Privacy notice (full version)

We welcome you to our website and thank you for your interest in our company.

This privacy notice describes, among other things, the way in which EDAG MEXICO SOCIEDAD ANÓNIMA DE CAPITAL VARIABLE (EDAG MX), processes your personal data and your rights as HOLDER thereof for Access, Rectification, Cancellation and Opposition (ARCO) .
Please do not hesitate to contact us if you have any questions regarding the way in which EDAG MX processes your personal data. Our contact information is found in Sections I and II below.

I. Name of the Responsible and Contact Information
EDAG MEXICO Variable Capital Stock Company
Ébano Avenue, Lot A, Interior 10
FINSA Industrial Park
Cuautlancingo, C.P. 72710, Puebla
Phone: +52 (222) 641-3590
E-mail: info(at)edag.com.mx
Website: https://mx.edag.com/es/

II. Name and contact of the person in charge of processing personal data
Matthias Miehe, CFO
EDAG MEXICO Variable Capital Stock Company
Ébano Avenue, Lot A, Interior 10
FINSA Industrial Park
Cuautlancingo, C.P. 72710, Puebla
Phone: + 52 (222) 641-3590
E-mail: matthias.miehe(at)edag.com.mx
Website: https://mx.edag.com/es/

III. General information on the processing of personal data

1. Purpose of the treatment
We collect personal data from our users to the extent necessary to provide a functional website, content and services. The collection of the personal data of our users is carried out exclusively with their consent. As an exception to this rule, there are cases where, in fact, it is not possible to obtain your prior consent and/or said data processing is permitted by law.

2. Legal basis for the processing of personal data
The legal support for the processing of your personal data is found in articles 6, 7 and 8 of the Federal Law for the Protection of Personal Data Held by Private Parties (LFPDPPP), and articles 2 and 52 of its Regulations (LFDPPP ) and other applicable provisions.

In accordance with the provisions of section IV of article 10 of the LFPDPPP, we process personal data to comply with an obligation derived from a legal relationship with the owner, as well as to comply with the steps prior to the constitution of the corresponding legal relationship.

Occasionally, EDAG MX will process your personal data to fulfill an obligation provided for in the Law, in accordance with the provisions of section I of article 10 of the LFPDPPP.

In any case, in accordance with the provisions of article 4 of the LFPDPPP, EDAG MX will process your personal data, to legitimately protect its own interests, without, therefore, failing to observe the principles established in the various article 6 of the LFPDPPP .

3. Blocking and deletion of personal data
Your personal data will be blocked to prevent access and subsequently deleted, as soon as the purpose for which they were obtained has been fulfilled. Some data may be kept for a longer time, without, therefore, exceeding the terms established in fiscal, administrative and/or accounting provisions that are applicable to your specific case.

4. Collection of personal data
At EDAG MX we can collect your personal data because it is necessary to comply with our obligations, so the refusal to provide it may prevent us from complying with them. We collect your personal data in a variety of ways, 1) when you provide it to us directly; 2) when you visit our website or use our online services, and 3) when we obtain information through other sources that are permitted by law.

At EDAG MX we collect your personal data directly, when you provide it to us through various means, such as when you provide us with information in order for us to provide you with a service, which makes it necessary to comply with our obligations, therefore that the refusal to provide them may prevent us from complying with them.


IV. Website and Log Files
1. Description and scope of data processing
Each time you access our website, the system automatically collects data and information from the device from which access is given.

The information collected is the following:
(1) IP address of the user
(2) Date and time of access
(3) Website visited
(4) Data sent, expressed in bytes
(5) Source/link accessed in the system
(6) Browser used
(7) Operating system used

The data obtained is stored in the log files of our system. This data does not include personal user information.

2. Legal basis for the processing of personal data
The temporary storage of the aforementioned data is based on article 13 of the LFPDPPP.

3. Purpose of personal data processing
The temporary storage in our system of your IP address is necessary so that the user can view the website on his computer. The information obtained is used for purely statistical analysis that allows us to improve our website. To do this, first of all, your IP address is anonymized.

The information collected is stored in log files in order for the website to function correctly. Additionally, said information serves to optimize the website and guarantees the security of our systems. EDAG MX does not process data for commercial purposes in this context. This purpose is covered by articles 6, 7 and 8 of the LFPDPPP.

