I. IDENTIFICATION OF FILE CONTROLLER AND PROCESSOR

II. FOR THE PURPOSES OF THE PRESENT NOTICE IT IS UNDERSTOOD:

III. PURPOSE AND/OR USE OF PERSONAL DATA

IV. LIMITATIONS OF USE AND DSCLOSURE OF YOUR PERSONAL DATA

V. REVOCATION OF YOUR CONSENT FOR TREATING PERSONAL DATA

VI. TRANSFERRING YOUR PERSONAL DATA TO THIRD PARTIES

VII. MODIFICATIONS TO THE PRIVACY NOTICE

VIII. RIGHTS OF THE TITLE HOLDER OVER PERSONAL DATA



I.-IDENTIFICATION OF FILE CONTROLLER AND PROCESSOR

PoderCívico A.C., with the commercial name La Ciudad de las Ideas and business address at Paseo de la Reforma #222, Torre 1, Floor 12-A, Col. Juárez, Delegación Cuauhtémoc, Zip. 06600, Mexico City, Mexico, has developed a comprehensive privacy policy to help you understand how we collect, use, transfer and store your Personal Data, in conformity with Article 16 of the Mexican Constitution in terms of the Federal Law of Personal Data Protection in Possession of Private Parties. Thus, we inform you we are Responsible for the treatment, use and protection of your Personal Data in our possession. That faculty has enabled us to name a Data Controller, it being: ARA SOFTWARE DESING, S.A. DE C.V., with business address at Paseo de la Reforma #222, Tower 1, Floor 12-B, Col. Juárez, Delegación Cuauhtémoc, Zip. 06600, Mexico City, Mexico. Thus, it will be in charge of processing your request should you wish to cancel the consent of treating your Personal Data or exercise your ARCO rights, please resort to the aforementioned business address and telephone number 01 (55) 5514-8850 or, if you wish to contact them by e-mail: operaciones@vydp.org.


II.-FOR THE PURPOSES OF THE PRESENT NOTICE IT IS UNDERSTOOD:

• Principles that rule the processing of your personal data: Any information concerning a natural person, identified or identifiable. We collect your personal data directly, when you handle it to us firsthand and through different media, in our premises, by telephone, as when you participate in our promotions or when the data you provide aims at us providing you a better service or any pf our products.

• Current Applicable Laws: Law: Federal Law of Personal Data Protection in Possession of Private Parties. (FLPDPPPP) Regulations: Federal Law of Personal Data Protection in Possession of Private PartiesRegulations. (FLPDPPPPR)

• Principles that rule the processing of your personal data: We collect the aforementioned data in order to fulfill the purposes mentioned in the current Privacy Notice and these will be treated under the rightful principles of lawfulness, quality, consent, information, purposes, loyalty, proportionality and responsibility devoted to The Law.

• Sensitive personal data: Personal data related to the owner’s most intimate information, or that could be misused and thus lead to discrimination or a high risk for the owner. Particularly sensitive data that could disclose ethnic or racial group, current and future health, genetic information; religious, philosophical and moral beliefs; association to unions, political opinions, sexual preference.

• Financial or patrimonial personal data. If you made you payment with a credit card, you will be requested the next personal data, which, according to the Article 8 of the Federal Law of Personal Data Protection in Possession of Private Parties, corresponds to the category of financial or patrimonial personal data: the name of the credit card’s title holder, credit card number, credit card expiration date, and the name of the bank. The Law stipulates that, in case the collected personal data includes sensitive, patrimonial or financial data, the file controller must act in order to meet the express consent of the Title Holder as decreed by Article 8 of the Law and other applicable legislations, whether it is by signing the corresponding format, printed or using electronic media, with straightforward answers and meeting the required processes for the formation of an including agreement, but not limited, through the express consent, and supplied by,the Title Holder of the personal data.

Expressed Consent. Expressed Consent results from the facts and acts that presuppose it. Thus, in the case of lacking your refusal, we will act as you consenting to such terms. As established by the Article 9 of the Federal Law of Personal Data Protection in Possession of Private Parties, we will request your expressed consent for handling sensitive, financial and patrimonial data, indicating if you agree with our handling of it or not. According to the Article 1803 of the Federal Civil Code, expressed consent can be manifested verbally, it can be written, or expressed through unmistakable signs.

