Privacy notice

This Privacy Notice is established in compliance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (the “LFPDPPP” or the “Law”), the Regulations of the Law (the “Regulations”), as well as any other legislation applicable and in force in the United Mexican States (“Mexico”), for which we make the following available to you:

INTENDED FOR CLIENTS AND EX-CLIENTS

The client (the “Owner”) is informed that during the processing of their personal data ARMA Y DESARMA® will establish necessary measures to comply with the principles of legality, quality, consent, information, purpose, loyalty, proportionality and responsibility in accordance with the Law. and the Regulations. ARMA Y DESARMA® is committed to keeping its processes updated in order to prevent any violation of your personal data.

I. WHAT PERSONAL DATA DO WE COLLECT?
The Owner is informed that all personal data that he voluntarily provides to ARMA Y DESARMA® will be collected, by any means that we make available to him or her or through publicly accessible means or any other lawful source, which may include:

a) Identification Data: In an enunciative but not limited manner, name, address, email address, date and place of birth, nationality, telephone numbers, geolocation, identification data, among other data of the same nature, with the sole purpose of carrying out the work requested of ARMA Y DESARMA®.
b) Financial and/or Patrimonial Data: By way of example but not limited to, Federal Taxpayer Registry Code (RFC), Unique Population Registry Code (CURP), information related to bank accounts and/or transactions, information about your income, data related to your credit history, among other data of the same nature.
c) Sensitive Data: ARMA Y DESARMA® will not process sensitive data, unless strictly necessary. In cases in which ARMA Y DESARMA® needs to collect Sensitive Personal Data, it will communicate this to the corresponding Owner to obtain their express consent and clearly notify them of the purpose of their Processing.

As part of the client registration process and/or the existing or past legal relationship, ARMA Y DESARMA® may request and/or keep electronic copies of the documentation containing or related to personal data, which will also be safeguarded. with the technical, administrative and physical security measures necessary to protect your Personal Data.
To comply with the obligations legally acquired with you, ARMA Y DESARMA® may process personal identification and contact data of third parties (i.e. family members, friends or other people who constitute your personal references) that will be provided to us by you, so You agree to inform said third parties about the processing of your personal data and the content of this Privacy Notice.

II. PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA
ARMA Y DESARMA® will use the Owner’s Personal Data to comply, in the first instance, with all commercial, administrative, legal, etc. activities. that may arise as a result of the commercial relationship between the Owner and ARMA Y DESARMA®, and, in the second instance, with secondary purposes or that do not necessarily address the commercial or business relationship that is maintained with the Owner, which will be divided as follows:

(a) Primary or necessary purposes: (i) for the provision of the services provided by ARMA Y DESARMA®, whether of an administrative, legal, economic nature or any other area related to the services provided by ARMA Y DESARMA®; (ii) to carry out the collection that is generated by the provision of ARMA Y DESARMA® services; (iii) formalize the contractual relationship; (iv) carry out the registration, renewal or cancellation of the client in the ARMA Y DESARMA® systems; (v) send communications related to the contracted products or services, and information corresponding to the management of the contracted products and services; (vi) prepare and/or modify contracts, agreements, commercial agreements and/or any other document nt necessary to create, complement, fulfill or terminate any commercial, legal or business relationship; (vii) make or attend to and follow up on queries and complaints or requests related to the products and services offered by ARMA Y DESARMA®; (viii) prevent and detect fraud or illegal acts to the detriment of your person, or the Controller; (ix) verify, confirm and validate your identity during the contracting and provision of the services; (x) analyze credit applications; (xi) determination of transactional profile and carrying out any other evaluation or analysis that is required for the provision of ARMA Y DESARMA® products or services; (xii) external and internal audit processes, investigations to prevent and/or detect fraud or other crimes that may cause a claim or damage to the Controller and/or the Owner; (xiii) comply with the policies and procedures of the Controller; (xiv) comply with the legal provisions applicable to the products and services; (xv) comply with the requirements of authorities that regulate us, including without limitation, regarding the prevention of money laundering and financing of terrorism; (xvi) efforts aimed at keeping your personal data updated, correct and complete.
(b) Secondary or non-necessary purposes: We use your data for non-necessary purposes with the aim of improving our services, making you part of our new products and providing you with a better customer service experience: (i) evaluate the quality of the contracted products or services, including the performance of internal studies; (ii) contact you personally, by telephone or via email for promotion, telemarketing, or advertising; (iii) marketing, statistics and reporting; (iv) projections; (v) historical behaviors; (vi) socio-demographic analysis; (vii) market strategies; and (viii) commercial prospecting.
If you do not agree with the secondary or non-necessary purposes, we inform you that you will have a period of no more than (5) five calendar days from the date on which this Privacy Notice is made available to you. to inform us of your refusal via email or in our Personal Data Office, whose data is provided below. The rights of the Owner to exercise their rights to revoke consent or opposition are safeguarded, in the event that they do not express their refusal to process their personal data, prior to their delivery or processing.