4. Information storage time
The information is deleted as soon as the purpose for which it was collected is fulfilled. The information collected for the purpose of making the website accessible is deleted as soon as the session is ended.

In the case of information stored in log files, it is kept for a maximum of seven days. Storage for a longer period is possible, in this case, the user's IP will be dissociated, so it does not allow the identification of the client who has accessed the system.

5. Opposition and cancellation rights
The acquisition and storage of information in log files is essential for the proper functioning of the system. The description of the procedure to oppose and/or request the cancellation of data processing is described below, in Section X of this document.


V. Use of Cookies

1. Description and scope of data processing
Cookies are data records that are stored by the Internet browser, in itself, or in the user's computer system. The file contains a specific string of characters that allows the browser to be clearly identified the next time the user accesses our website.

We use cookies on our website to make it more accessible to the user. Some elements of our website require identifying the browser used for access, if the user changes from one page to another.

2. Personal data processed.
The information stored and transmitted by means of cookies is the following:
(1) IP address of the user
(2) Date and time of access
(3) Amount of data transferred
(4) Domain requested

In our system we also use cookies in order to analyze the user's browsing habits. The following information is transmitted in this way:

(1) Type of equipment, model, brand, screen resolution
(2) Operating system, version, family
(3) Browser, version, configuration, engines, plugins, language, language code
(4) Location data
(5) Provider data
(6) Pages per visit, number of visits, time and date of visit
(7) Access and exit page, URL, page title, searched articles, downloads
(8) Search engines, searched articles, websites, social networks
(9) Campaigns, campaign keywords

By accessing our website, the user is informed of the existence of cookies and their use as an analysis tool and is asked to provide their consent for the processing of personal data collected for this purpose.

In the same context, you are provided with information regarding this PRIVACY NOTICE.

3. Legal basis for the processing of personal data

The legal support for the processing of personal data through cookies is covered by the provisions of article 13 of the LFPDPPP. The purpose of processing personal data is to simplify and improve the website, the experience of use by the user and its contents.

Personal data is obtained with the express consent of the user, in terms of the provisions of article 8 of the LFPDPPP.

NOTE FOR USERS RESIDENT IN THE EUROPEAN UNION: The legal basis for the use of Google Analytics, provided your consent has been given, is found in section 1 of Article 6 of the General Data Protection Regulation (GDPR).

4. Purpose of processing personal data
The use of cookies is technically necessary to simplify the user's use of the website. Some functions of the site cannot be offered without the use of cookies, since they allow the recognition of the user when changing from one page to another.

The information collected through cookies is not used to create user profiles.

The information obtained is analyzed to improve the content of our site and its contents. This allows us to understand how the website is used, which allows us to continuously improve our services. This makes it possible to provide the user with an optimal guide through the site and to present it as varied as possible together with new content, each time they visit it again.

This treatment is permitted in accordance with the provisions of articles 6, 7 and 8 of the LFPDPPP.

 

5. Storage period, right of opposition and cancellation

Cookies are stored on the user's computer and from there they are transmitted to our website. Therefore, the user (you) has complete control over the use of cookies. You can deactivate or restrict the transmission of cookies by modifying the settings of your internet browser. Stored cookies can be deleted at any time, which can also be done automatically. If the cookies on our website are disabled, some functions of the site could present difficulties for its correct use.


VI. Job requests via e-mail

1. Description and extent of the processing of personal data

We receive requests via email. The personal data that you provide us through your job application are name, telephone number, address, email address and date of birth, but it is possible that there are some others. Personal data is not shared with third parties without your prior consent.

2. Legal basis for the processing of personal data
The legal support for the processing of personal data, provided by the user, is found in articles 6, 7 and 8 of the LFPDPPP. The processing of personal data, part of our legitimate interest to achieve accurate and effective recruitment of personnel.

3. Purpose of personal data processing
The sole reason for data processing is to allow us to handle your job application.

4. Period of storage of personal data
Personal data is deleted as soon as the purpose for which it was collected is fulfilled. In the case of personal data obtained as a result of the contracting procedure, they are deleted as soon as the contracting process is closed.

5. Right of opposition and cancellation
As an applicant, you can contact us at any time to have your data deleted.

 

VII. Contact via E-Mail

1. Description and scope of personal data processing
You provide us with your email address to maintain contact with us. This is stored together with the personal data you provide us.
Personal data is not disclosed to third parties and is used exclusively for the communication process.