Duration of the processes for your personal data. Your personal data will only be processed during the necessary time in order to meet the purposes described in the Privacy Policy made available to you, following the corresponding legal stipulations. In spite of any disposition concerning this Privacy Notice, the Title Holder acknowledges that expressed consent in not needed for processing personal data by the File Controller or third parties in any of the cases appointed in the Article 10 of the FLPDPPPP.

Personal data of underage individuals.
We know the importance of protecting the privacy and personal data of underage individuals. Thus, we don’t collect, use, disclose or store personal data related to underage individuals without their parents’ or tutor’s previous consent.If you are father/mother or tutor and know about an underage individual that has provided personal data without your consent, you can request the cancellation of such data.


III.-PURPOSE AND/OR USE OF PERSONAL DATA

Your personal data will be used depending on how the data has been provided or collected, always following the present Privacy Notice and its updates which, in due time, will be put at your disposition in order to meet the following purposes:

1. If you are our client.
2. If you are our provider.
3. If you work at our organization or are in process of selection.
4. Through video surveillance within our premises.
5. For accessing our installations.
6. On our website.
7. In contracts with third parties.

If the present Privacy Notice is put at the disposition of the Title Holder and the Title Holder manifests no opposition, it will be understood that the Title Holder is authorizing the File Controller to process the Title Holder’s Personal Data provided and/or those provided in the future in order to fulfill the purposes established in the present Notice.

1.-IF YOU ARE OUR CLIENT:

Your personal data will be used for the following purposes:
If you are our client or possible client: to fulfill the obligations derived from a commercial and legal relationship you have or may have, meaning, to provide the services and products you require, to execute/exercise the contract, for statistical purposes, to inform about changes or new products or services relate to a contract acquired by one of our clients; evaluate service quality, determine the quality of our products and services, exchange information needed to attend internal and external audits, as well as auditing by Authorities; for commercial, marketing and/or market research; grant benefits and fulfill our obligations contracted with our clients, as well as conducting internal studies on consumption patterns.

2.-IF YOU ARE OUR PROVIDER:

Your personal data will be used for the following purposes:
Purposes necessary for the commercial and legal relationship with the File Controller, evaluate the performance of the File Controller and, if willing, hire the File Controller in the future as a provider, and lead a follow up of our hired providers and their services for latter record in system administration, transferring your personal data to third parties, following the Privacy Notice.

3.-IF YOU WORK AT OUR ORGANIZATION OR ARE IN PROCESS OF SELLECTION.

Your personal data will be used for the following purposes:
In order to meet the obligations derived from the commercial and legal relationship created with you, as well as personnel administration; creating employee files; creating employees’ medical records; wages and payroll administration; payment of benefits, salaries and services, bonuses, refunds, pensions, insurances and others; hiring of insurances; documentation and control of computing and communication assets and gear; internal audits; creation of business e-mail accounts; company directory development; work tools assignation; assignation of keys and passwords, ensuring the implementation of confidentiality and other work-related obligations; verification of personal and working references; contacting family members, dependents and/or beneficiaries in case of emergency. Furthermore, we inform you that we can use your personal data for other purposes, as long as such purposes are compatible and can be considered akin to the abovementioned purposes.

Ways in which we collect your personal data.
We collect the Title Holder’s personal data through direct and/or personal delivery by means of creating contact between the Title Holder and the File Controller or the Managers. We can also accomplish personal data collection indirectly through public access resources and other available legal sources, such as phonebooks or public databases on the internet, which prove very useful for the aforementioned consented purposes.

The personal data that can be collected and processed are:
(i) Identification data (including the derivatives of their own physical features); (ii) contact data; (iii) patrimonial data); (iv) financial data; (v) academic data; and, (vi) work-related data. The following research can be lead and the deemed necessary actions can be taken in order to prove, by any third party, branch or authority, the veracity of the data provided. Your personal data will be treated according to legal principles, consent, information, quality, purpose, loyalty, proportionality and responsibility in terms subjected to Legislations. We will preserve the confidentiality of your personal data efficiently establishing, and maintaining, administrative, technical and physical security measures in order to avoid damage, loss, alteration, destruction, use, access or improper disclosure of your personal data.

