In accordance with the provisions established in the Federal Law on the Protection of Personal Data held by Private Individuals (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the “Law”), and in compliance with the duty to protect its clients’, affiliates’ and/or beneficiaries’ personal data, we hereby inform you the following:

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1. Personal Data Content

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In accordance with the Law, “Personal Data” refers to any information pertaining to an individual, identified or identifiable.  For purposes of this Privacy Notice, “Personal Data” shall be considered as, without limitation:

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     1.1. General Data

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For individuals: Name(s) and last names, date of birth, gender, marital status, existence or not of children, address, telephone number (house or office), cell phone, e-mail, Federal Taxpayer’s ID Number, Unique Population Registry Key (CURP), spouses data, work data, bank references, personal references, among other similar data regarding an individual and its financial and credit status.

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For businesses: Business name, length of service, Federal Taxpayer ID Numbers, business address, telephone, business e-mail, industry to which it belongs to, country of incorporation, legal representative, as well as its Personal Data, company’s organization data, among other similar data pertaining to a business and its credit and financial status.

 

     1.2. Data regarding job applications

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When you enter or provide Personal Data in the job pool, in addition to general data, information about level of education, work experience and any information regarding the curriculum vitae that you send is considered Personal Data.

 

     1.3. Social Networks

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Social networks (such as Facebook® and Twitter®, among others) are communication and interconnection platforms between digital platforms among various users; these are foreign to TWO and therefore are not under its responsibility.

 

The information that you provide in social networks where TWO participates as a user, is not and is not considered Personal Data protected under this Privacy Notice and shall be provided under responsibility of the corporation that provides that platform and of the individual or company that discloses it.

 

The Personal Data mentioned in section 1.1. of this Privacy notice shall be collected by filling formats and/or by gathering the information or documents required by TWO, either personally or electronically  in any of its Internet pages, existing or future (TWO’s web pages), among them www.http://thewildoscar.mx/

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2. Individual responsible for collecting Personal Data

 

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​The individual responsible for collecting your Personal Data (in this act, as well as in past and/or future acts) is TWO.

 

For purposes of the provisions established in fraction I of article 16 of the Law, TWO’s address is located at Lamartine 516, Colonia Polanco, Ciudad de México C.P. 11517

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3. Processing Personal Data

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In accordance with the provisions established in the Law, obtaining, using, disclosing or storing personal data is considered as processing personal data (“Processing Personal Data”), through any means. Usage covers any action regarding handling, use, transfer or disposal of Personal Data. Processing of Personal Data by TWO will be limited to compliance of Processing Purposes provided for in this Privacy Notice and shall be subject to the following:

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a) In the event that your Personal Data is processed for purposes other than those established in this Privacy Notice, TWO will be required to obtain your consent for such purpose, again.

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b) It shall be as necessary, adequate, and relevant for the purposes described in this Privacy notice.

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4. Purposes of Personal Data Processing

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By means of this Privacy Notice, TWO states that the purposes of processing your Personal Data shall be the following (“Processing Purposes”):

 

a) Commercial purposes, to provide commercial information, such as information regarding products and services, promotions, electronic magazine, changes to our products and services, new products and services, requesting the evaluation of product and service quality, carrying out internal studies regarding consumption habits, loyalty and advertising campaigns, courses and congresses, and any other promotion or issue associated with products and/or services.

 

​b) Marketing or advertising purposes.

 

c) Marketing activities.

 

d) Registering your data in TWO’s client systems.

 

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5. Acceptance of Personal Data Processing

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In order for TWO to process Personal Data, our clients, users and/or personal data titleholders must grant express or tacit acceptance of such processing which shall be done by any of the following media:

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     5.1. Acceptance Through Electronic Media

 

a) Publication In Web Pages.

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In addition to providing the Privacy Notice by e-mail, TWO will publish this Privacy Notice in its web, in order for you to grant or deny your consent once you are aware of its content to be able to process personal data.

