Managers. INGENIA also can collect personal data indirectly through publicly accessible sources and other available sources in the market, such as its website: www.ingenia.com, as well as by filling out forms that INGENIA makes available to the HOLDER at a specific time.

INGENIA collects personal identification, financial, patrimonial, academic, and labor data, indicating in an enunciative, but non-limiting, way the following:

Identification data including names, company names, addresses, telephone numbers, and email addresses, signatures, Federal Taxpayers Register number (RFC), Unique Population Register Code (CURP), voting credential, social security number, as well as affiliation number, birthdate, age, nationality, marital status, personal references and links to social networks.
Job-related information, including your occupations, positions, salaries, benefits, departments or divisions, email addresses, and job, personal, and business references.
Academic information including their educational studies, degrees, professional card numbers, certificates, and other validation documents.
Information used to deliver prizes for the contests that INGENIA organizes by itself or on behalf of third parties such as name, business, conventional or private addresses, telephone numbers, email address, school identification document (if the holder is a minor), identification document of the parent or guardian (if representing a minor), Facebook account, bank account number, and personal references.
Payroll data: name, address, Taxpayer Registration Code (RFC), bank identification document, bank name, bank branch, bank account number, interbank code (CLABE), telephone and extension of the office and email address electronic.
Data registered on developed websites: name, email address, birthdate, contact telephone number, address and gender.
Data registered at reception when visiting the INGENIA facilities, including date and name of the User, represented company, person visited, floor, time of entry and exit, observations and number plates (if you park your vehicle in the building).
Commercial data: telephone and email of the represented company.
Data collected through mobile applications and/or online: Facebook user ID, email address and names used in the application.
Information used to create an email account, including the name of the employee and the name of the company.
Data provided for technical support purposes, including username, email address, and computer equipment details.


PRIMARY PURPOSES. INGENIA will process the personal data of the Holder in order to carry out the activities and procedures focused on the fulfillment of the obligations originated and derived from any legal and commercial relationship that it establishes as a result of the provision of its services; billing; collection; credit; customer service; contact with the client, with the sales force; and provide, renew, retain, activate, change, return or cancel the services that the Holder requests in terms of DEVELOPMENT OF TECHNOLOGIES, HOSTING, CREATIVITY, BRANDING, STRATEGY AND INNOVATION, DIGITAL MARKETING, DESIGN, PRODUCTION AND STAFFING, as well as travel and events that are organized. Likewise, for activities related to access control and safeguarding of human and material resources within the facilities of the Responsible or the buildings that are made available to them in response to the requested service.

INGENIA will also process personal data in order to fulfill with obligations in labor, tax, administrative, sanitary, prevention of money laundering and financing of terrorism. The foregoing as a medium of compliance with obligations established in Laws and regulations of general observance and of public interest, which is why it is made aware of the provisions of article 10 of the "LFPDP"
By an enunciative and not limitative way, INGENIA may use the Holder's personal data for the following cases:

Answer doubts, complaints and suggestions, either in person, electronically or by telephone, as well as for any procedure regarding the services and products that it is developing;
Send you quotes about the services and products that are requested;
Contact you to offer INGENIA services and productS;
Generate statistical reports; and
To comply with the applicable legislation, as well as the requirements of federal and local authorities.

SECONDARY PURPOSES. Likewise, INGENIA will process personal data for other purposes such as sending notification of offers, notices and/or promotional messages; communications for marketing or advertising purposes about new or existing products and services, whether owned or from business partners; conduct surveys; statistics; Market studies; evaluate the quality of services; and in general for any activity focused at promoting, maintaining, improving and evaluating its products and services.

The HOLDER may oppose the processing of their data for secondary purposes through the mediums made available to them for the exercise of their ARCO rights. If you do not object within five business days after your data was collected, it will be understood that you have given your consent.

5.- VIDEO SURVEILLANCE AND PHOTOGRAPHY. Any person who enters the Responsible's facilities may be videotaped by our security cameras and may also be photographed.

The images captured by the cameras of the closed-circuit television system will be used for your safety and other people who visit us, to remotely monitor the properties and confirm in real-time any risk condition to minimize it. Also, to protect the material and human resources within our facilities. The photographs are intended to carry out the control of access to our corporate facilities.

The video recordings and/or photographs are stored for 25 to 35 days in the buildings.

6.- TRANSFERS AND / OR REMISSIONS OF DATA. requires sharing the personal data of the Holder in order to comply with its legal and/or commercial obligations, for which it has entered into or will enter into various commercial agreements. The recipients of personal data are obliged by virtue of the corresponding contract, to maintain the confidentiality of the personal data supplied and to observe this Notice. INGENIA and/or its Managers may communicate the personal data collected to any other company of the same business group to which the Responsible belongs and that operates with the same internal processes and policies for its treatment with the same purposes described in this Notice.

Likewise, the Holder is made aware that INGENIA will share their personal data, among others, to the following third parties:

With the companies that support us in the management and administration of the personal data that is collected; With the companies that support us in the management and administration of the personal data that is collected;
With the developers and integrators of the services offered by INGENIA, such as internet sites that operate social networks such as Facebook, Twitter, Instagram and any other similar existing or that will be developed, and necessary for the provision of the services that INGENIA offers, including service providers that support us in providing the contracted service;
We may share your personal data with other companies of the same group, as well as with subsidiaries, affiliates, controlled or controlling INGENIA; and
With federal and local authorities, in compliance with the obligations contemplated in the applicable legislation and/or in compliance with their requirements.

Any third party to whom the aforementioned transfer is made, if applicable, previously states that they are aware of this Privacy Notice and be bound by its terms.