4.-THROUGH VIDEO SURVEILLANCE WITHIN OUR PREMISES.

The footage obtained by our surveillance cameras located within our premises promote your security, and that of all our visitors and collaborators through constant surveillance. For security reasons, images are stored for 28 days and then are permanently erased.

5.-FOR ACCESSING OUR INSTALLATIONS.

To access our premises we request the signing of a logbook, including date, full name, person you are visiting, time of arrival and departure, and signature.

6.- ON OUR WEBSITE

The use of data crawling on our website.

Please note that our website uses cookies, web beacons and other technologies through which it is possible to trace your behavior as an internet user, as well as providing you with a better service and experience when surfing our website. The personal data we collect through these technologies is used for statistical purposes and aims at providing the user with a quicker access to the selected services.

Our website also uses web beacons, which are minute and transparent images inserted in e-mails. When the user opens an e-mail, the image is downloaded alongside the rest of the e-mail content and lets you know if an e-mail has already been opened or nor, as well as its IP address from which it has been downloaded.

The personal data we collect by implementing these data crawling technologies are: identifiers, a session’s user name and passwords, the user’s language preference, region in which the user is located, the user’s type of browser, the user’s operative system, initial and final date and time of a user’s session, visited webpages, searched pages, and publicity the user goes through.

In order to know how these technologies can be disabled on the main browsers, consult the following media:

Google Chrome
Select the icon on the Chrome menu >SelectSettings>On the lower part of the page select Advanced options>On the “Privacy” section, select Content settings >Select Block third-party cookies >Select Done.

Internet Explorer
Click on Tools and then on Internet Options >Click the “Privacy” tab> Settings> block all cookies and then click OK.

Safari
To block cookies in Safari on iOS, go to Preferences > Block cookies and select Always block. On iOS 7 and prior versions, select Never, publicity and third parties or Always.

Firefox
Click on Menu and go to Options > Click the “Privacy” tab > On Firefox you have to: select “Use custom settings for history” > Unmark the option Enable cookies in order to disable them > Close the page. Any change you have made will be automatically saved. For other types of browsers or versions, consult the “Help” tab on your browser.

7.-IN CONTRACT WITH THIRD PARTIES.

In the elaboration of contracts with third parties, as is the case of rental and professional service agreements, among other similar contracts, we are committed to respect and give proper treatment to the personal data resulting from the contract, according to the Federal Law of Personal Data Protection in Possession of Private Parties, keeping at sight the present Privacy Notice, without ever expressing objection about its contents, manifests expressed consent by signing the aforementioned contract.


IV.-LIMITATIONS OF USE AND DISCLOSURE OF YOUR PERSONAL DATA

Should you wish to limit the use or disclosure of your personal data in our possession, the mechanism implemented for the exercise of such rights is presented through the fulfillment of the corresponding request form, sending an e-mail to the following address:

operaciones@vydp.org with the subject: REQUEST FORM FOR LIMITATION OR DOSCLOSURE OF PERSONAL DATA.


V.-REVOCATION OF YOUR CONSENT FOR TREATING PERSONAL DATA You have the right to revoke the consent you have given us to treat and/or process your personal data, whether it is implied, or expressed and written. The implemented mechanism requires the presentation of the corresponding request form by sending an e-mail to the following address:

operaciones@vydp.org, with the subject: REQUEST FORM FOR REVOKING CONSENT OF TREATING AND/OR PROCESSING PERSONAL DATA. The period to tend to your request consists of 20 working days, after which we will inform you about its status through the media you provided for notification.