2. Legal basis for the processing of personal data
The cause for the treatment of the personal data collected by the receipt of an e-mail, lies in our interest to manage and respond to your request. If the cause of your e-mail was to sign a contract, the legal support is also found in section IV of article 10 of the LFPDPPP.

3. Purpose of personal data processing
Your personal data is processed exclusively to respond to your e-mail, which we would not be able to do without such processing.

4. Storage period
Your personal data is deleted as soon as the purpose for which it was collected is fulfilled. The personal data transmitted via e-mail are deleted when the private communication with the user is finished. It is understood that a communication with a user is terminated, when circumstances indicate that the subject of the communication has been completely resolved.

 5. Right of objection and deletion
If the user contacts us via e-mail, they may oppose the storage of their personal data at any time, in this case, the communication may not be continued and the personal data collected via e-mail will be deleted.

 

VIII. Web Crawl

1. Description and scope of personal data processing
This website uses Google Analytics, an analysis service of Google Inc. ("Google"). Its use includes the Universal Analytics operating mode; this makes it possible for information, sessions and interactions between multiple devices to be assigned under an anonymized user ID, allowing cross-device analysis of user activity.

Google Analytics makes use of cookies, which are stored on your computer and allow the use of the website to be analyzed. As a rule, the information generated by cookies, in relation to your use of this website, is sent to Google servers in the United States of America, where it is stored. Google will use this information to learn about your use of this website, to compile reports on the activities on the website, to perform other services related to the use of the website and the Internet, for the owner of the website.

For this, the following personal data is processed:

(1) IP address of the user
(2) Date and time of access
(3) Access information
(4) Amount of information transmitted
(5) Requesting domain
(6) Type of equipment, model, brand, screen resolution
(7) Operating system, versions, family
(8) Browser, version, configuration, engines, plugins, language code
(9) Location data
(10) Provider details
(11) Pages per visit, number of visits, repeat visits, time of visit, date of visit
(12) Entry page, exit page, page URL, title, searches, downloads
(13) Search engines, search elements, websites, social networks
(14) Campaigns, campaign keyword

The IP address sent to you via Google Analytics is not merged with other Google data.

2. Legal basis for the processing of personal data
The legal support for the use of Google Analytics, once your consent has been obtained, is found in articles 6, 7 and 8 of the LFPDPPP.

In the case of users residing in the European Union, once their consent has been obtained, the legal support is found in article 6, section 1 of the General Data Protection Regulation.

3. Purpose of personal data processing
The purpose behind the use of web analytics services is to regularly analyze and improve the use of our website. The statistics obtained allow us to improve our services and make them more interesting for you and our users. In exceptional cases, personal data is transferred to the United States of America, in which case, the standard clauses established in the contractual agreements concluded with Google apply.

4. Storage period, right of opposition and cancellation
Any information sent by Google and linked to cookies, user authentication (eg user ID) or advertising IDs are automatically deleted after 14 months. According to Google, every month, automatically, the information that has reached said storage period is deleted. In any case, we point out that we have no control over the period of storage of information by Google.
 

You can prevent the storage of cookies by making the appropriate settings in your browser software, accordingly, we note that if you choose to do so, it may prevent the use of the functions of the website. Similarly, you can prevent Google from collecting the information generated by cookies regarding your use of the website (including your IP address) as well as from processing the information by downloading and installing the browser plug-in available at the following link : tools.google.com/dlpage/gaoptout.

Opting out of cookies may prevent future acquisition of personal data when visiting this website. To prevent collection by Universal Analytics across different devices, you will need to enable the refusal to download cookies for any system in use. Access the following link to start the process: https://tools.google.com/dlpage/gaoptout

This website uses Google Analytics, with the "anonymizeIp" function. This ensures that your IP address is processed incompletely, making it impossible to trace a particular user. If the information collected from you creates a direct personal link, it is immediately blocked, and the personal data is immediately deleted.

Information from third parties (suppliers)

Google Dublin, Google Ireland Ltd., has its address at Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
The applicable terms of use can be found at: https://marketingplatform.google.com/about/analytics/terms/us/.
An overview of the privacy policy can be found at: https://policies.google.com/?hl=en-US and the privacy policy at: https://policies.google.com/privacy?hl=inU.S.
For this purpose, we have an information processing contract with Google.