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This shall also be done, in case TWO does not have your e-mail or when your Personal Data are not correct or are not being used and we are not able to find you.

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     5.2. Personal Acceptance

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When Personal Data is obtained personally from the titleholder, TWO shall provide this Privacy Notice at the time that your Personal Data is collected in a clear and credible manner. Also it shall obtain the acceptance or denial of consent from the titleholder to submit such data to the Processing Purposes established in this Privacy notice.

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     5.3. Tacit acceptance

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Based on the provisions established in article 35 of the Law, the content of this Privacy notice, as well as any modification or addition hereto, shall be made known to you through any of the media established in sections 5.1. and 5.2. above, and in the event that you do not reject its content and scope within 2 months from the date when TWO informs you of the Privacy Notice or its modifications, it shall be understood that you granted tacit consent in order for TWO to process your Personal Data based on the Processing Purposes established in the Privacy Notice.

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     5.4. Retroactive Acceptance

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All our clients or users that previous to the notification or publication of this Privacy Notice provided us their Personal Data, through any means or media, shall receive the Privacy Notice as per the provisions established in sections 5.1. and 5.2. above, in order for them to grant or deny their consent (express or tacit) to allow TWO or not to process their Personal Data based on the Processing Purposes established in the Privacy Notice.

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6. Personal Data Usage Or Disclosure Limitation

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     6.1. Actions To Prevent Unauthorized Use Or Disclosure 

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To guaranty protection of your Personal Data and to limit the unauthorized use or disclosure thereof, TWO continuously performs and will perform the following actions:

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a) Information Confidentiality. TWO shall maintain confidentiality regarding the Personal Data obtained which shall continue even after finalizing its commercial relations or relations of another nature with the client or titleholder of such Personal Data.

 

​b) Confidentiality Notification. In the event, that for any reason TWO is obligated to provide your personal data to third parties (under the terms provided by the Law or in this Privacy Notice), it shall notify such third parties of the duty to comply with the provisions of the Law and the confidentiality of your Personal Data.

 

c) Database Management. Personal Data is managed and safeguarded by means of databases (“Database”), which are managed only by individuals designated by TWO for such purpose and the use, consultation or access by unauthorized individuals is not allowed.

 

​d) Computer And Computerized Systems. Our databases are protected by firewalls and computer and/or computerized systems focused on preventing and avoiding access by unauthorized individuals or foreign to TWO to your Personal Data.

 

     6.2. Requests To Limit The Use Or Disclosure

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In the event that you wish to limit the use or disclosure of your Personal Data, regarding one or several Processing Purposes of Personal Data (such as, i.e. advertising mails, employment offers, among others), you may send the respective request as per the procedure established in paragraph 7 of this Privacy Notice.

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7. Access Rights, Rectification, Cancellation Or Objection

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In accordance with the provisions established in the Law, you have the right to access, rectify cancel or object to personal data processing and the following procedure is provided for this purpose:

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     7.1. Personal Data Department

A department has been designed to safeguard Personal Data (“Personal Data Department”), which shall transact your requests and shall promote personal data protection within TWO.

 

For this purpose, the Personal Data Department provides the following means of contact and information and related document receipt:

 

– E-mail: wildoscar@thewildoscar.com

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To: Personal Data Department.

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     7.2. Access, Rectification, Cancellation Or Objection Request

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As titleholder of your Personal Data, you may submit or send the Personal Data Department a request for access, cancellation or denial regarding your Personal Data.

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Such request must contain the following at least:

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– Full name and address of personal data titleholder, or another means to respond to the request.

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– Documents that credit the identity or legal representation of personal data titleholder.

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– Clear and precise description of personal data for which exercising any of the previous rights is sought.

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– Any other element or document that facilitates locating the Personal Data.

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– Indicate the modifications and/or limitations to be made on the use of Personal Data, according to the provisions established in section 6.2., of this Privacy notice.

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– Provide documents supporting your request.

