- IDENTITY AND ADDRESS OF THE PERSON IN CHARGE. This Privacy Notice (hereinafter referred to as “Notice”) establishes the terms and conditions under which URBI DESARROLLOS URBANOS, S.A.B. de C.V. and / or its subsidiaries (hereinafter “URBI”), located for notification purposes at AVENIDA ALVARO OBREGÓN 1126, COLONIA NUEVA, MEXICALI, BAJA CALIFORNIA 21100; in his capacity as Manager (or the Manager designated by URBI) will deal with the personal data of the Holder.
- CONSENT OF THE HOLDER. For purposes of the provisions of the Federal Law on Protection of Personal Data Held by Individuals (hereinafter “LFPDP”) and other applicable legislation, the Owner states (i) that this Notice has been made known to the Manager, (ii) that he/she has read, understood and agreed to the terms set forth in this Notice, and therefore gives his/her consent regarding the processing of his/her personal data. In case the personal data collected include patrimonial or financial data, by signing the corresponding contract, either in printed format, or using electronic means and their corresponding processes for the formation of consent, acts that constitute the owner’s express consent will be carried and (iii) that he/she gives his/her consent to URBI or its Managers to make transfers and / or referrals of personal data in terms of section 6 of this Notice.
- PERSONAL DATA THAT WE COLLECT. URBI can collect personal data of the Holder by means of direct and / or personal delivery by any means of contact between the Holder and the Person in Charge or their Managers. URBI can also collect personal data indirectly through public access sources and other available sources in the market.
URBI collects personal identification data, financial and / or patrimonial, academic and labor data, as well as collecting sensitive personal data related to physical and personal characteristics, and biometric data.
URBI also collects data related to the offers of sales of real estate and services indicated in its corporate purpose and information regarding the access and / or use of said services.
- PURPOSE OF PERSONAL DATA
4.1. PRIMARY PURPOSES. URBI will process the personal data of the Holder in order to carry out activities and managements focused on the fulfillment of the obligations originated and derived from any legal and commercial relationship that it establishes due to the commercialization of goods or the rendering of its services; billing; collection; credit; customer service; technical service; granting of guarantees; management of value-added services and content; contact with the customer, with the sales force and distributors; and provide, renew, retain, activate, change, return or cancel sales and / or services that the Owner requests. Also, for activities related to the control of access and safeguard of material and human resources within the premises of the Manager
4.2. SECONDARY PURPOSES. Likewise, URBI will process personal data for other purposes such as sending notification of offers, notices and / or promotional messages; communications for marketing, advertising or telemarketing purposes on new or existing products and services, whether their own or commercial partners; conduct surveys; statistics; market research, records on consumption habits through automatic data capture tools, interests and behavior; conduct benefit and incentive programs; participation in social networks, chatrooms and / or discussion forums; participation in events, trivia, contests, raffles, games and raffles; evaluate the quality of products and services; and in general for any activity aimed at promoting, maintaining, improving and evaluating your products and services.
You can oppose the processing of your data for secondary purposes through the means put at your disposal for the exercise of your rights. If you do not oppose within a period of five business days after your data was collected, it will be understood that you have given your consent.
- VIDEO SURVEILLANCE AND PHOTOGRAPHY. Anyone who enters the facilities of the person in charge may be videotaped by our security cameras and may also be photographed.
The images captured by the cameras of the CCTV system will be used for your own safety and the people’s who visit us, with the purpose of remotely monitoring the real estate and, in real time, confirming any risk condition to minimize it. Also, in order to protect the material and human resources within our facilities, photographs are intended to carry out the control of access to our corporate facilities.
The video recordings and / or photographs are stored from 25 to 35 days in the buildings
- TRANSFERS AND / OR DATA REMISSIONS. URBI requires sharing the personal data of the Holder in order to comply with its legal and / or commercial obligations, for which it has entered into or will enter into various commercial agreements both locally and abroad. The recipients of personal data are obliged by virtue of the corresponding contract, to maintain the confidentiality of the personal data provided and to observe this Notice. URBI and / or its Managers will be able to communicate the collected personal data to any other company of the same business group to which the Manager belongs to and that operates with the same internal processes and policies, whether it is locally or abroad, for its treatment with the same purposes described in this Notice.
Your personal information may be forwarded, stored and processed in a country other than where it was provided, which will be carried out in accordance with applicable data protection laws. We take measures to protect personal information regardless of the country where it is stored or referred to. We have timely procedures and controls to procure this protection.
URBI does not require the Holder’s consent to transfer national or international personal data in the cases provided for in Article 37 of the LFPDP (Federal Law on Protection of Personal Data Held by Individuals) or in any other case of exception provided by the same or other applicable legislation.
- PROCEDURE TO EXERCISE RIGHTS AND REVOCATION OF CONSENT. The Holder has, at all times, the right to access, rectify and cancel your data, as well as to oppose the processing thereof or revoke the consent you have provided by submitting an application in the format that we will provide for this purpose upon express request. same that must contain the following information and documentation:
I. Name of the Holder and address or other means to communicate the response to his/ her request;
II. The documents that prove his/ her identity (copy in printed or electronic format of voter card, passport or Visa) or, where appropriate, the legal representation of the Holder (copy in printed or electronic form of the simple power of attorney letter with handwritten signature of the Holder, the agent and their corresponding valid official IDs – voter’s credential, passport or Visa);
III. The clear and precise description of the data with respect to which it seeks to exercise any of the Rights, and
IV. Any other element or document that facilitates the location of the Holder’s personal data
In the case of requests for rectification of personal data, the Holder must also indicate the modifications to be made and provide the documentation supporting their request.
