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At Brel Proyectos Financieros S.A de CV and/or any of its holdings, subsidiaries, affiliates, companies and/or entities belonging to the same business group we are aware and recognize the importance of the treatment and use of personal information. Therefore, through this Privacy Policy (“Privacy Policy“) we inform you that Brel Financial collects, uses, stores, treats, transfers, and protects certain personal information in the following terms.

This Privacy Policy, as well as the information contained herein, is issued in accordance with the Federal Law for the Protection of Personal Data in Possession of Private Parties (“LFPDPPP“).

  1. Purposes, Use & Collection of Personal Data.
  • Purposes and Use. Considering our internal, corporate, commercial, advertising, and customer service processes, as well as from our methods of information, contracting, invoicing, follow-up and general services, we inform you that Brel Financial collects, uses and protects your Personal Data, including those classified as sensitive, with the following Purposes (“Purposes“): (i) To identify, locate and contact its owner; (ii) To send and provide information related to Brel Financial; (iii) To send and provide information related to Brel Financial’s services, as well as to promote, advertise and quote such services; (iv) To answer to our clients’ questions, doubts or concerns; (v) To conduct investigations prior to any contracting, including but not limited to, before credit information companies, Credit Bureau and judicial authorities; (vi) If applicable, to establish a commercial, professional or business relationship; (vii) To comply with and maintain all obligations or requirements that, contractually or by provision of any law or authority, Brel Financial must comply with or enforce; (viii) To evaluate the quality of Brel Financial’s services, as well as the support to our clients; (ix) To conduct inquiries and surveys on behalf of Brel Financial; (x) Send notices and communications of importance concerning Brel Financial or its services, including information related to changes in the commercial terms and conditions, or information regarding new services; (xi) Maintain the security and integrity of the individuals visiting Puntoa’s facilities, and Brel Financial itself; and (xii) Develop databases and generate statistical data for Brel Financial’s internal control.
  • Personal Data. We inform you that the Personal Data that Puntoa collects or may obtain from you and use, may be, but not limited to (“Personal Data“):
  • In the case of an individual, full name, nationality, country, age, place and date of birth, marital status, occupation, address, landline, personal and mobile telephone, data and official identification documents such as birth certificate, voter’s card, passport, visa and Unique Population Registry Code (CURP), biometric data consisting of fingerprints, iris, hand geometry and facial features; and, in the case of a legal entity, its corporate name, nationality, main activity or line of business, address, landline telephone number, place and date of incorporation, incorporation documents and amendments such as deeds and policies, full name of the legal representative and the powers he/she has, as well as the identification data and documents of such legal representative, among others.
  • Email addresses and social networks, among others.
  • Tax address, proof of registration and proof of tax status of the Federal Taxpayers Registry (RFC), notice of compliance with tax obligations issued by the Tax Administration Ministry (SAT), proof of inclusion in the provisional or definitive list published by the Ministry of Finance and Public Credit (SHCP) in connection with Article 69-B of the Federal Tax Code, invoices, Internet Tax Receipts (CFDI’s), receipts for fees, and annual returns, among others.
  • Bank information (bank institution, account number and CLABE), credit history, quotations and amount of operations or contracts, among others.
  • Level of studies, academic history, professional credentials, professional titles, certificates, diplomas, acknowledgments and recommendations, curriculum vitae, employment application, psychometric, knowledge and technical evaluations, personal, commercial or professional references, information obtained during the interview process, union affiliation, affiliation to any public health institute (IMSS, ISSSTE or similar) and affiliation number, Retirement Savings System (SAR) number, medical history and history of affiliation and/or contracting any type of medical and/or health insurance, whether public or private, and attendance list, among others.
  • Articles of Incorporation, powers of attorney, public instruments (deeds or policies) containing meetings of partners or shareholders regarding corporate amendments to bylaws and/or transfer of shares, contracts, agreements, judicial records, lawsuits, or judgments, among others.
  • Regarding the foregoing, you expressly agree and authorize Puntoa to collect your Personal Data in any of the ways indicated below, in the understanding that such ways are indicated in an enunciative but not limited manner: (i) When you provide them to us directly through direct personal visit to our facilities; or (ii) When you provide them to us through email, phone call or videoconference; or (iii) When you browse our Official Website (“Website“), or use our online services, chatbots and applications; or (iv) When you browse and contact us through any of our Official Social Networks (“Social Networks”); or (v) When you contact us through electronic or digital instant messaging platforms such as SMS, WhatsApp, Telegram, Messenger and other similar; or (vi) When you contact us directly or indirectly through the official advertising and marketing companies that are subcontracted by Puntoa; or (vii) When you subscribe to our Newsletter (“Newsletter“); or (viii) When you contact us directly or indirectly through any individual or legal entity, national or foreign, and in general, through any third party; or (ix) When you contact us through any other mechanism allowed by Law. If you enter, transit, or remain in Brel Financial’s facilities, you will be recorded and/or photographed for security reasons.
  • For this reason, we inform you that Brel Financial undertakes that the Personal Data will be treated under the strictest security measures to ensure its confidentiality.
  1. Transfer of Personal Data.
  • We inform you that your Personal Data, including sensitive data, may be transferred by Brel Financial and processed inside and outside the country, by third parties other than Puntoa providing in this case the indispensable data for a specific activity or service to holdings, subsidiaries, affiliates, companies and/or entities belonging to the same business group, suppliers, commission agents or third parties that provide Brel Financial with services inherent or derived from our internal, corporate, operational, commercial, advertising, informative, and customer services processes such as: management, finance, accounting, legal, billing and collection, advertising and marketing agencies of the services offered, companies or third parties responsible for marketing, coordination and customer service, as well as to the competent federal, state and municipal authorities, solely and exclusively when it is within the exceptions indicated in the LFPDPPP and its Regulations. In the event that this transfer were to occur, Puntoa will communicate this Privacy Policy to such third parties, who must adhere to it.
  • We inform you that, if you do not express your opposition to the transfer of your Personal Data, it will be understood that you have given your consent to do so.
  1. Sensitive Personal Data.
  • In order to comply with the Purposes set forth in this Privacy Policy and/or in compliance with legal, tax, administrative and/or judicial obligations, Puntoa may obtain in some cases Sensitive Personal Data (“Sensitive Data“), being all those Personal Data that affect the most intimate sphere of its owner or whose improper use may give rise to discrimination or entail a serious risk to the owner. In particular, those that may reveal aspects such as racial or ethnic origin, present and future state of health, genetic information, religious, philosophical and moral beliefs, political opinions, sexual preference are considered sensitive.
  • In accordance with article 9 of the LFPDPPP, you must express your consent for the processing of your Sensitive Data, indicating whether or not you accept the processing in the institutional formats that so indicate.
  1. Means to exercise the rights of Access, Rectification, Cancellation or Opposition of Personal Data (ARCO).
  • Puntoa informs you that you have the right to access your Personal Data in our possession and to be informed of the treatment we give to them, as well as to rectify them in case they are inaccurate or incomplete and to cancel them when they are excessive or unnecessary for the Purposes that justified their collection or to oppose the treatment of them for specific purposes.
  • If you have provided us with your Personal Data for the Purposes described above and you wish to access, rectify, update, cancel, oppose or revoke the use of your Personal Data, you may request it at any time by writing to our authorized address or e-mail.
  • Such letter must meet the following requirements: full name and address, e-mail, documents proving your personality, clear and simple description of the right you seek to exercise (reason for the request) and in the case of rectification of any of your Personal Data, you must indicate the changes to be made and provide documentation to support your request. In the event that the person submitting the aforementioned document is not the owner of the Personal Data, legal representation must be evidenced by means of a power of attorney signed before two witnesses or a public instrument, attaching identification of the owner of the Personal Data and the legal representative.
  • Your request will be answered within a maximum period of 20 (twenty) business days from the date Brel Financial receives it and within this period we will inform you of our response by email. In order to attend to your request, Brel Financial may require you to submit the originals of the documents attached to your request, for this purpose, you must go to the address indicated in this document within 5 (five) business days from the date on which they are required. If you do not submit the originals of the documents within this period, your request will be filed and the terms of the processing of your Personal Data will be in accordance with the provisions of this Privacy Policy.

