General Privacy Notice

Antuñano, Niño, Mojica y Aguilar, S.C., headquartered in Lafayette No. 14, Anzures Ward, Miguel Hidalgo Borough, Zip Code 11590, Mexico City Mexicoi, México, is responsible for the use and protection of your personal data, for this reason and in compliance with the provisions of the Federal Act on Protection of Personal Data Held by Private Parties, its Regulations, its Guidelines, including good practices recommended for privacy notices, we make this Privacy Notice (hereinafter The Notice) available to you, which has the purpose of giving strict compliance to the information principle, as well as the principles of legality, consent, quality, purpose, loyalty, proportionality and responsibility established by law, and let you know about the existence and main characteristics of the treatment to which your personal data will be submitted and be able to exercise your right to information self-determination, privacy and protection of personal data.

In this document, you will be able to know:

1. Who is responsible of the treatment of your personal data?
2. What data will be submitted to treatment?
3. What sensitive data are collected and why they are collected?
4. What is the purpose of the treatment?
5. Personal Data of Minors and disabled.
6. What are the mechanisms for you to express your refusal to the treatment of your data for the so-called “secondary purposes?
7. What are the data transfer that will be carried out, what for and for whom?
8. Your acceptance for such transfer.
9. What are the means and procedures to exercise the ARCO rights and the right for consent revocation?
10. What are the options and means that we put at your availability to limit the use or disclosure of your data?
11. What are the remote mechanisms of electronic communication that collect your data automatically?
12. What are the procedures and means by which we will notify you the changes in this Privacy Notice?
13. Exclusion of liability.
14. Safety and confidentiality of the information.
15. Getting in touch with us.

1. Who is responsible of the treatment of your personal data?
Antuñano, Niño, Mojica y Aguilar, S.C. (Hereinafter referred to TMC® LEGAL), collects your personal data for our legal advice on commercial matters, intellectual and industrial property, foreign trade, civil, administrative, contentious, migratory, information technology, compliance, due diligence (audits) and business ethics, as well as for the approach of the actions and defenses in the legal matters that are entrusted by our clients.

Our contact information for any subject related to this privacy notice, are the following:

Address

• Lafayette 14, Colonia Anzures, Delegación Miguel Hidalgo, código postal 11590, Ciudad de México, México.

Telephone
(+52 55 52 55 11 11

E-mails
info@tmclegal.com (privacidad@tmclegal.com)

2. What data will be submitted to treatment?

TMC® LEGAL directly collects your personal data through emails, public databases and our website and treats your information to provide a better service. Said compilation is made with an adequate notification and with your prior consent.

TMC ®LEGAL might collect the identification information that is described below, which has been selected by categories to better understand them:

Identification Data: Full name, date and place of birth, nationality, private telephone, cell phone, email, company, position or position held, address of the work, institutional telephone, institutional email, Population Registration Number ( CURP), Federal Taxpayers Registry (RFC), Passport, Immigration Identification, Voters Card (INE), Bank Account Number, Credit / Debit Card Number, Wire Transfer Code Number (CLABE).

At all times TMC® LEGAL performs and will perform a strict exercise of minimizing the data it collects, with the purpose of requesting only the necessary, pertinent, correct and updated data related to the purpose of each treatment, taking into account the legislation and current regulations in Mexico.

Also, your data can be collected directly and indirectly in the following cases:

• Through emails.
• By telephone.
• Through our website.
• Through public databases.

In all cases, TMC® LEGAL has implemented mechanisms to make available this comprehensive privacy notice, a short privacy notice or a simplified privacy notice, depending on the characteristics of obtaining your data.

In case we indirectly obtain your personal data, either through a consent transfer or public databases, we will inform you of this privacy notice at the first contact we have with you and prior to the use of your data personal, with the possibility at all times of expressing your opposition to said use.

3. What sensitive data are collected and why they are collected?
Please be informed that TMC® LEGAL never collects sensitive data.

4. What is the purpose of the treatment?

In this section you will have access to the list of the specific and precise purposes of the treatment of your personal data, which, for your better understanding, they have been drafted avoiding inaccurate, ambiguous or vague phrases.

In order to clearly inform you of the purposes of the processing of your personal data, Mexican regulation requires you to clearly identify and distinguish among the purposes that originated and are necessary for the existence, maintenance and fulfillment of the legal relationship between the responsible party and the holder of the data, of those that are not (secondary purposes), for which, in strict compliance with the above, we put at your availability the different treatments to which your personal data may be subject:

Original and necessary purposes:

Identification data:
• For the representation of your legal interests.
• For legal advice in different branches of law.
• For the negotiation of private agreements and competent authorities.
• For the resolution of conflicts of a legal nature.
• For the fulfillment of our contractual obligations, compliance, due diligence (audits), labor, civil, fiscal, social security and commercial law, in which they can be treated solely and exclusively for the fulfillment of the purposes subject matter of the legal relationship that is established.
• For the fulfillment of present and future obligations, of governmental requirements.