5. Using the tag tracker
Our site uses Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage website tags through one interface. The Tool Tag Manager, which implements the tags, is a service that can collect (process) personal data by setting cookies.


IX. Using Google Web Fonts

1. Description and scope of personal data processing
We use web fonts provided by Google and downloaded to our local server to ensure font types are displayed consistently. For this purpose, the required web fonts are loaded into the cache of your browser so that the texts and fonts are displayed correctly. If your browser does not support web fonts, a default font from your computer is used.

Cookies are not set when you access the page. In addition, a direct connection to the Google servers is not established, since the fonts are integrated locally on our website.

2. Legal basis for the processing of personal data
We have a legitimate interest in guaranteeing that the types of sources are displayed consistently, which is legally supported in articles 6, 7 and 8 of the LFPDPPP.
In the case of users residing in the European Union, the legal basis for data processing is found in article 6, section 1, subparagraph f) of the General Data Protection Regulation.

3. Purpose of personal data processing
Google Fonts is a freely accessible library of over 8,000 fonts. Google Web Fonts allows us to present our website with an attractive design for the user and with the same quality regardless of the device used to access it. This is the only way to make it technically possible for all visitors to our home page to have a consistent and enjoyable user experience. This is considered a legitimate interest for data processing, within the scope of the LFPDPPP.

For users residing in the European Union, this is considered a legitimate interest contemplated by article 6 section 1 of the General Data Protection Regulation.

4. Storage period, right of opposition and cancellation
Personal data is stored for the time necessary for the purpose for which it was collected. You have at all times the option to oppose the treatment, changing the configuration of your browser.
 

 
X. Google Maps integration

1. Description and scope of personal data processing

On this website we use the services of Google Maps. This allows us to display interactive maps on the website, making it easier for you to use the maps feature.

As soon as you visit the website, Google is notified that you have activated such a subpage on our website. Consequently, the following information is transmitted:

(1) IP address of the computer from which it is accessed
(2) Date and time of the request

This happens regardless of whether or not Google has provided you with a user account for your access. If you are signed in to Google, the information is assigned directly to your account; If you do not want the information assigned to your profile, with Google, you must exit your profile before selecting the link.

Furthermore, depending on the settings that the user has made, it is still possible for Google to obtain information related to your location, however, the consent for the use of this data will always be necessary, therefore, you can deny Google its use. when answering the query.

More information regarding the purpose and scope of obtaining personal data, as well as its processing by the plug-in provider, can be found in the provider's privacy statement, where you will also find additional information regarding your rights in this regard and options of settings to protect your personal sphere.

2. Legal basis for the processing of personal data
The legal basis for the processing of the user's personal data lies in obtaining their consent, in accordance with articles 6, 7 and 8 of the LFPDPPP.

In the case of users residing in the European Union, once their consent has been obtained, the legal basis for the processing is found in article 6, section 1, subparagraph a) of the General Data Protection Regulation.

3. Purpose of personal data processing
Google stores your data as usage profiles, which it then uses for advertising or marketing purposes and/or based on the needs of the website. Such analysis is performed (even for users who are not logged in) to provide needs-based advertising and to inform other people using social networks of your activities on the site.

4. Storage period, right of opposition and deletion
We store your personal data for as long as it is necessary to provide it to Google Maps while you access our website. You have the right to object (withdraw) your consent at any time without affecting the admissibility (acceptable quality) necessary for any processing carried out prior to your opposition.

 Similarly, you have the right to oppose the creation of user profiles and to exercise this right you must contact Google.

5. Transfer of personal data
Google processes your personal data in the United States of America (USA).

By granting your consent to integrate the function, you also consent to the transfer for the processing of your personal data in the USA, in accordance with the provisions of articles 16 section V and 36 of the LFPDPPP.

In the case of users residing in the European Union, with the consent for the integration of the function, you also consent to the processing of your personal data in the USA, in accordance with the provisions of article 49, section 1 of the GDPR, the processing of your data personal, once you have given your consent.

