In compliance with the Federal Law on Protection of Personal Data Held by Private Parties, the Regulations thereof and the Privacy Notice Guidelines published in the Federal Official Gazette on January 17, 2013, we provide our Privacy Notice to you:

 

Identity and domicile of the Responsible Person of the data.

Tralexa, Sociedad Anónima de Capital Variable, with domicile located at Presidente Masaryk No. 61 Interior 901 B, Col. Polanco in the Municipality of Miguel Hidalgo of Mexico City, Zip Code 11560. Hereinafter, "Tralexa".

 

Personal data being processed.

To render our services or make administrative paperwork or recruiting processes or business relations or professional advice or provision of services, you voluntarily and directly provide, whether personally or by mail or electronically, personal data to "Tralexa" for the purposes set forth hereunder. Such data are: names and surnames, gender, domiciles, marital status, date of birth, tax ID, sole population registry code, private telephone numbers, mobile telephone numbers, emails, financial data, asset data, personal and professional references and information on bank accounts, as well as work or professional curriculum and official or unofficial identification documents, which may contain the personal data mentioned above or any other data that are deemed personal data and that are inherent to the nature of the document.

 

When you provide data to third parties, you acknowledge and state that you have the consent of such persons to process their data for the purposes you are providing such data.

 

If your personal data were indirectly obtained, i.e., you have not provided them personally and directly to "Tralexa" and we have obtained them through a public access source or a transfer, we will provide our privacy notice to you before processing your data.

 

Sensitive personal data that will be processed.

The data that will be processed and that could be interpreted or considered as sensitive, are the following:

 

Names and surnames, gender, domiciles, marital status, date of birth, tax ID, sole population registry code, private telephone numbers, mobile telephone numbers, emails, financial data, asset data, personal and professional references and information on bank accounts, as well as work or professional curriculum and official or unofficial identification documents, which may contain the personal data mentioned above or any other data that are deemed personal data and that are inherent to the nature of the document.

 

Purposes of the processing.

The purposes of processing the personal data you provide to "Tralexa", for the existence, preservation and compliance with the legal relation with us, are:

 

1. Information and/or quotation of our products and/or services.
2. Advice and/or consultancy regarding our products and/or services.
3. Preparation of all kinds of documents relevant to your relationship with "Tralexa".
4. Investigation and verification of the information and/or data provided.
5. Carry out the activities and paperwork to develop and comply with the obligations that result from the relation with "Tralexa".
6. Send information about updates, notices, notifications, reminders, promotions, invitations and information about our products and/or services and/or legal relation between you and "Tralexa".
7. Recruiting, human resources paperwork, and bank transactions.

 

The purposes of processing the personal data you provide to "Tralexa" to begin a new legal relation with us, provide you with options in our sector and keep you informed, are:

 

1. Marketing, advertising, and market research of our products and/or services.
2. Promote, offer, advertise, and sell products and/or services that are currently or in the future owned by and/or sold by "Tralexa".

 

Mechanisms for the data subject to reject the processing of his/her personal data for the purposes that are not necessary and have not given rise to the legal relation with the responsible party.

If you desire to express your refusal for "Tralexa" to process your personal data for the purposes of beginning a new legal relation with us, providing you with options in our sector and keeping you informed, you must send an email to [email protected], including sufficient information to evidence your identity and stating your refusal for your personal data to be processed for purposes other than those for the existence, maintenance and compliance with a legal relation with us.

 

You must do the foregoing within (5) five business days; however, you preserve your right to revoke your consent or to object.

 

Transfers of personal data; third party receiving personal data and purposes thereof.

With the purpose of granting a good service and maintaining and/or complying with the legal relation between you and "Tralexa", acting with prevention and safety and, as applicable, comply with obligations before authorities, we may transfer your personal data with persons, agencies, organizations, entities, or institutions in the private or in the public sector, in Mexico or abroad. The following must be deemed within the private sector: Our branches and affiliates, external advisors, service providers, credit and legal information institutions, agencies and persons for the validation of information, vendors, and advertising and marketing advisors.