Financial data
• For the payment of obligations of our principals, clients, suppliers, employees
• For billing purposes, payroll receipts, settlements, indemnifications, and compensations.
• For payment of payroll, social security fees and taxes, commissions.

Secondary purposes:
TMC® LEGAL is a responsible company for the treatment, safety and confidentiality of personal data of its customers, so it does not carry out treatments for secondary purposes, such as delivery of mass advertising via the Internet other than those established in this privacy notice or in a physical form.

In case there are changes in the aforementioned treatments that substantially affect the purposes described hereinabove, we will put at your availability a new privacy notice that will describe the new treatment features.

We inform you that TMC® LEGAL does not carry out automated decision-making processes without involving the valuation of a human person.

5. Personal Data of Minors and disabled.
It is not the wish of TMC® LEGAL to enter into contracts that may collect personal data of minors or of persons who are in a state of interdiction or disability. In these cases, the parents or guardians grant their consent when subscribing our privacy notice, in terms of the Federal Civil Code. In order to safeguard the right to the protection of personal data of minors and disabled, security mechanisms, confidentiality and access to such information have been established.

6. What are the mechanisms for you to express your refusal to the treatment of your data for the so-called “secondary purposes?
Although TMC® LEGAL does not carry out data processing for secondary purposes, it has implemented an express mechanism so that you can express your refusal to process your personal data in relation to the purposes listed in point 4, by sending an e-mail to the address privacidad@tmclegal.com.

In case of non-sensitive information data and this privacy notice not being made known to you directly or personally, you will have a period of 5 days so that, in its case, you are able to express your refusal to treat your data for the described “primary purposes”. If case your refusal in said term is not received, it shall be construed that you have given your consent for these purposes, without prejudice to be able to exercise your rights of revocation or opposition thereafter.

7. What are the data transfer that will be carried out, what for and for whom?

We inform you that TMC® LEGAL does not carry out the transfer of your personal data to third parties for secondary purposes. In this section you will know the remittals of the personal data that we carry out, the individual in charge of receiving of the personal data and the determined purposes of said referrals, which result to be necessary for the provision of the entrusted services.
TMC® LEGAL solely transfers your personal data to judicial or administrative authorities to comply with our advisory services, the approach of actions and defenses of the legal matters entrusted by our clients which in terms of article 10 fraction IV, and of article 37 fractions IV, V, VI and VII of the Law on Protection of Personal Data in Possession of Individuals does not require consent for collection and transfer.

8. Your acceptance for such transfer.
As we deal with remittals that are necessary to comply with the contractual relationship that binds us with you, it is not necessary for you to give your consent therefor, however, TMC® LEGAL has implemented mechanisms for you to express your opposition, which it will be appropriate as long as it does not affect the contractual relationship acquired.

9. What are the means and procedures to exercise the ARCO rights and the right for consent revocation?

You have the right to know what personal data we have gathered from you, so that we use them and the conditions of use we give them (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); that we remove it from our records or databases when it considers that it is not being used properly (Cancellation); as well as to oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

To facilitate your request to exercise rights of Access, Rectification, Cancellation or Opposition (ARCO Rights) or to revoke your consent directly which you can do so by accessing your user profile, using your username and password, in order to access to your information, make the corrections or rectifications you want, cancel or delete your account. However, if you have any questions about how to exercise your ARCO rights, you can send us an email to: privacidad@tmclegal.com.

For your safety, if the request is made through a third party other than yourself, TMC® LEGAL may request the corresponding identification document and the supporting document of the faculties granted upon the representative, by means of the corresponding notarial document.

It is important to inform you that the aforementioned procedures have been established with the purpose of facilitating its exercise, and seeking at all times the greatest possible coverage, in attention to the profile of the clients of TMC® LEGAL and the way in which it keeps in touch with you. The exercise of these rights is completely gratuitous.

For your information, the contact details of the person or department of personal data, which is in charge of processing the ARCO rights requests, are the following:

a). – Name of the person in charge of peronal data: Francisco Cruz Yépez.
b). – Lafayette 14, Colonia Anzures, Delegación Miguel Hidalgo, código postal 11590, Ciudad de México, México.
c). – e-mail: privacidad@tmclegal.com
d). – Telephone number: +52 55 52 55 11 11

TMC® LEGAL will notify you within a maximum period of 20 working days as of the date on which the request for access, rectification, cancellation or opposition was received, and with regard to the revocation of your consent, the adopted decision. If it is appropriate, it will be effective within 15 business days following the date on which the response is notified. The means by which the answer will be communicated will be, specialized messaging, direct delivery in our offices and / or email. In all cases, acknowledgment of receipt will be retrieved.