Additionally, we would like to point out that the European Court of Justice considers the USA as a country with an insufficient level of personal data protection, in accordance with the standards of the European Union. In view of this fact, there are no other guarantees that are adequate for the protection of your data. As a result, there is a risk of processing your data by US authorities for monitoring and control purposes, possibly without the possibility of accessing legal recourse. If you do not want this to happen, click on "REJECT"

 

XI. Use of Youtube

1. Description and scope of personal data processing

Videos from YouTube have been integrated into our online service, which are stored on www.YouTube.com and can be played directly on our website. The videos are embedded in "enhanced privacy mode", which means that no personal data of you as a user is transferred to YouTube, unless you play such videos.

The data listed below will not be transferred until you play the videos. We have no interference in the transfer of personal data.

When you visit our website, YouTube will receive the information that the corresponding subpage has been activated on our website. Additionally, personal data such as the IP address and the corresponding access mark are transferred. This transfer occurs regardless of whether or not you access a user account assigned by YouTube. If you have access to your Google account, this information will be directly assigned to your account.

2. Legal basis for the processing of personal data
The legal support for the processing of your personal data is found in articles 6, 7 and 8 of the LFPDPPP

In the case of users residing in the European Union, the legal basis for data processing is found in article 6, section 1, subparagraph a) of the General Data Protection Regulation.

3. Purpose of personal data processing
YouTube stores your data as usage profiles, which it then uses for advertising or market analysis purposes, and/or needs-based website design. An analysis of this type is carried out (even for users who have not logged in), to provide needs-based advertising and, to inform third parties that use that social network, of your activities on our website.

4. Storage period, right of opposition and cancellation
If you do not want this data to be associated with your YouTube user profile, you must exit your profile before clicking the button. You have the right to oppose the creation of these user profiles, and to exercise this right you must contact YouTube directly.

More information regarding the purpose and scope of the treatment of information (acquisition and processing) by YouTube, can be found in its privacy notice, where you will also find additional information about your rights and configuration options, to protect your sphere private at the following address: https://www.google.de/intl/de/policies/privacy

5. Transfer of personal data
YouTube processes your personal data in the United States of America (USA).

By granting your consent to integrate YouTube videos, you also consent to the transfer for the processing of your personal data in the USA, in accordance with the provisions of articles 16 section V and 36 of the LFPDPPP.

In the case of users residing in the European Union, with the consent for the integration of YouTube videos, you also consent to the processing of your personal data in the USA, in accordance with the provisions of article 49, section 1 of the GDPR.

Additionally, we would like to point out that the European Court of Justice considers the USA as a country with an insufficient level of personal data protection, in accordance with the standards of the European Union. In view of this fact, there are no other guarantees that are adequate for the protection of your data. As a result, there is a risk of processing your data by US authorities for monitoring and control purposes, possibly without the possibility of accessing legal recourse. If you do not want this to happen, click "REJECT".


XII. Using HubSpot

1. Description and scope of personal data processing
We use HubSpot services to create and share marketing, sales, and customer service content. The emails that are sent to you for marketing purposes, and the forms and registrations that you complete to obtain information related to Edag products, are managed by HubSpot.

Data collected through the HubSpot service is used to communicate with you about products and services, as well as to market and promote the subscription service we have entered into with HubSpot.

2. Primary purposes of the treatment.
The personal data you provide us will be used exclusively for the following purposes:

1. Identify the person who is interested in Edag services.
2. Send information about the services from which the person requests information.
3. Contact the person requesting information about Edag services, to follow up on possible contracts.
4. Integrate email lists, blogs and posting on social networks, allowing easier and clearer customer service.
5. Give attention to requests for the exercise of ARCO rights and access to information.

Personal data will be limited to what is necessary, in relation to the purposes for which they are processed.

Secondary purposes.
Additionally, Edag may use your personal data for the following purposes that are not necessary, but that allow and facilitate us to provide you with better service:

I. Send you updates about additional products or services that may be of interest to you.
II. Inform you about promotions, offers and other information from Edag and its subsidiaries, other than the information you requested.
III. Carry out satisfaction surveys to find out your perception of the company and the way in which we can improve.
IV. Internal statistical purposes of the company.

3. Legal basis for the processing of personal data

The legal support for the processing of your personal data is found in articles 6, 7 and 8 of the LFPDPPP.

We have a legitimate interest in guaranteeing that the types of sources are displayed consistently, which is legally supported in articles 6, 7 and 8 of the LFPDPPP.