III. PERIOD WHICH PERSONAL DATA WILL BE KEPT
The Personal Data collected will not be kept for a period of time longer than permitted by applicable data protection laws and, in any case, for longer than necessary for the purposes for which it was collected, nor are they otherwise processed. unless a longer retention period is required by applicable law.

IV. TRANSFER OF PERSONAL DATA
ARMA Y DESARMA® does not carry out transfers without having previously obtained the consent of the Owner, as long as said consent is required in accordance with the Law. In the event that, at the time of collecting Personal Data, there is a need to make a transfer with respect to which the Law requires the consent of the Owner, and if it has not been previously obtained in some way, ARMA Y DESARMA® will communicate it to the Owner. If the Owner does not object, it will be understood that he has given his Consent to carry out the Transfer.
ARMA Y DESARMA® will make this Privacy Notice and the purposes to which the Owner subjected its processing available to third parties to whom, where appropriate, it transfers personal data. Where applicable, the processing of personal data by the third party must be carried out in accordance with the provisions of this Privacy Notice and the third party must assume the same obligations that correspond to ARMA Y DESARMA®.
ARMA Y DESARMA®, as responsible for the personal data, guarantees that this Privacy Notice will be respected at all times and the necessary measures will be adopted so that the people who have access to your personal data comply with it, as well as with the principles of personal data protection established in the Data Law.
Personal data may be transferred within the national territory or abroad, in compliance with the applicable regulations in accordance with this Privacy Notice.
In accordance with article 37 of the Law, the Controller may transfer his personal data without his consent, including but not limited to, and in accordance with the competent legislation, to:
a) To controlling companies and/or affiliates and/or subsidiaries and/or related or pert companies to the same business group of ARMA Y DESARMA®, that operate under the same processes and internal policies of ARMA Y DESARMA®, for the purposes of marketing, advertising, promotion, commercial prospecting, reference processes, preparation, valuation and analysis of customer profiles, centralized storage of information, analytical and statistical purposes and historical registration of users and the conduct of surveys regarding ARMA Y DESARMA®, its subsidiaries and/or affiliates.
b) To government authorities, organizations or entities, in compliance with or in relation to the obligations contemplated in the legislation applicable to ARMA Y DESARMA®, its subsidiaries and/or affiliates, as well as in compliance with requirements made to them.
c) To third-party acquirers, derived from a corporate restructuring of ARMA Y DESARMA®.
d) Providers of services or products and/or commercial allies, with whom ARMA Y DESARMA® has a contractual relationship that requires their support for the provision of services.
e) To companies dedicated to real estate development, property owners, and/or construction companies.
f) To any company to carry out the corporate purpose of ARMA Y DESARMA®.
Likewise, we inform you that the Controller may send your personal data to third party providers of services necessary for compliance with the legal, accounting, regulatory or contractual obligations of the Controller or the parent company or its affiliates, as well as to third parties that provide services related to information technologies, operation and administration.

