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Privacy Notice

THOR URBANA CAPITAL, located at Paseo de la Reforma 2620, 16th floor, Colonia Lomas Altas, C.P. 11950, Mexico City (hereinafter “TUC”), recognizes the importance of the legitimate, controlled and informed handling of personal data, for which, in compliance with the Federal Law for the Protection of Personal Data in Possession of Individuals published in the Federal Official Gazette on July 5th 2010, its regulation published in the Federal Official Gazette on December 21st2011 and the General Guidelines for Privacy Notice published in the Federal Official Gazette on January 17th 2013(hereinafter the “Law”), TUC presents the following Privacy Policy for your information.

  • I. Personal data that shall be handled.
  • Some or all of the following personal data shall be handled by TUC, as it is necessary in order to originate the existence, maintenance and compliance of your legal relationship with TUC.

 

    1. Identification data: name, address, date of birth, Unique Population Registry Number (CURP), tax identification card number, telephone number, landline or mobile, facsimile, e-mail and/or other similar information, as well as the name of your relatives and their contact information.
    2. Academic data: educational background, title, professional identification card number, specialties, certificates, affiliation to any association, college or professional bar, and/or other similar information.
    3. Professional data: position, seniority, professional record and background, address, e-mail, telephone number, landline or mobile, and facsimile and/or other similar information.
    4. Financial data: bank account information, financial statements, payment method and/or other similar information.
    5. Invoice data: tax domicile, tax identification number and the data of the person to be invoiced.

Considering the nature of the relationship between you and TUC, some of the data mentioned above might involve, under certain circumstances, financial or economic personal data, which will be handled according to the provisions of this Privacy Policy.

  • II. Sensitive Personal Data.
  • For your information, TUC will only handle the sensitive personal data which is necessary for the existence, maintenance and compliance of the legal relationship between you and TUC. Such sensitive personal data might include: injuries or accidents, affiliation to a labor union or to labor organizations and participation in legal trials or judicial problems.
  • III. Purposes for handling personal data.
  • The personal data delivered to TUC by you shall be handled, in each individual case, for the existence, maintenance and compliance of the legal relationship between you and TUC. TUC will handle your personal data in order to:

 

    1. Contact you;
    2. Create your profile in its client database and keep it up to date;
    3. Comply with the objective of the relationship that originated the handling of such personal data;
    4. Answer the questions and comments that you deliver to us in any way;
    5. Send you information that might be of interest to you;
    6. In general, follow up on any service requested from us by you.

TUC will not use your data for marketing, advertising or commercial purposes.

  • IV. Transfer of personal data.

TUC will transfer your personal data within national territory or abroad with the purpose of originating the existence, maintenance and compliance of the legal relationship between you and TUC (the “Receivers”). TUC will transfer all or part of such information to the Receivers through e-mail and/or similar information transmission methods.

Receivers may be one of two types: (i) companies with which TUC has a contractual and/or commercial or professional relationship for the provision of legal services; and (ii) third parties other than TUC, when such transfer is made precisely for the maintenance of or compliance with the legal relationship between you and TUC, including without limitation, the transfer of data to legal, tax, financial or labor advisors, etc.

In both cases, TUC will inform the Receiver of the personal data protection measures implemented by TUC. Nevertheless, TUC will not be responsible for the handling of personal data by third parties, as the actions of third parties are beyond the scope of TUC. Likewise, it should be noted that TUC, in its judgement, may request that third parties provide data, regarding their legal and personal background, for which TUC will verify that such transfers have a privacy policy that protects your personal data.

In any of the abovementioned cases, TUC shall not require your consent to perform the personal data transfer, pursuant to the provisions of Article 37 of the Law. Nevertheless, given the case that you disagree with such transfer, please send an e-mail to info@thorurbana.com in order to prevent the transfer of your personal data. Any other kind of data transfer may only be performed if: (i) it is provided by the Law, (ii) it is a result of a request from a competent authority, or (iii) the expressed consent of the data holder is obtained.

  • V. Security measures.

TUC has adopted the security, administrative, technical and physical measures necessary to protect your personal data against damage, loss, alteration, destruction or use, access or non-authorized handling. Nevertheless, due to the existence of communications via internet that we cannot monitor, we cannot guarantee at all times that your personal data delivered to us via internet, will be free from use, access or non-authorized handling.

The security measures taken by TUC will be reviewed and examined in light of technical and legal developments and will not be less than those that TUC carries out in order to protect its own data.

If it comes to our knowledge a breach in security has occurred during any phase of our handling of your personal data, which might significantly affect your moral or economic rights, the director of TUC’s personal data department shall immediately inform you via e-mail of such security breach, in order for you to take the necessary measures for the defense of your rights.

In any case, the access to your personal data possessed by TUC, will be limited to the persons that need access to such information, in order to fulfill the purposes of this Privacy Policy.

  • VI. Rights of the personal data holder.

As a personal data holder, you may contact TUC’s Personal Data Department to exercise your access, rectification, cancellation and/or opposition rights (“ARCO Rights”) provided in the Law. Likewise, you might revoke, at any time, the consent you granted and that was necessary for the treatment of your personal data, as well as limit the use and disclosure of such. If, after such revocation, you request confirmation, TUC shall expressly respond.

The exercise of the ARCO Rights shall be carried out through a written request addressed to the director of TUC´s Personal Data Department, and sent to the e-mail address info@thorurbana.com or sent to our offices located at Paseo de la Reforma 2620, 16th floor, Colonia Lomas Altas, C.P. 11950, Mexico City, within a time of 9:00 to 19:00 hours from Monday to Friday, expressing with detail your request (“ARCO Request”). The ARCO Request must be accompanied by a copy of your official valid I.D. and will indicate your preferred method of receipt. The director of TUC´s Personal Data Department shall reply to your ARCO Request through the chosen means in a term no longer than 20 (twenty) business days counted from the day on which the ARCO Request was received (or from the term that, given the case, is established in the Law for such effects, whichever is the longest). The procedure will be sustained pursuant to what is provided in the Law.

For such effects, TUC will make available to you a series of suggested formats to perform the requests for access, rectification, cancellation and/or opposition, which will be directly available in TUC’s Personal Data Department at our offices.

In terms of the Law and its Regulations, TUC informs you that, in the case of disregard to or non-compliance with your ARCO Rights, you may present given ARCO Request before the National Institute for Transparency, Information Access and Personal Data Protection, (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales), in the terms and times provided by the Law and its Regulations.

  • VII. Amendments to the Privacy Policy.

You will be informed of any amendment to this Privacy Policy at least 30 (thirty) days prior to the date on which such amendment takes place, through the publication of a notice at www.thorurbana.com