In the case of users residing in the European Union, the legal basis for data processing is found in article 6, section 1, subparagraph a) of the GDPR. The use of the service for purposes of email, blog or posting on social networks, is within our legitimate interest in accordance with the provisions of article 6, section 1, subparagraph f) of the GDPR

3.1 Personal data processed.

To carry out the purposes described, Edag will use the following personal data:

Identification data: name; place and date of birth; nationality.
Contact information: address, email, landline, cell

4. Processor.

HubSpot, Inc. (hereinafter “HubSpot” or “processor”), located at Two Canal Park, Cambridge, MA 02141, USA, is the personal data processor, solely with respect to personal data and of the purposes indicated in this chapter. Any questions regarding the processing of your personal data should be directed to Nicholas Knoop, Data Protection Officer, HubSpot, Inc., Two Canal Park, Cambridge, MA 02141, USA.

The data referred to in this chapter is obtained through the HubSpot service, and is processed solely for the purposes mentioned here. We inform you that we have signed a contract with HubSpot, in which it offers sufficient guarantees to apply appropriate technical and organizational measures, so as to guarantee the protection of your personal data.

The processing of personal data by the person in charge is governed by the terms and conditions of the subscription service that Edag has contracted with HubSpot, and by the privacy policies previously established by HubSpot. These agreements establish the object, duration, nature and purpose of the treatment, the type of personal data and categories of interested parties, and the obligations and rights of the person in charge.

The processing of personal data by the person in charge will be carried out following Edag's instructions, previously established between Edag and HubSpot.

Deputy managers

The person in charge may hire sub-processors to process personal data under the responsibility of Edag, and they may do so in three ways.

1. Hire sub-managers to help with housing and infrastructure.
2. Hire sub-processors to facilitate certain features and integrations.
3. Hire HubSpot affiliates as sub-processors to provide service and support.

Currently, the sub-processors designated by HubSpot are affiliates of HubSpot and the third parties listed in Exhibit 3, which can be found on the following website:

To learn more about subprocessors, you can consult the following page: https://legal.hubspot.com/es/sub-processors-page

Suppliers.

The processor uses third-party providers to collect usage data. If you want more information about how they protect your information with these service providers, see the website: https://legal.hubspot.com/es/privacy-policy

You can prevent the processing of data by HubSpot by making the appropriate settings in your browser to prohibit the storage of cookies. You will find instructions for this at http://www.meine-cookies.org/cookies_verwalten/index.html


XIII. Social networks

1. Social networks in detail

We have profiles on the following social networks:

1. Facebook
2. Instagram

These social networks have their own privacy policies; however, when interacting with our pages and profiles on these networks, Facebook may act as the person in charge of the processing of personal data, so we will continue to be responsible for the personal data processed. For more information, see the website: https://mbasic.facebook.com/privacy/policy/printable/

Likewise, we inform you that the provider of these applications is Meta Platforms Ireland Limited, 4 Grand Canal Square Dublin 2, Ireland.

On the other hand, we inform you that we also have profiles on Linkedin and Twitter. To consult their privacy policies, you can visit the sites: https://es.linkedin.com/legal/privacy-policy and https://twitter.com/es/privacy, respectively


XIV. Data transfer.

We inform you that the personal data obtained may be transferred to the companies EDAG Engineering GmbH and EDAG Beteiligung GmbH, only when strictly necessary to carry out the primary purposes indicated in this notice. The indicated companies are domiciled in the Federal Republic of Germany and belong to the same corporate group as the controller, so they operate under the same internal processes and policies. Due to the above, based on article 37 of the Law, we do not require your consent to transfer your personal data to the indicated companies.

We also inform you that the personal data you provide us may be transferred to the authorities that request it, provided that said request is issued by a competent authority, and is duly founded and motivated.

For its part, HubSpot may transfer the personal data processed to:

A. International transfers within the HubSpot Group.
B. International transfers to external entities

Some of the third-party entities that provide HubSpot services based on a contract that are based in other countries may not have equivalent privacy and data protection laws in the country in which you reside. When they share personal data with outside entities in the European Union, Switzerland, or the United Kingdom, they use various legal mechanisms to protect the transfer, such as standard contractual clauses approved by the European Commission and other additional measures, if applicable. To transfer data to or from the UK, they use the UK annex. To transfer data to Canada, they use standard contractual clauses. With respect to Canada, HubSpot submits to the regulatory authority of the Office of the Commissioner for the protection of privacy of Canada.