VI.-TRANSFERRING YOUR PERSONAL DATA TO THIRD PARTIES

We are committed not to transfer your personal data to third parties without your consent,abiding the exceptions stipulated by the Article 37 of the Federal Law of Personal Data Protection in Possession of Private Parties, as well as accomplishing such transference under the terms stipulated by that law.
Excepting the cases of the Article 37 of the Law:
• When the transference is foreseen by a Law or Treaty Mexico is a part of.
• When the transference is necessary for prevention and medical prognosis, sanitary assistance, medical treatment or development of sanitary services.
• When the transference is made onto controlling societies, subsidiaries or branches related to the common power of an individual in charge of a parent company, or any other society of the same group that operates following the same processes and internal policies.
• When the transference is needed in virtue of a celebrated contract, or future contract, in interest on the Title Holder, the person in charge and a third party.
• When the transference is needed or legally requested for the safety of public interest, or for an office or public administration of justice.
• When the transference is needed for the recognition, exercise or defense of rights during legal processes.
• When the transference is needed for the maintenance and compliance of the legal relationship between the data controller and the title holder.
We only transfer your personal data to third parties, nationalor foreign, that are commercially and legally related to us in order to fulfill the purposes described throughout the Privacy Notice and related updates put at your disposition. Thus we are enabled to transfer your personal data in previewed cases authorized by the Law and meet the following:
• At the service of SAT (Servicio de AdministraciónTributaria), in virtue of processes of emission and delivery of Digital Fiscal Invoices through the Internet.
• People who are commerciallyaffiliated and/or related to us.
• Different authorities related to the discharge of requirements or being part of some kind of legislation or regulation.
Your personal data will only be processed during the time necessary to fulfill the purposes described in the Privacy Notice put at your disposition and, when required, establishing the corresponding legal dispositions.


VII.-MODIFICATIONS TO THE PRIVACY NOTICE

We reserve the right to make changes or update the present Privacy Notice, for the attention of our legislative novelties, internal policies or new requirements for providing or offering our services or products.

These modifications will be available to the public through the following media:
• Visible announcements in our premises or in customer service centers.
• Flyers and brochures available at our establishments or customer service centers.
• On our Personal Data Manager’s website (section related to the Privacy Notice).
• We will sent it to the e-mail address you provided.


VIII.- DRIGHTS OF THE TITLE HOLDER OVER PERSONAL DATA

You can access your right to access, rectification, cancellation and opposition (ARCO rights) concerning your personal and/or sensitive data. You can also limit the use and disclosure of your personal data and revoke the consent give for the treatment and/or processing of such data, as long as the treatment is not necessary or comes as the result of a legal relationship.

ARCO RIGHTS CONSIST OF:

ACCESS.- You are informed which features of your personal data are contained within our database, what is it used for, their origin and the communications held with these and, in general, conditions and coverall treatment. Access obligation will be deemed fulfilled when:
The date is put at the Title Holder’s disposition or,
Through the expedition of simple copies, magnetic media, optics, sounds, visuals, holographic, electronic documents or any other technology deemed proper.

RECTIFICATION.- In case your personal date is mistaken or incomplete these must be corrected.

CANCELLATION.- That your personal data should be discharged, totally or partially, of our database. This request could ensue a blocking period after which the data will be suspended.

OPOSITION.- Oppose to the legitimate cause of our company treating your personal data. Should you wish to access the content of your personal data, rectify, cancel or oppose to their use, the implemented mechanism for exercising these rights comes through the presentations of the corresponding request form, sengingan e-mail to the following address:

operaciones@vydp.org with the subject: REQUEST FOR ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION, (as accordingly), and with the following information.
• Name of the Title Holder.
• Title Holder’s address or e-mail address to answer to your request.
• Documents that credit the personality or identity to present the request.
• Description of the personal data on which ARCO rights are about to regulate.
• Any other element enabling the localization of personal data and request attention.

If you think your right to the protection or your personal data has been damaged by one of our employees or our actions or answers, or if it is presupposed that the treatment of your personal data is being violated, in terms of the Federal Law of Personal Data Protection in Possession of Private Parties,you will be able to file a complaint or the corresponding report before INAI, for more information, visit: www.inai.org.mx

The treatment of your personal data under our possession will be accomplished under the present terms and conditions. Thus, from then on, it is expressly understood that you are authorizing the Data Controller and the Managers, to treating your personal data in order to meet aforementioned purposes, as long as you don’t express your opposition through some of the features appointed by the law. For anything related to your personal data that hasn’t been addressed by this Privacy Notice, please contact the Data Controller, its data can be found at the beginning of this file.

Updated: July 29th, 2015.