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     7.3. Resolution and communication

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TWO shall inform the personal data titleholder of the resolution adopted within a term not exceeding 20 business days from the date when the request is received. This term may be extended by TWO on a single occasion for an equal term, as long as the circumstances of the case justify it.

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Based on the previous and in accordance with the provisions established the Law, TWO shall inform the personal data titleholder of the sense and motivation of the resolution through the same media used to make the request and shall include any pertinent proof to such resolution, as the case may be.

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Whenever the request is valid, it shall become effective for TWO within 15 business days after informing of the resolution adopted.

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The titleholder may submit a data protection request to the Federal Institute of Access to Information (IFAI) based on the response or lack of response received.  Said request must be submitted by the titleholder within 15 business days from the date when the response is communicated to the titleholder by TWO, and shall be subject to the provisions established in the Law.

In the case of personal data access requests, it shall be necessary for the applicant or its legal representative to prove their identity beforehand.

The duty to access information shall be deemed completed once TWO provides the titleholder its personal data or by means of issuance of copies or electronic documents thereof.

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In the event that an individual requests TWO access to its Personal Data assuming that it is responsible and it is not, it shall suffice for TWO to indicate such condition to the titleholder through any means (among those established in this section) to consider said requested as completed.

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The response to your Personal Data access, rectification or objection request shall be free of charge. You must only cover justifiable delivery costs or copy or other format reproduction expenses, which shall be made known by TWO as the case may be.

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In the event that the same individual reiterates the personal data access, rectification, cancellation, or objection request within a period under 12 months from the date of the last request, the reply may have an additional cost indicated by TWO, in accordance with the provisions established in article 35 of the Law.

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     7.4. Denial To Access Personal Data

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TWO may deny total or partial access to Personal Data or to rectification, cancellation or processing thereof in the following cases:

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– When the petitioner is not the titleholder or the legal representative is not licensed thereto.

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– When TWO’s database does not contain the petitioner’s Personal Data.

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– When the rights of a third party are damaged.

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– Whenever there is a legal impediment or a resolution from an authority.

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– When the rectification, cancellation or rejection has been previously performed, in such a manner that the request lacks substance.

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     7.5. Cancellation Consequences

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The cancellation of Personal Data shall result in a blocking period after which TWO shall suppress the corresponding data.  Once the corresponding personal data are cancelled, TWO shall inform the titleholder.

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Once the previous is done, TWO may preserve the Personal Data exclusively for purposes of the liability derived from processing referred to in the Privacy Notice.

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When Personal Data is transferred to third parties before the rectification or cancellation and is processed by said third parties, TWO shall inform them of the request submitted by the titleholder in order for them to make such rectifications or cancellations.

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TWO will not be obligated to cancel your Personal Data in cases other than those established in article 26 of the Law. Also, when the information collected in the Personal Data ceases to be necessary for compliance of the purposes established in this Privacy Notice and in the applicable judicial provision, your Personal Data will be cancelled from TWO’s databases.

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8. Changes To The Privacy Notice

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TWO reserves the right to make, at any time, modifications or updates to this Privacy Notice, to address legislative, judicial, internal politic updates, new requirements to render or offer its products and services, or for commercial practices.

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Therefore, in the event that TWO modifies the content of this Privacy Notice, it shall inform you through any of the manners and media established in section 5. hereof.

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9. Personal Data Transfer

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In the event that TWO transfers your Personal Data to any of its providers for Processing Purposes as established in this Privacy Notice, it shall do so upon previous execution of confidentiality agreements, as long as (i) the provider or individual to whom it is transmitted agrees to subject processing of personal data to this Privacy Notice and does not constitute any of the assumptions established in article 37 of the Law.

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If you do not state an objection regarding the transfer of your personal data to third parties, it shall be considered that you have granted TWO your consent for this purpose.

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Final considerations – Informative nature of this document

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The content of this Privacy notice is merely of an informative nature, therefore in the event that you wish to reject its content, we invite you to enter the personal data collection sections established in the web pages where you can send the corresponding request to the Personal Data Department.

 

wildoscar@thewildoscar.com