Your personal information is not sold to any third party.


XV. Means to exercise the rights of access, rectification, cancellation or opposition to the processing of personal data.

1. You have the right to know what personal data we have about you, what we use them for and the conditions of use that we give them (Access). In case there is such treatment, you can request information about the following:

a) the purposes of the treatment;
b) the categories of personal data processed;
c) Third parties to whom your personal data have been transferred or will be transferred (mainly transferred or not to a third country or to an international organization);
d) The period for which your personal data is to be stored and if precise information is not available, the criteria that allow the storage period to be defined;
e) the existence of the right to request from the controller the rectification or deletion of personal data or the limitation of the processing of personal data relating to the interested party, or to oppose said processing;
f) Existence of the right to file a complaint with the competent authority;
g) when the personal data has not been obtained from the interested party, any information available on its origin;
h) the existence of automated decisions, including profiling, and at least in such cases, significant information on the logic applied, as well as the importance and expected consequences of such processing for the data subject.

2. In addition, you can request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification). You have the right to request the person in charge to correct or complete your personal data, when they have been treated wrongly or incompletely. The person in charge must make the corrections as soon as possible.

3. You have the right to delete it from our records or databases when you consider that it is not being used in accordance with the principles, duties and obligations set forth in the regulations (Cancellation).

The cancellation of personal data will give rise to a blocking period after which the data will be deleted. The person in charge or the person in charge may keep them exclusively for the purposes of the responsibilities arising from the treatment.

You can request the person responsible for the cancellation of your personal data, if any of the following conditions are met:

(1) Your personal data is no longer necessary as the purpose for which it was processed has been fulfilled.
(2) You revoke your consent for the processing of your personal data and there is no other legal cause that motivates its processing.
(3) You have filed an opposition to the processing of your personal data.
(4) If the processing of your personal data is unlawful.
(5) Cancellation of your personal data is necessary to ensure compliance with any legal provision applicable to the data controller.
(6) When the personal data has been obtained from a data transfer.

The cancellation of personal data cannot be made when the treatment is necessary:

a. To exercise the right to freedom of expression and information;
b. For compliance with a legal obligation that requires data processing, or when the cancellation of the processing hinders judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions;
c. For reasons of public interest.
d. They are necessary to comply with an obligation legally acquired by the owner.
e. For archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes.
f. For the formulation, exercise or defense of claims.
g. They are necessary to protect the legally protected interests of the holder;

Upon receipt of the request, Edag will delete the personal data processed from its records, and will notify third parties to whom information has been transferred, so that they proceed to delete the information from their records. In the same way, taking into account the available technology, the person in charge must apply appropriate measures, even of a technical nature, to inform those in charge that you have requested the cancellation of your personal data.

4. You have the right to oppose the use of your personal data for specific purposes (Opposition).

The interested party will have the right to oppose at any time, the processing of their personal data.

The person in charge and the person in charge will cease the processing of your personal data, unless they demonstrate the existence of causes of public order that justify their refusal, the preservation of third-party rights or the existence of any of the causes provided for in article 34 of the Law, which justify the continuation of said treatment.

This right includes the possibility of revoking the consent previously granted for the processing of your personal data.

5. Exercise of your rights.

For the exercise of any of the ARCO rights, or for any doubt, complaint or suggestion regarding the use of your personal data, you may submit the respective request to the Data Protection Department through the email compliance(at)edag.com.mx

The exercise of ARCO rights will be subject to the following procedure:

1. All requests to exercise ARCO rights must contain the following:

a. Name of the owner of the personal data.
b. Copy of the document that proves the identity of the holder, which may be Voter ID, Professional ID, Passport.
c. In the event that the holder carries out the process through a representative, he must show the document that proves the legal representation of the holder, which may be a simple power of attorney granted before two witnesses, which must be accompanied by copies of the holder's identification , of the attorney and of the witnesses. Only the identifications indicated in subparagraph b of this section will be accepted.
d. Address or any means to receive answers about your request.
e. Clear and precise description of the personal data with respect to which one seeks to exercise any of the aforementioned rights.
f. Description of the right to be exercised.
g. Where appropriate, documents or information that facilitate the location of personal data.

