Ingeniosi Privacy Notice

January 2020

INGENIOSI S.A.P.I de C.V., located at Vasco de Quiroga 3900 Torre A Piso 10 Int 10-B, Colonia Santa Fe de Cuajimalpa, Ciudad de México, C.P. 05348 Cuajimalpa de Morelos (hereinafter referred to as the ‘COMPANY’), recognizes the significance of the legitimate and informed management of personal data provided by its job applicants. This Privacy Notice is provided to you so you can know how your personal information is obtained, used, disclosed, and stored by the COMPANY.

Personal data collected – The personal information that may be gathered in the course of our employment relationship with you will include: (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 Taxpayer Registry Code (R.F.C.); Unique Population Registry Code (CURP); affiliation number to the Mexican Social Security Institute (IMSS); images; photographs, photo I.D.s, and signature; (ii) Contact Data: address, telephone numbers, cellular numbers, and email address(es); (iii) Employment and academic data: resume/curriculum vitae, occupation/job title(s), references related to employment history and personal references, documents showing academic qualifications/education level(s), results from verification studies conducted by the COMPANY regarding the information you have provided as well as your job performance; (iv) Third Party Data: details of individuals who are economically dependent or entitled to benefits such as name, date of birth, relationship, contact information and identification of persons to contact in an emergency; (v) Fiscal and social security data: records of taxation and tax deductions, credit number with FONACOT (if applicable); (vi) Personal data collected from public sources with consent: Details obtained from public registries, directories, social networks and other lawful sources available on the market; (vii) Social media personal data: Information that has been made publicly available on social networks (e.g., Facebook, Twitter, LinkedIn, etc.) or shared in any way that is open to the public.

Examinations and background checks may be periodically conducted to collect Sensitive Data (including ‘personal data’), which requires special protection, such as psychometric evaluations, medical examinations (including audiometric exams, blood tests, x-rays, and vision tests), family/criminal/labor records, health data (e.g., whether an individual is a smoker), union membership info, financial information (salary/benefits/expenses), savings fund contributions, bank account details, socioeconomic study results, other work-related payments, and INFONAVIT/FONACOT credits.

The COMPANY may also ask you to present original documents and provide copies of them as proof of the information you have given.

Purposes and/or uses of personal data – The personal data gathered by the COMPANY may be utilized for the following essential purposes: (i) to comply with any applicable legal requirements related to the information given (ii) to establish and define roles within the organization; (iii) to determine job positions; (iv) for talent and staff management; (v) creating and maintaining a directory of the COMPANY employees (vi) Lists for email and sending out messages; (vii) To be presented in the event of national or international legal cases or any other administrative proceedings before a competent authority, either domestic or foreign, and in general to fulfill legal obligations and safeguard the interests and rights of the COMPANY, its affiliates, subsidiaries as well as any natural person or legal entity with which the COMPANY has had, is having or may have a business relationship; (viii) Safeguard the property and rights of the COMPANY together with connected firms as well as the privacy of their information; (ix)-(x) Contact designated persons if an emergency arises; (xi) Conduct surveys on candidates’ opinions; (xii) Execute relocations (xiii) for international mobility; (xiv) assess their experience, expertise, health, fitness, talents and abilities and identify roles they are suited to; (xv) organize interviews with the COMPANY; (xvi) evaluate their experience, knowledge, health status, physical aptitude, talents and abilities and determine profiles that fit them best; plan job interviews with the COMPANY; (xvii) carry out a background check; survey jobs in the labor market to find the most suitable position for them; (xviii) prepare all types of reports; (xix) undertake internal investigations to decide on our labor divisions ;(xx )establish job positions ; talent management , databases.

Personal data may also be used for other activities, such as sending communication (including emails) regarding the COMPANY, creating and keeping a database of future job openings with the COMPANY, and offering references to potential employers.

You may submit a written request to our Privacy Officer at Vasco de Quiroga 3900 Torre A Piso 10 Int 10-B, Colonia Santa Fe de Cuajimalpa, Ciudad de México, C.P. 05348 Cuajimalpa de Morelos, or by emailing contacto@ingeniosi.mx if you wish to deny or limit the use of these non-essential purposes. This request will be added to the Opt-Out List.