If you do not want your personal data to be transferred in terms of the above, you can express this from the moment you provide us with your personal data or, at any time thereafter, following the procedures described in the Privacy Notice.
Except for these cases, the Controller will not share or transfer your personal data to third parties except in the cases provided for in the applicable laws, or in the event that the Owner has previously consented to such transfer of their personal data.

V. PERSONAL DATA OFFICE

The area responsible for the processing of personal data of ARMA Y DESARMA® is located in the office with address Carretera San Miguel de Allende a los Rodriguez, Km 2.5, Col. Palmita de Landeta, San Miguel de Allende, Guanajuato, Postal Code 37748 (“Personal Data Office”) and whose public service hours are from 10:00 a.m. to 5:00 p.m., Monday to Friday, and email address [email protected] (the “Contact Person”).

VI. MEANS FOR THE EXERCISE OF YOUR RIGHTS ARCO

In order for the Holders of personal data to exercise their rights of access, rectification, cancellation or opposition (the “ARCO rights”), as well as to revoke consent to ARMA Y DESARMA® for their processing, a request must be sent. of ARCO Rights, either by email to the Contact Person or by submitting said request physically in our Personal Data Office. It is important to mention that the exercise of each of these rights is independent of each other, that is, it is not necessary to exhaust one to exercise any of the others.
The Holders of personal data are informed that the hours for receiving ARCO Rights requests are:
• From 9:00 a.m. to 6:00 p.m., Monday to Friday, when sent by email;
• From 09:00 to 15:00 hours from Monday to Friday, when they present themselves at our Personal Data Office.
Any request sent by email outside of the aforementioned hours will be considered submitted the next business day.
With the aim of facilitating the communication and exercise of ARCO Rights of our Holders, ARMA Y DESARMA® makes available to them the application called “ARCO Rights Request”, through its website www.armaydesarma.com, upon request. through the Contact Person’s email and/or in their Personal Data Office.
When ARMA Y DESARMA® receives the Request for Arco Rights, duly signed by the Owner and/or their representative, as well as with the requested annexes, ARMA Y DESARMA® will inform the owner within a maximum period of 20 (twenty) days. calendar days counted from the date on which said request was received to issue its resolution so that, if appropriate, it is made effective within fifteen (15) calendar days following the date on which the response is communicated. In the event that the information provided in the request is insufficient or erroneous to respond to it, or the necessary documents are not accompanied, ARMA Y DESARMA® may require the owner, once and within five (5) calendar days following receipt of the application, to provide the elements or documents necessary to process it. The owner will have ten (10) calendar days to respond to said request, counted from the day following receipt of it, with the understanding that, if a response is not provided within said period, the corresponding request will be considered not submitted. In the event that the owner meets the information request, the deadline for ARMA Y DESARMA® to respond to the request will begin to run the day after the owner has met the request.

In the event that the term indicated by the Law and the Regulation elapses without ARMA Y DESARMA® giving a response to the owner’s request, the owner may exercise his ARCO rights before the National Institute of Transparency, Access to Information and Protection of Personal Data (the “INAI”), with address located at Insurgentes Sur No. 3211 Col. Insurgentes Cuicuilco, Delegación Coyoacán, C.P. 04530, Mexico City.

The Owner may revoke his consent for the processing of his Personal Data, as long as such revocation does not imply the impossibility of complying with obligations derived from a current legal relationship or when said Processing is established by law or when any of the assumptions of exception to consent provided for in the Law.

ARMA Y DESARMA® wants to keep your personal data updated and current at all times. Therefore, we request your help and cooperation to inform us in a timely manner of any changes that we must take into account, to incorporate them into our databases. You guarantee and respond, in any case, for the veracity, accuracy, validity and authenticity of your personal data and any information you provide to us, as well as any third party in your custody or legal representation, with the understanding that ARMA Y DESARMA ® will fully comply with the provisions of the applicable legislation.

