Ingeniosi's Privacy Notice

January 2020

INGENIOSI S.A.P.I. DE C.V. ("THE COMPANY"), with domicile at Océano Pacífico 1738 2º Piso C, Colonia Prados del Tepeyac, Ciudad Obregón, Sonora, C.P. 85150, is aware of the importance of the legitimate, controlled and informed treatment of the personal data of its candidates to be hired. Therefore, THE COMPANY hereby makes available this Privacy Notice, so that you may know how THE COMPANY obtains, uses, discloses and stores your personal data.

Personal Data Collected - Personal data that may be collected during the employment relationship with you will fall into the following categories: (i) Identification Data: full name; gender; date of birth; marital status; country, citizenship and nationality; work visas and/or permits to work in Mexico or abroad; Federal Taxpayers Registry (RFC) key; Unique Population Registry (CURP) key; Mexican Social Security Institute (IMSS) affiliation number; images; photographs, photo IDs; signature; (ii) Contact Data: address; telephone numbers; cellular numbers; e-mail; (iii) Work and academic data: curriculum vitae; occupation; work references -; personal references; information related to previous jobs; documents that accredit academic preparation and degree of studies; results of studies verifying the information that you provide to THE COMPANY; work performance; (iv) Third party data: data of economic dependents and beneficiaries such as name; date of birth; relationship; contact details; identification and contact details of persons designated in case of emergency; (v) Tax and social security data: tax returns and tax withholdings, credit number with FONACOT (if applicable); (vi) Personal data from publicly accessible sources and received via consented transfer Data from public records, directories, social networks and other lawful sources available in the market; (vii) Personal data from social networks: personal data and information that you have shared publicly on social networks (such as Facebook, Twitter, LinkedIn, among others), including information that you have shared in any other way in a public capacity

In addition, periodic examinations and background checks may be conducted to collect Sensitive Data (which should be understood to fall within the term "personal data") that require special protection such as results of psychometric assessments and tests; results of medical examinations, including audiometric, blood tests, X-rays, and vision tests; medical, family, criminal, and employment history; health data; information about whether you are a smoker and information about union membership or affiliation; and financial or property data: such as salaries, employment benefits and expenses, contributions to the savings fund, worker-employer contributions; bank accounts, beneficiaries, results of socio-economic studies; other payments you receive as a result of your work; data on INFONAVIT credits; FONACOT credits.

Additionally, THE COMPANY may ask you to show original documentation and to provide a copy of it as evidence to support the information you have provided.

Purposes and/or uses of personal data - The personal data collected by THE COMPANY may be used for the following necessary purposes: (i) for the fulfillment of any legal obligation related to the information provided (ii) to conform and determine the labor divisions we have; (iii) to determine job positions; (iv) talent management and personnel administration; (v) elaboration and maintenance of the directory of THE COMPANY; (vi) listings for e-mail and sending communications; (vii) to be exhibited in case of national and international trial or in any administrative or any other kind of proceeding before a competent authority, either national or international, and in general to comply with legal obligations and to defend the interests and rights of THE COMPANY, its affiliates, subsidiaries and any natural or legal person with whom THE COMPANY has, has had or may have a business relationship; (viii) to protect the property and rights of THE COMPANY and related companies, as well as the confidentiality of their information; (ix) (x) to contact designated persons in case of emergency; (xi) to carry out opinion surveys of candidates; (xii) to carry out relocations; (xiii) for international mobility; (xiv) to evaluate its experience, knowledge, health status, physical condition, skills and abilities and to identify profiles with which it is compatible; schedule interviews with the Company; (xv) perform a reference check; to survey positions in the labor market and determine the optimal position for it; (xvi) for the preparation of all types of reports; (xvii) to perform internal investigations, to conform and determine the labor divisions with which we have; (xviii) to determine job positions; talent management, databases.

In addition, personal data may be used for unnecessary or secondary purposes such as (i) communications (including e-mail) regarding THE COMPANY; (ii) developing and maintaining a database for future employment opportunities with THE COMPANY; and (iii) providing employment references from you to prospective employers.

To limit or deny the use of these unnecessary purposes, you may submit your request in writing to our Privacy Officer at the offices of the Company, at Océano Pacífico 1738 2º Piso C, Colonia Prados del Tepeyac, Ciudad Obregón, Sonora, C.P. 85150, or via email at contacto@ingeniosi,mx and your request will be placed on the Opt-Out List.