 

  • If your request is admissible, it will be effective within 15 (fifteen) calendar days following the date on which Brel Financial communicates the answer.
  • We inform you that Puntoa may deny the exercise of ARCO rights in the following cases:
  • When you are not the owner of the Personal Data, or you have not duly accredited the representation of the owner; or
  • When your Personal Data does not exist in our database; or
  • When the rights of a third party are harmed; or
  • When there is a legal impediment or the resolution of a competent authority that restricts your ARCO rights; or
  • When the rectification, cancellation or opposition has been previously made.
  1. Cancel of consent to the processing of Personal Data.
  • At any time, you may cancel your consent to the processing of your Personal Data; to do so, it will be necessary to send your request by e-mail to the address indicated in Privacy Policy, where you must expressly state your request.
  1. Use of Cookies and Web beacons.
  • We inform you that Cookies and Web beacons are pieces of information that a website transfers to your computer’s individual hard drive for record-keeping purposes.
  • Our Website may use Cookies that send information to your computer while you are browsing our site. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies track the type of browser, operating system and Internet service provider and allow us to tabulate the total number of visitors to our Website. You can disable Cookies on your computer or set them to notify you when Cookies are being sent to you through your browser’s preferences icon.
  1. Contact us.
  • We work daily to limit the use or disclosure of Personal Data. In Puntoa we have implemented policies and mechanisms that protect in an management, technical and physical way the Personal Data that you have provided us in order to prevent loss, misuse or unauthorized access, publication, modification or destruction of Personal Data. These privacy practices are carried out permanently for the protection, privacy, and confidentiality that the Personal Data deserve.
  • For any questions or comments about our Privacy Policy, or in case you require advice or to update the Personal Data we have about you, please contact us at:

Colomos Nº 2512,

Col. Italia Providencia, C.P. 44648,

Guadalajara, Jalisco, Mexico.

+52 (33) 2304 0645.

curadores@brel.us

Monday to Friday from 09:00 to 14:00 and from 16:00 to 19:00 (GTM-06:00).

  1. Authorization.
  • By accessing our facilities, as well as through the use of our Website, or our Social Networks, or the subscription to our Newsletter, or the exchange of communications by telephone, videoconference, email or instant messaging applications, you consent to the collection, use, storage, processing, transfer and protection of your Personal Data in accordance with this Privacy Policy and for the Purposes, terms and conditions set forth herein.
  1. Updates y Changes.
  • Puntoa reserves the right to make at any time, modifications or partial or total updates to the Privacy Policy, either due to changes in Puntoa’s internal policies, or derived from legislative reforms or jurisprudential criteria that are issued from time to time that establish new requirements or processes; the foregoing, in the understanding that the latest version of the Privacy Policy that has been published on our Website will be considered as the updated and current version of such Privacy Policy.
  • In case there is any change to the terms of our Privacy Policy, Puntoa will communicate it in a timely manner through its Website or its Social Networks, or by email.

 

Last Updated: May 01, 2024.

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