TMC® LEGAL may deny access to your personal data or to make the rectification or cancellation or grant the opposition to the treatment thereof, in the following cases:
• When the applicant is not the titleholder of the personal data, or the legal representative is not duly vested for it;
• When in our database, the applicant’s personal data are not found;
• When the rights of a third party are harmed;
• When there is a legal impediment or the resolution of a competent authority that restricts access to personal data or does not allow rectification, cancellation or opposition of the same; and
• When the rectification, cancellation or opposition have been previously made.
The refusal referred to in this article may be partial, in which case TMC® LEGAL will carry out the access, rectification, cancellation or opposition required by the owner.
In all the above cases, TMC® LEGAL will duly inform you of the reason for its decision or, where applicable, the legal representative, within the deadlines established for this purpose by the same means by which the request was made. In case you feel affected by the resolution we determine, you are entitled to the protection rights before the Federal Institute for Access to Public Information and Data Protection.
10. What are the options and means that we put at your availability to limit the use or disclosure of your data?
We are a company that honors the protection of personal data of the different people involved in our different processes. For this reason, we have implemented the different options and means to limit the use and disclosure of your personal data before their use, described in the preceding paragraphs.

Likewise we inform you that you can request the limitation and / or disclosure of your personal data in the following government agencies:

Federal Consumers Board (PROFECO) Av. José Vasconcelos 208, Col. Condesa, Deleg. Cuauhtémoc CP.06140 Ciudad de México, through the Public Registry to Avoid Advertising (REPEP) whether phisically, through telephone or on the internet. For more information please call the following numbers: 56256700; 01800 4688722 or go to the Website http://repep.profeco.gob.mx/index.jsp

11.What are the remote mechanisms of electronic communication that collect your data automatically?

Cookies are text files that are downloaded automatically and stored on the hard disk of the user’s computer when browsing a specific Internet page, which allows the Internet server to remember some information about this user, including their purchasing preferences for the display of the pages on that server, name and password.

On the other hand, web beacons are embedded images in an Internet page or email, which can be used to monitor the behavior of a visitor, such as storing information about the user’s IP address, duration of interaction time on said page and the type of browser used, among others.

We inform you that we use cookies and web beacons on our Website to obtain personal information from you, such as the following: i) The type of browser and operating system that you use; ii) The Internet pages that you visit prior to and after the entry of the TMC® LEGAL Website; iii) The links you follow and stay on our site; iv) Your IP address; v) Place from which you are visiting us and navigation statistics.

These cookies and other technologies can be disabled. You can search for information about known browsers and find out how to adjust the preferences of cookies on the following websites:

Microsoft Internet Explorer:
http://www.microsoft.com (informative link)

Mozilla Firefox:
http://www.mozilla.org (informative link)

Google Chrome:
https://support.google.com/ accounts / answer / 61416?hl =en (informational link)

Safari:
http://www.seguridadapple.com (informative link)

In the case of use of cookies, the “help” button found in the toolbar of most browsers will tell you how to avoid accepting new cookies, how to make the browser notify you when you receive a new cookie or how to disable all cookies.

12. What are the procedures and means by which we will notify you the changes in this Privacy Notice?

TMC® LEGAL reserves the right to modify and update this Privacy Notice, however, it has the obligation to inform you, as the owner of the relevant personal data, the publishing of new versions of the privacy notice, through any of the following means:

• Email to any of the addresses you have rendered;
• Notices placed in visible places in our offices.
• On our Website

13. Exclusion of liability.
Our Website may contain links, hyperlinks or hypertexts “links”, banners, buttons and / or Internet search tools that when used by users it might take you to other portals or Internet sites that may be owned by third parties. TMC® LEGAL does not control said sites nor is responsible for the privacy notices that they bear or the lack thereof. The personal data that users may provide through these portals or Internet sites other than our Website fall within your responsibility , so you ought to check the privacy notice on each site you access.

14. Safety and confidentiality of the information.
TMC® LEGAL has implemented technological measures to protect the relevant personal data. We also apply reasonable physical, electronic and administrative procedures to protect personal data against accidental or unlawful destruction, accidental loss or alteration and disclosure or unauthorized access. However, and despite having safer tools every day, data transmissions through the Internet are not 100% safe, so once the personal data are received, we will take all the reasonable efforts at our hand to safeguard them and in case of violation, you will be immediately notified so that you have the opportunity to take the relevant security measures.

15. Getting in touch with us.
Do not hesitate to contact TMC® LEGAL should you have any comments, questions or suggestions regarding the personal data management practices described in this privacy notice, for this you can contact us by sending a message to the Data Protection Department from TMC® LEGAL to privacidad@tmclegal.com.