7.- PROCEDURE TO EXERCISE ARCO RIGHTS AND REVOCATION OF CONSENT. The Holder has, at any time, the right to access, rectify and cancel their data, as well as to oppose their treatment or revoke the consent previously provided by submitting a free written request, which must contain the following information and documentation:

Name of the Holder, and address or other medium to communicate the response to your request;
Current documents that prove your identity (copy in printed or electronic format of your voter credential, passport or Visa) or, where appropriate, the legal representation of the Holder (copy in printed or electronic format of attorney power with Holder and representative signature , and their corresponding valid official identifications - voter credential, passport or Visa);
The clear and precise description of the data you seek to exercise any of the ARCO Rights, and
Any other element or document that facilitates the location of the Holder's personal data.

In the case of requests for rectification of personal data, the Holder must also indicate the modifications to be made and provide the documentation that supports the request.

In order to comply with the obligation of access to your personal data, it is necessary an accreditation of the owner identity or representative personality; making the information available on site at the Responsible address. It could be agreed another medium between the Owner and the Responsible, in the case that the requested information allows it.

For the reception and response of requests to exercise your ARCO rights, the revocation of your consent and the other rights provided for in the LFPDP, we make the following mediums available for you:
Email: [email protected]
Address: Avenida Homero 1425, 903 A, Polanco V Sección, Alcaldía Miguel Hidalgo, 11560, Ciudad de México.

In the event that the information provided in your application is incorrect or insufficient, or the corresponding accreditation documents are not accompanied, we may request, within five business days following request receipt, to provide the elements or documents necessary to process it. The Holder will have ten business days to meet the request, counted from the day after it has been received. If no response is provided in this period, the corresponding request will be considered not submitted.

INGENIA will respond to the Holder within a maximum period of twenty business days, counted from the date the request was received. If the request is appropriate, make it effective within fifteen business days after the response is communicated. In all cases, the answer will be given by the same medium you submitted your request or, where appropriate, by any other medium agreed with the Holder.

8.- LIMITATION OF USE AND DISCLOSURE OF INFORMATION. The Responsible and/or their Managers will keep the personal data of the Holder for as long as necessary to process their requests for information, products, and/or services, as well as to maintain accounting, financial and audit records in terms of the LFPDP, and current commercial, fiscal and administrative legislation.

The personal data collected will be protected by appropriate administrative, technical, and physical security measures against damage, loss, alteration, destruction, or unauthorized use, access, or treatment, in accordance with the provisions of the LFPDP, and other applicable legislations. Notwithstanding the foregoing, INGENIA does not guarantee that unauthorized third parties have access to the physical or logical systems of the Holders or Responsible Party, as well as to the electronic documents, and files stored in their systems such as Hacking. Consequently, INGENIA will in no way be responsible for any damages that may arise from unauthorized access.

You or your duly accredited legal representative may limit the use or disclosure of your personal data through the same medium and procedures provided for the exercise of ARCO Rights. If your request is appropriate, you will be registered in the exclusion list provided by INGENIA to stop receiving information related to advertising and marketing campaigns.

Likewise, you have the right to register in the PROFECO’s Public Registry to Avoid Advertising (REPEP) http://repep.profeco.gob.m

In the event that you consider that INGENIA has violated your right to personal data protection, you can go to the National Institute of Transparency ("INAI").

9.- DATA COLLECTION WHEN BROWSING IN INGENIA’S WEBSITES. INGENIA may collect data through its websites, or through the use of automatic data capture tools. These tools allow us to collect the information that your browser sends to the website, such as the type of browser you use, the user's language, access times, and the IP address of the websites you used to access the websites of the Responsible or their Managers.

Within the automatic data capture tools used by INGENIA on its websites and pages are cookies, Web beacons, and links in emails.

Use of Cookies.- The proper functioning of the INGENIA site requires the enabling of "cookies" in your Internet browser. "Cookies" are small data files transferred by the website to your computer's hard drive when you browse the site. In most browsers, cookies are automatically accepted by virtue of their default settings, you can adjust your browser preferences to accept or reject cookies. Disabling cookies may disable various functions of the INGENIA websites. In case you prefer to delete cookies, you can delete the file at the end of each browser session.

Use of Web beacons.- Also known as Internet tags, pixel tags and, clear GIFs. INGENIA may use Web beacons on its websites and in its HTML-formatted emails, alone or in combination with cookies, to collect information on the use of the websites and their interaction with an email. The Web beacon is an electronic image, called a single pixel (1x1) or GIF that can recognize information that is processed on your computer, such as cookies, the time and date when the site was visited, and its sections viewed.

Links in INGENIA emails.- The emails may include links that allow INGENIA to know if you activated the link and visited the destination web page, and this information may be included in your profile. Likewise, they may include links designed to direct you to the relevant sections of the Web sites. By redirecting it through INGENIA's servers, the redirection system allows to determine the effectiveness of online marketing campaigns.

Protection of minors, persons in a state of interdiction or incapacity.- INGENIA encourages parents and/or guardians to take an active role in the online activities of their children or represented. In case you consider that the personal data have been provided by a minor or by a person in a state of interdiction or incapacity, in contravention of this Notice, please send an email to [email protected], so INGENIA can proceed to delete the personal data as soon as possible.

10.- CHANGES TO THE NOTICE. INGENIA reserves the right to periodically update this Notice and to reflect changes in its information practices. It is the responsibility of the Owner to review the content of the Notice on the site https://ingenia.com/globals/privacy-policy.html or by requesting it to the email [email protected], the Responsible party will understand that not expressing otherwise, it means that the Owner has read, understood and, agreed to the terms set forth therein, which constitutes their consent to changes and/or updates regarding the processing of their personal data.


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