Transfer of your personal data – The COMPANY may need to pass on your data, sensitive personal data and/or financial data to third parties, both domestic and foreign, to carry out the stated purposes. Furthermore, suppose there is a company restructuring involving a merger, consolidation, sale, or partial or total transfer of business or assets. In that case, it may involve transferring personal data within or outside the country. The third parties the COMPANY may disclose your personal information to include but are not limited to: other organizations that share the same standards and protocols as the COMPANY, professional advisors who work on behalf of, and in the interest of the COMPANY, service providers hired to carry out the described purposes while acting for and on behalf of THE COMPANY, potential buyers of THE COMPANY’s business or assets…. In addition, the COMPANY may also transfer your data when it is necessary to enforce legal rights and obligations or to comply with requests from Mexican or foreign authorities. This can include presenting the data as evidence in court proceedings in Mexico or any other country.

The COMPANY will only share the minimum required information. When it comes to passing on your data to third parties, the COMPANY will ensure that such recipients have appropriate measures in place to protect the confidentiality and security of your data. Additionally, they must follow all applicable laws, policies, and THE COMPANY’s Privacy Notice and not use your data for any other purpose than what they were hired for.

The COMPANY will make sure that the data is protected in line with the standards of personal data protection set out by the Federal Law for the Protection of Personal Data in Possession of Individuals and its Regulations (the ‘Law’), and any recipients of said data must agree to follow these same obligations as the COMPANY.

The COMPANY will only give away your data or hand it over to third parties outside the COMPANY, with your permission, except for the exceptions mentioned beforehand. There may be cases where the COMPANY is legally obliged to transfer your data.

Safeguarding your data – The COMPANY has taken the necessary administrative, technical, and physical security precautions to protect your data.

Only those individuals who need to use your personal data held by the COMPANY for the expressed purposes outlined in this Privacy Notice will be granted access.

The safeguarding of minors, those under legal guardianship, and persons with limited capacity – The COMPANY does not gather or process personal data from children, individuals under legal custody, or those with limited capacity unless they are provided by a parent, guardian, or authorized representative. Suppose the COMPANY suspects that personal data has been supplied by someone underage or who cannot make decisions for themselves or is legally restricted in violation of this Notice. In that case, we will delete the data swiftly. If you know anyone who provided such information under 18 years of age or an incapacitated or interdicted individual, please email contacto@ingeniosi.mx.

Rights of individuals owning personal data – You, as the individual holding personal data, are entitled to exercise your rights of access, rectification, cancellation and opposition (known as ‘ARCO’ rights) before THE COMPANY’s Privacy Officer in charge of Personal Data Protection according to the Law. You may withdraw your consent for the processing of your personal data at any time. To do so, please send an email to contacto@ingeniosi.mx.

If you or someone legally representing you want to exercise your ARCO Rights, they must send a request to the Legal Department of COMPANY for processing and further action.

Choices to limit the use or disclosure of your personal information – You may restrict the use or disclosure of your personal information to prevent its use or disclosure.

If you would like to restrict the use or distribution of your personal information, please send a request to contacto@ingeniosi.mx. Please be aware that The COMPANY may be unable to fulfill certain obligations if this occurs.

Use of Cookies and Other Tracking Technologies – The COMPANY does not employ cookies or any other tracking technology to gather personal information when you access its internal network service, internal portal and/or website.

Changes to the Privacy Notice – If there are any changes or modifications made to this Privacy Notice, the revised version will be provided to you by our Privacy Officer at THE COMPANY’s offices located at Vasco de Quiroga 3900 Torre A Piso 10 Int 10-B, Colonia Santa Fe de Cuajimalpa, Ciudad de México, C.P. 05348 Cuajimalpa de Morelos, or through an email sent to contacto@ingeniosi.mx.

Contact – If you have any inquiries or remarks concerning this Privacy Notice, or if you would like to exercise any of your legal rights, please reach out to Human Resources via the following email address: contacto@ingeniosi.mx or at the following address: Vasco de Quiroga 3900 Torre A Piso 10 Int 10-B, Colonia Santa Fe de Cuajimalpa, Ciudad de México, C.P. 05348 Cuajimalpa de Morelos.

I have read and understand this Privacy Notice.

Under the Federal Law for the Protection of Personal Data in Possession of Individuals and its Regulations, if you do not respond to ARCO rights requests or disagree with them, you can file a Request for Protection of Rights with the National Institute of Transparency, Access to Information and Protection of Personal Data as outlined in Chapter VII of the Law and its associated Regulations.