We transfer your personal data without your consent in the events provided in Article 37 of the Federal Law on Protection of Personal Data Held by Private Parties.

 

Agreement with the transfer of your personal data.

"Tralexa" transfers your personal data only when the transfer comply with the exceptions to the obtention of consent provided in Article 37 of the Federal Law on Protection of Personal Data Held by Private Parties.

In the event of a transfer of your data other that those mentioned in the foregoing paragraph, "Tralexa" will inform you in advance so that you are able to grant your consent.

 

"Tralexa" will inform about this privacy notice to the third parties receiving your personal data, so that they abide by its terms.

 

Means and procedure to exercise ARCO rights. / Mechanisms and procedure for data subjects to revoke their consent to process their personal data. / Options and means offered by the responsible party for the data subjects to limit the use and disclosure of personal data.

You or your legal representative may exercise your right to access, rectify, delete, or object (hereinafter, "ARCO Rights"), to revoke your consent for your personal data to be processed, and to limit the use or disclosure thereof, sending an email to [email protected], to the attention of Daniel Ugalde Montes de Oca, who will process your request.

The following information must be included in the email mentioned in the foregoing paragraph: the official identification document of the data subject, the official identification of your legal representative (as applicable), the document that evidences your powers as attorney-in-fact, a letter with handwritten signature of the data subject mentioning his/her full name, the full name of his/her legal representative (as applicable), the right he/she is exercising (Access, Rectification, Deletion, Objection and/or revocation of consent and/or limitation of use or disclosure of personal data), specifying the personal data regarding which he/she is exercising rights, brief description of his/her relation with "Tralexa", and his/her email to give notice of the response to his/her request. With respect to rectification, in addition to the foregoing information, the data subject must mention the changes he/she is requesting and attach to the email the documents that support such changes, as applicable.

The requirements mentioned in the foregoing paragraph have the sole purpose of evidencing the identity of the data subject in terms of law and to complete and answer your request, which will be by email.

If your request in not in the terms mentioned above, whether because the information is erroneous or insufficient, or because the data subject does not attach the documents that must be attached to the email, we will ask for the information required to process your request within five (5) business days after we receive your request. You will have ten (10) business days to satisfy the requirement. If you do not answer within said term, your request will be deemed invalid and your right to submit it again will be preserved.

We will answer your request within twenty (20) business days after receiving your request or after you satisfy the requirement mentioned in the foregoing paragraph. If your request is admitted, it will be effective 15 (fifteen) days after the date you receive the answer. The terms mentioned in this paragraph may be extended only once for the same period, as long as the circumstances justify it.

If your request is regarding a right to "access" and it is admissible, taking into consideration the provisions in Article 34 of the data protection Law, such right will be satisfied by attaching a document to the email where the answer is provided to you.

To answer all requests, "Tralexa" will fully comply with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties and its regulations.

 

Information about the use of mechanisms in remote or local means of electronic or optical communication, or other technologies that allow the obtention of personal data in an automatic manner and at the same time the data subject has contact therewith.

 

Tralexa uses email and the webpage www.trlxa.com as electronic means of communication, which may include the use of cookies, and their purpose is to provide a better browsing service. It may also include web beacons used to monitor the behavior of the user in these means and, through such data, information about origin IP, web browser used, operating system, moment where the page was accessed and, in the event of email, the association of the foregoing information with the recipient may be obtained.

 

We remind you that you may disable or adjust the use of cookies following the instructions in the web browser you use, and we may find our cookies policy on our webpage www.trlxa.com.

 

Procedures and means by which the responsible party will communicate the changes to the privacy notice to the data subject.

 

Changes or updates to our privacy notice will be published on our webpage www.trlxa.com, therefore we suggest to you to access periodically to read our privacy notice, where at the beginning of the text you will find the date of the last update or change made.

 

Whenever we provide you a new privacy notice, we will do it in a clear, evident and unequivocal manner posting an announcement on our webpage www.trlxa.com during (60) calendar days.