2. Additionally, depending on the right you wish to exercise, you must indicate the following:
h. For the right of Access: The way in which you want the information to be delivered, which may be in person at the EDAG facilities, by email or by parcel. In the same way, you must indicate if you want the information to be provided in a simple or certified copy.
i. For the right of Rectification: the modifications that you request to be made to your personal data, for which, you can provide the documents that support the request.
j. Right of Cancellation: the causes for which you request that your personal data be deleted from the files, records or databases of EDAG.
k. Right of opposition: the reasons for which you request that the processing of your personal data end, or, where appropriate, you must indicate the specific purposes for which you wish to exercise this right.

3. If the request does not have the information described above, Edag may request, within a maximum period of 5 days from the day after the request is submitted, the missing information. Once the request is made, the holder will have 10 business days, counted from the day after the request was received, to provide the required information. If you do not meet the requirement, your application will be considered as not submitted.

4. Once the request has been submitted, and as long as it meets the requirements described above, the area responsible for the processing of personal data must inform you whether or not the exercise of the requested right is appropriate, within a period of 20 business days, counted from the following day. upon receipt of the request, or from the time the formulated requirement has been met. This period may be extended up to 10 more business days, when there are justified causes.

5. If the request is favourable, Edag will have a period of 15 days from the day after the response was notified, to carry out the necessary actions to make your right effective.

The exercise of ARCO rights is completely free. Regarding the delivery of personal data, it will be free, and the owner will only have to cover the justified shipping costs, or the costs of reproduction in copies or other formats.


XVI. Options and means to limit the use or disclosure of personal data.

In the event that you have given your consent for the secondary purposes of this Notice, we inform you that you may limit the use and disclosure of your personal information so as not to receive communications or promotions from the person in charge. To do this, please send a request to the email compliance(at)edag.com.mx indicating that you wish to limit the use and disclosure of your information.


XVII. Revocation of consent for the processing of your personal data.
You can revoke the consent you have given to Edag for the processing of your personal data. However, it is important that you consider that not in all cases we will be able to meet your request or terminate the use immediately, since it is possible that due to some legal obligation we need to continue processing your personal data or because it is necessary to satisfy the purpose for which it was managed.

To revoke your consent, you must send your request to the email compliance(at)edag.com.mx, with the requirements indicated in number 1 of the chapter "Means to exercise the rights of access, rectification, cancellation or opposition for the processing of personal data (ARCO Rights).” The deadlines for resolution will be the same as those indicated in numerals 3, 4 and 5 of the same chapter.

If you have any questions or comments, you can contact the Data Protection Department at compliance(at)edag.com.mx, who will process your request and answer any questions you may have regarding the revocation of consent.

 

XVIII. Duration of storage, right of opposition and right of deletion
The personal data collected in terms of this privacy notice will be kept in the EDAG MX databases as long as it is necessary to carry out the purposes for which they were obtained. Once the purposes described here have been achieved, the person in charge will proceed to delete the data that he has kept, prior to blocking them, for their subsequent deletion.

In the same way, we will inform this situation to those third parties to whom we have transferred your information, or to those who act as managers.

 

XIX. Notification of personal data security breaches
In the event of a breach of the security of personal data, EDAG MX will notify the National Institute of Transparency, Access to Information and Data Protection, or the competent control authority, no later than 72 hours after becoming aware of the breach. the rape. In the same way, we will inform you, at least, of the following:

a) the nature of the personal data breach, including, where possible, the categories and approximate number of data subjects affected, and the categories and approximate number of personal data records affected
b) the name and contact details of the data protection officer or other contact point where more information can be obtained
c) the possible consequences of the violation of the security of personal data
d) The measures taken or proposed by the data controller to remedy the breach of personal data security, including, if applicable, measures taken to mitigate potential negative effects

If it is not possible to provide the information simultaneously, and to the extent that it is not possible, the information will be provided gradually without undue delay.

We will document any breach of personal data security, including the facts related to it, its effects and the corrective measures taken. Said documentation will allow the control authority to verify compliance with the provisions of this article.


XX. Changes to this Privacy Notice

This privacy notice may undergo modifications, changes or updates derived from new legal requirements; of the company's own needs; of our privacy practices; Changes in our business model, or other causes.

EDAG MX undertakes to keep you informed about the changes that this privacy notice may undergo, through an informative bulletin that will be shared through the internal digital platform of EDAG MX or through institutional email.

I declare that I have read this Privacy Notice in detail and that I accept its terms and conditions.

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