VII. USE OF COOKIES
The warning is given that ARMA Y DESARMA® may use “cookies” or “web beacons” on its website, as well as in its technological applications, for the purpose of confirming your identification, personalizing your access to the portal and reviewing its use. , monitor your behavior as an Internet user, provide you with a better service and user experience when browsing our page, offer you new products and services based on your preferences, since through the aforementioned “cookies” personal data of users is collected in terms of the Law and its Regulations. These technologies can be disabled by accessing the settings or preferences of your browser and looking for the corresponding option to disable cookies or not use cookies. We remind you that the option to disable these technologies may vary depending on the technological platform, browser and mobile device you use to visit our site.
Our portals may contain links to other external sites, of which the content and privacy policies are not the responsibility of ARMA Y DESARMA®, so the user, where applicable, will be subject to the privacy policies of those other sites. without any responsibility borne by ARMA Y DESARMA®.

VIII. MECHANISMS TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL DATA
The Owner may limit the use or disclosure of his Personal Data by using the enabled means described in section V. of this Privacy Notice, which consist of (i) expressing his refusal to process his Personal Data for the Purposes Secondary or Not Necessary, in terms of the penultimate paragraph of section 2 of this Privacy Notice; (ii) not accept the processing of your Personal Data by omitting to give your express consent to this Privacy Notice; and (iii) exercise your ARCO rights in accordance with the provisions of this Privacy Notice, the Law and the Regulations. In this sense, it is important to mention that, once the Owner exercises any of the previously mentioned rights, ARMA Y DESARMA® will carry out the corresponding actions to respond to your request, such as excluding the Owner from the corresponding communications.
If you are the Owner of Personal Data collected by ARMA Y DESARMA® and wish to obtain more information about this Privacy Notice and the compliance policies of the Personal Data Law that ARMA Y DESARMA® has adopted, please send a letter to the address from the Personal Data Office of ARMA Y DESARMA® provided in section IV of this Privacy Notice and/or to the email [email protected], and indicate as recipient the Personal Data Department of ARMA Y DESARMA®.

IX. MEANS TO REVOCATE CONSENT FOR THE PROCESSING OF PERSONAL DATA
To revoke your consent for the processing of your personal data, you must submit your request to the Person of Con tact, sending an email to the following address: [email protected]
If, after the revocation, you request confirmation of the same, the Controller will respond expressly.

We inform you that not in all cases we will be able to respond to your request or conclude the processing of your personal data immediately, since it is possible that due to some legal obligation, we require to continue processing your personal data. Revoking your consent for the processing of your personal data may result in the impossibility of continuing with our legal relationship.

X. SECURITY AND CONTROL MEASURES
In the interest of protecting your personal data against use, damage, access, alteration, destruction or any unauthorized treatment, ARMA Y DESARMA® has high security measures and healthy practices, which we request from our subsidiaries, controlling and controlled companies. and/or affiliates. These measures include policies, procedures, employee training, video surveillance systems, physical access control and technical elements related to information access controls.
In the event that a security breach occurs in any phase of the processing of your personal data, which significantly affects your economic or moral rights, the Contact Person will inform you immediately by email or, if the Controller cannot contact you by email, then it will use traditional mail, so that the Owner can take the corresponding necessary measures to defend their rights.

XI. MODIFICATIONS TO THE PRIVACY NOTICE
ARMA Y DESARMA® reserves the right to make modifications to this Privacy Notice at any time, either due to updating any of the established assumptions or due to any modification that affects the characteristics of the Personal Data collected. Any changes to this Privacy Notice will be published on the following Internet page: www.armaydesarma.com

ARMA Y DESARMA® is not responsible if there is any problem with your internet transmission service or any other cause not attributable to ARMA Y DESARMA®, so we suggest you periodically review the content of the most updated Privacy Notice on the page www. armaydesarma.com, or by requesting it through our email: [email protected]

XII. CONSENT
By providing your services or products to the Controller, you grant your consent for the processing of your personal data, including personal financial and property data, under the terms of this Privacy Notice. Denying your consent to the processing of your personal data by the Controller may result in the impossibility of establishing or continuing the legal relationship with the Controller.

This Privacy Notice complies with the requirements established by the Law, the Regulations and other applicable legal provisions.

Last update date of this Privacy Notice: 05/20/24.