In order to comply with the obligation of access to your personal data, prior accreditation of the identity of the owner or personality of the representative will be made by making the information available on site at the address of the person in charge. Another means may be agreed between the Holder and the person in charge, provided that the requested information so permits.
For the request of the format, reception and response of the requests to exercise their Rights, the revocation of their consent and the other rights foreseen in the LFPDP (Federal Law on Protection of Personal Data Held by Individuals) we put at your disposal the following means:
Office of Protection of Personal Data
Email:
Attendance:
_______________________________.
In case the information provided in your application is erroneous or insufficient, or the corresponding accreditation documents are not accompanied, we may request, within five business days of receipt of the request, for you to provide the necessary elements or documents to process it. The Holder will have ten business days to meet the requirement, counted from the day after he received it. Should there be no response within that period; the corresponding request will be deemed not filed.
URBI will respond to the Holder within a maximum period of twenty business days, counted from the date on which the request was received, so that, if it is appropriate, it becomes effective within fifteen business days after the response is communicated. In all cases, the response will be given by the same means by which you submitted your application or, where appropriate, by any other means agreed with the Holder. The aforementioned deadlines may be extended in terms of the LFPDP (Federal Law on Protection of Personal Data Held by Individuals).
- LIMITATION OF USE AND DISCLOSURE OF INFORMATION. The Manager and / or Managers will keep the personal data of the Holder for as long as it is necessary to process their requests for information, products and / or services, as well as to maintain the accounting, financial and auditing records in terms of the Federal Law on Protection of Personal Data Held by Individuals and of the mercantile, fiscal and administrative legislation in force.
The personal data collected will be protected by adequate administrative, technical and physical security measures against damage, loss, alteration, destruction or unauthorized use, access or processing, in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Individuals and other applicable legislation. Notwithstanding the foregoing, URBI does not guarantee that unauthorized third parties cannot access the physical or logical systems of the Holders or Directors or in the electronic documents and files stored on their systems. In consequence, URBI will not be in any case responsible for the damages that could be derived from this unauthorized Access.
You or your duly accredited legal representative may limit the use or disclosure of your personal data through the same means and procedures provided for the exercise of the Rights. If your request is appropriate, it will be registered in the exclusion list provided by URBI to stop receiving information related to advertising or marketing campaigns.
Also, you have the right to register in the Public Registry to Avoid Advertising (REPEP, or Registro Público para Evitar Publicidad) of PROFECO
http: //repep.profeco.gob.mx
In case you consider that URBI has violated your right to the protection of your personal data, you can visit the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI, or Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales ).
- DATA COLLECTION WHEN ACCESING URBI’s WEBSITES AND CONTENTS
URBI can collect data through its websites, or through the use of automatic data capture tools. These tools allow you to collect the information that your browser sends to these Web sites, such as the type of browser you use, the user’s language, access times, and the IP address of the websites you used to access the sites of the Manager or other people in charge.
Within the tools of automatic capture of data used by URBI in its sites and web pages are cookies, Web beacons, and links in emails.
Use of Cookies. The correct operation of the URBI sites requires the enabling of “cookies” in your Internet browser. “Cookies” are small data files transferred by the website to your computer’s hard drive when you browse the site. In most browsers cookies are automatically accepted by virtue of their default settings, you can adjust your browser preferences to accept or reject cookies. The deactivation of cookies can disable various functions of URBI websites or that are not displayed correctly. In case you prefer to delete cookies, you can delete the file at the end of each browser session.
Use of Web beacons. Also known as Internet tags, pixel tags and clear GIFs. URBI can use Web beacons on its websites and in HTML-formatted emails, alone or in combination with cookies, to collect information on the use of websites and their interaction with email. The Web beacon is an electronic image, called a single pixel (1 × 1) or GIF that can recognize information that is processed on your computer, as in the case of cookies, the time and date on which the site and its sections are visualized.
Links in the URBI emails. The emails can include links that allow URBI to know if you activated this link and visited the web page of destination; this information can be included in your profile. Likewise, they can include links designed to direct it to the relevant sections of the websites, by redirecting it through the URBI servers. The re-addressing system allows determining the effectiveness of online marketing campaigns.
Protection of minors, persons in a state of interdiction or incapacity. URBI encourages parents and / or guardians to take an active role in their children’s online or represented activities. In case you consider that the personal data have been provided by a minor or by a person in a state of interdiction or incapacity, in violation of this Notice, please send an email to the address: _________________ so that URBI can proceed to eliminate such personal information as soon as possible.
10. CHANGES TO THE NOTICE. URBI reserves the right to periodically update this Notice to reflect changes in its information practices. It is the responsibility of the Holder to review the contents of the Notice on the website www.urbi.com or by requesting it to the email _________________. The Manager will understand that not to express otherwise, means that the Owner has read, understood and agreed to the terms set forth therein, which constitutes hi consent to changes and / or updates regarding the processing of his personal data.
