PRIVACY POLICIES

Capital Digital’s commitment to your privacy

At Capital Digital, S.A.P.I. de C.V., (hereinafter “Capital Digital”) we respect your right to privacy and the protection of your personal data. Your data is not sold or rented to third parties by us. We exclusively transfer or share your personal data to third parties under the terms set forth in this Privacy Notice. Such communications are made only and exclusively if you have consented to it, except in those cases in which your consent is not required, in terms of the applicable legislation. 
Equally important to us is that you have the ability to make informed decisions about our use of your personal data. This Privacy Notice sets out Capital Digital’s privacy policies and practices with respect to the processing of your personal data (i.e., the collection, use, disclosure and storage of such data) and the steps we take to protect your data. This Notice is addressed to:

●Our customers, users or followers when they use our website, located at capitaldigital.com (the “Website”).

●Our customers, users or followers

1. What is personal data? By personal data we mean any information relating to a natural person that identifies him or her or can be associated with an identifiable person.
2. What personal data does Capital Digital obtain? In order to fulfill the purposes set forth in this Privacy Notice, we may obtain the personal data mentioned below:
A. Identification data: information that differentiates you from other people. Among these data are: name, position, autograph signature, electronic signature, federal taxpayer registry (RFC); copy of the document that proves your identity (Credential to Vote with Photo or other type of document);
B. Contact information: information that allows us to maintain contact with you. These data include your address, fiscal address, address for delivery purposes, e-mail, home telephone or other contact telephone.


Identity and address of the person in charge


CAPITAL DIGITAL S.A.P.I. DE C.V.
(hereinafter “CAPITAL DIGITAL”) with address at Juan de la barrera #112, Colonia Condesa, Alcaldía Cuauhtémoc, C.P. 06140, Mexico City, is responsible for the processing of your personal data.


Personal data collected by CAPITAL DIGITAL, which are not sensitive personal data


To provide our Services (as such term is defined below), and to comply with the purposes of the treatment indicated in this privacy notice, it is necessary and/or required by the applicable regulations that CAPITAL DIGITAL uses:

1. Your personal identification data, contact, references, professional, financial and/or patrimonial information.
2. The identification and contact data of the persons you have designated as references. When providing this data you acknowledge having the consent of such persons for the treatment of their data for contact and/or collection purposes and/or to carry out investigations and periodic monitoring of your credit history.

Primary purposes

CAPITAL DIGITAL will computer process the personal data described above to carry out all or any activities necessary for the development and fulfillment of the obligations arising and deriving from the contractual and/or commercial relationship for the provision of the Services delivery of products and/or for the management of the Services; the registration and/or deregistration and/or change and/or portability of Services, equipment, plans; registration and management of services and/or applications, the provision of Services by third parties, including but not limited to services related to any type of bonds, insurance and/or warranty extension, as well as contacting you and your contacts and/or references for the follow-up of any matter related to the Services or to the present purposes.
 
Secondary purposes
 
CAPITAL DIGITAL will treat your personal data to carry out any or all secondary purposes such as:

●Informing you of the launch or changes of new products, goods, services, promotions and/or offers according to your interests, as well as other brands and/or affiliated companies and/or subsidiaries of CAPITAL DIGITAL, including sending communications through emails.

Transfer of personal data
 
By accepting this Privacy Notice you acknowledge that your personal data may be transferred to third parties solely for the purpose of fulfilling the service obligations assumed between you and Capital Digital and will be treated at all times in accordance with the provisions of our Privacy Notice in accordance with Article 36 of the LFPDPPP. For the above, the User may receive information in your email directly from CAPITAL DIGITAL associates.
 
Modifications to the privacy notice
 
CAPITAL DIGITAL reserves the right to modify this Privacy Notice at any time. In any event, we will inform you of the fact that changes have been made to the Notice by indicating at the end of the Notice the date on which it was last updated. The updated Notice will appear on our website. https://www.capitaldigital.com/ We encourage you to review our Privacy Notice to ensure that you understand how your personal information will be used.

Should you have any questions regarding data privacy that are the responsibility of Capital’s Personal Data Department, please send an email to [email protected] and we will be happy to respond.
 
Exercise of ARCO Rights
 
Additionally, in accordance with the LFPDPPP, you have the rights of Access, Rectification, Cancellation and Opposition to the Processing (the “ARCO Rights”); likewise, you have the right to revoke at any time the consent granted for the processing of your personal data to the extent permitted by law. Please contact our Personal Data Department (“DDP”) at [email protected] to exercise your ARCO Rights or your right of revocation or to formulate any doubt or complaint regarding the processing of your personal data. Your requests will be evaluated under the terms established in the LFPDPPP and other applicable obligations.
 
To do so, you must send to our DDP

●Full name and valid official identification or document proving the representation of the owner of the data, if applicable;

●Clear and precise description of the personal data with respect to which you wish to exercise your ARCO Rights;

●Means of contact (address, telephone or email),

●And place or email where you wish to receive the data.

Our response will be received within 20 days from the date we receive your request, and will be effective within 15 days from the date we communicate our response to you. In the case of requests for access to personal data, we will deliver the requested information, upon proof of identity of the applicant or legal representative, normally by electronic means, with physical access for 15 days, if possible, or by means of simple copies of our documents.
 

CAPITAL DIGITAL
 
January 2021