Transfer of your personal data - THE COMPANY may transfer to third parties, national or foreign, your personal data and/or sensitive personal and/or financial data in order to comply with the purposes described; likewise, in the event of a corporate restructuring including merger, consolidation, sale or total or partial transfer of our business or assets, it may be necessary to transfer the personal data nationally or internationally. The third parties to whom THE COMPANY may transfer your personal data are, for example: other affiliated companies or subsidiaries acting under the same policies and procedures as THE COMPANY, external professional advisors acting on behalf of THE COMPANY, service providers who are hired to fulfill the purposes described and who act on behalf of THE COMPANY, potential buyers of THE COMPANY's business or assets. In addition, THE COMPANY may transfer its personal data when necessary for the pursuit of justice and recognition of a right in a judicial proceeding, as well as to Mexican or foreign authorities that require it from the COMPANY or, to be exhibited as evidence in court in Mexico or in any country abroad.

THE COMPANY undertakes to transfer only that information which is absolutely and strictly necessary. When THE COMPANY shares your personal data with third parties it will do its best to ensure that such third parties take the necessary measures to protect the confidentiality and security of your personal data. THE COMPANY will require such third parties to comply with applicable data protection laws, policies and THE COMPANY's Privacy Notice and will prohibit them from using your personal data for any purpose other than the one for which they have been hired.

THE COMPANY shall ensure that such information is safeguarded in accordance with the principles of personal data protection recognized by the Federal Law on the Protection of Personal Data in the Possession of Individuals and its Regulations (the "Law") and that, where appropriate, the recipient of the data assumes the same obligations as THE COMPANY.

THE COMPANY never sells your personal data, nor gives or transfers your personal data to third parties outside THE COMPANY, without your prior consent, except in the cases mentioned above. However, THE COMPANY may transfer your personal data when such transfer is provided by law.

Safeguarding your personal data - THE COMPANY has adopted the security measures, administrative, technical and physical, that it considers necessary to protect your personal data.

Access to your personal data, held by THE COMPANY, will be limited to those persons who need to have access to such information, in order to carry out the purposes identified in this Privacy Notice.

Protection of minors, persons in a state of interdiction or incapacity - THE COMPANY does not collect or process personal data from minors, persons in a state of interdiction or incapacity, unless it has been provided by a parent, guardian or legal representative, as appropriate. In the event that THE COMPANY considers that personal data has been provided by a minor, an incompetent person or a person in a state of interdiction, in contravention of this Notice, we will proceed to remove such personal data as soon as possible. If you are aware that such personal data has been provided by a minor under the age of 18, or by a person incapable or in a state of interdiction, please send an email to: contacto@ingeniosi,mx

Rights corresponding to the owner of the personal data - You, as owner of personal data may exercise before the Privacy Officer, who is responsible for the Protection of Personal Data of THE COMPANY, as set forth below, the rights of access, rectification, cancellation and opposition ("ARCO" rights), established by Law. Likewise, you may revoke, at any time, the consent you have given and which is necessary for the processing of your personal data. To revoke your consent for the processing of your personal data, you must submit your request to the email contacto@ingeniosi,mx

To exercise your ARCO Rights, you or your legal representative must send your request for ARCO Rights to the COMPANY to the attention of the Legal Department for attention and follow-up.

Options to limit the use or disclosure of your personal information. You may limit the use or disclosure of your personal information to prevent it from being used or disclosed.

If you wish to limit the use or disclosure of your personal data, you must submit your request to the email contacto@ingeniosi,mx ,with the understanding that THE COMPANY could not comply with some of its obligations if this happens.

Use of Cookies and Other Tracking Technologies THE COMPANY does not directly use cookies or other tracking technologies to collect your personal data when you access the internal network service, internal portal and/or website.

Changes to the Privacy Notice - If there are any changes or modifications to this Privacy Notice, the updated version will be made available to you through our Privacy Officer at the offices of THE COMPANY, at Océano Pacífico 1738 2º Piso C, Colonia Prados del Tepeyac, Ciudad Obregón, Sonora, C.P. 85150 or at the email contacto@ingeniosi,mx .

Contact - If you have any questions or comments regarding this Privacy Notice or if you would like to exercise any of your rights under the Law, please contact the Human Resources Department at the following email address: contacto@ingeniosi,mx or at the addresses located at: Océano Pacífico 1738 2º Piso C, Colonia Prados del Tepeyac, Ciudad Obregón, Sonora, C.P. 85150.

I acknowledge that I have read and understand this Privacy Notice.

In terms of the Federal Law on the Protection of Personal Data in Possession of Individuals and its Regulations, we inform you that, in the event of a refusal to respond to requests for ARCO rights or non-compliance with the same, you may submit to the National Institute of Transparency, Access to Information and Protection of Personal Data, the corresponding Request for Protection of Rights within the terms and conditions set forth in Chapter VII of the Law and other related ones, as well as the corresponding ones in the Regulations.

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