FEENICIA PRIVACY NOTICE*

This notice is set forth pursuant to the Federal Law on the Protection of Personal Data in Possession of Private Individuals [Ley Federal de Protección de Datos Personales en Posesión de los Particulares] and to ensure the protection and privacy of personal data, as well as to regulate the access, rectification, cancellation, and objection to the processing thereof in consideration of informational self-determination.

Who Are We?

Servicios Estratégicos en Tecnologías de Información S. de R.L. de C.V. (hereinafter FEENICIA) with business address at Shakespeare #6, piso 3, Nueva Anzures, Miguel Hidalgo, C.P. 11590, Mexico City is responsible for collecting, using, and protecting your personal data.

PERSONAL DATA USE (PURPOSE LIMITATION)

As part of its operating process, FEENICIA registers your personal information to provide the services and products you requested, inform you of changes thereto and evaluate the quality of the service we offer.

The purpose of processing your personal data is exclusively the procurement and promotion of professional services such as consultancy, training, technical support related to the development of computer programs, service, and maintenance thereof; including the creation of databases, purchase-sale, installation, maintenance, renting and distribution of computer equipment in general offered by FEENICIA. Likewise, to render services, provide information, special offers and any other matter related to your interests or to associate you to any legal or business practice with us, as well as to inform you of any changes and to evaluate the quality of service we offer you. In the same vein, FEENICIA can use the image of its clients for informational, promotional, and advertising purposes through electronic and printed media. Likewise, we will use your personal data for the following:

1. Contact you to offer consultancy, help, and technical support for our products and services
2. Send information related to our products and services
3. Entering into agreements to formalize the rendering of services and to legalize it
4. Shipping and reception of POS terminals, also known as Feenicia Devices
5. Payment of transactions to CLIENT
6. Issue tax invoices
7. Send tickets, transaction information, payments, and invoices
8. Contact you to assess the quality of the service
9. Send advertisements for our and our business partners’ services, products and lines of business

TYPE OF INFORMATION OR PERSONAL DATA WE COLLECT

In order to comply with the purposes set forth in this privacy notice, we inform you that the following personal data will be collected:

1. Name and last names
2. Email
3. Contact telephone numbers
4. Address
5. Signature
6. Nationality
7. Official ID (picture)
8. Bank card (picture)

CARDHOLDERS

In order to control our risk levels and to safeguard the information to offer a service, we receive additional information from the CARDHOLDER. Such information may include their credit rating, risk level, risk forecast, credit limit, legal status, capital stock, Federal Taxpayer’s Number [RFC], personal address, business addresses, registration date, annual account summary and financial parameters, default history with the corresponding authority. We may also use a variety of technologies that automatically or passively collect information on how our products are accessed and how they’re used.
All cardholder data collected by CLIENT are collected in the FEENICIA database. Said personal data will never be used by FEENICIA for purposes other than those set forth in this Privacy Notice in order to undertake the commitment stipulated below.

OUR COMMITMENT

We are committed to process your data under the strictest security, legal, loyal and transparent measures to guarantee their confidentiality.
By accepting this Privacy Notice you agree that FEENICIA processes your personal data according to articles 6, 7, 8 of the Federal Law on the Protection of Personal Data in Possession of Private Individuals.

We guarantee that the personal data provided is accurate and current in relation to the purposes for which it’s processed, and we also request the information necessary to make pertinent corrections as necessary.

Your personal data shall never be used for a purpose other than for FEENICIA to provide services. Said data will be kept only for the time strictly necessary to render such service.
FEENICIA carries out the technical, physical, administrative security measures designed to provide strict protection to your personal data in order to prevent loss, misuse, unauthorized access, disclosure and alteration thereof. Security measures include firewalls, data encryption and decoding, physical controls to our data centers and information access authorization controls, as well as internal security and protection controls to the information processed by FEENICIA with its employees under individual confidentiality agreements entered into by each internal, external, temp employee that works directly or indirectly with FEENICIA.

You are responsible for safeguarding and maintaining the privacy of your passwords and Account information, and for verifying that the Personal Information we keep about you is accurate and up to date. We are not responsible for protecting Personal Information shared with a third party related to an account connection that you have authorized.

If you need more information about the Privacy Policy that FEENICIA has implemented to justify its reliance on domestic legal grounds as well as legitimate interest under the GDPR, please see the last part of this Notice “How to contact us” for more information on how to contact us.

PROTECTION AND STORAGE OF YOUR COLLECTED DATA

Your personal information is protected by physical, electronic and procedural safeguards in accordance with applicable Mexican laws. We also use computer safeguards such as firewalls and data encryption. For example, we use TLS encryption to safeguard your credit card data when used in e-commerce transactions. In addition, we enforce physical access controls to our offices and archives, and authorize access to users’ personal information only for personnel who require it to fulfill their job responsibilities. We strive to ensure the security of our systems.

Despite our efforts, we cannot guarantee that personal information will not be accessed, disclosed, altered or destroyed as a result of a breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take appropriate precautions to protect your personal data as well, including never sharing the username and password used in connection with your participation in the Services.

If you become aware of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, you agree that we may communicate with you electronically, may post a notice on the website or mobile application if a security breach occurs. We may send an email to you at the email address you have provided to us.

ACCOUNT INFORMATION UPDATE

FEENICIA allows you to change your personal information at any time. In order to do so, simply log in with your username and password and you can update the information you’ve provided.

MINORS

The FEENICIA site and Services are not aimed at minors. We do not knowingly collect any information (including Personal Data) from children or other individuals who are unable to use our Sites and Services legally. If we become aware that we have collected Personal Data from a minor, we will immediately delete it unless we have a legal obligation to retain it. Please contact us if you think we are collecting information from a minor by mistake or unintentionally.

RIGHTS RELATED TO YOUR PERSONAL DATA

You have the right to access, rectify and cancel your personal data, as well as to oppose the processing of such data or withdraw the consent you have given us for such purpose, through the procedures we have implemented.

To learn about these procedures, requirements, and deadlines you can contact our Customer Service Department, by phone at 55906817 or by email at ayuda@www.feenicia.com or at the address Shakespeare 6, piso 3, Nueva Anzures, Miguel Hidalgo, C.P. 11590, Mexico City, or visit our website at http://www.feenicia.com.
At any time, you may withdraw the consent you have given us for the processing of your personal data, so that we stop using it.

As the owner of your personal data, you have the right to request, access, rectify, withdraw, delete, and restrict the way we process your Personal Data. These rights include the ability to review the Personal Data we hold in our Information and Communications systems that concern you, the ability to make any corrections to the Personal Data, the ability to be informed of who that data was shared with, the ability to withdraw your consent for FEENICIA to process your Personal Data, the ability to request that we delete all of your Personal Data, and the ability to restrict how we process your Personal Data.

WITHDRAWAL OF CONSENT

You may at any time withdraw the consent you have granted to process your personal data in order to cancel the use thereof until you sign a legal act with FEENICIA.
For that, you must submit your written application to Shakespeare #6, piso 3, Nueva Anzures, CP 11590, Miguel Hidalgo, Mexico City. The application must contain the following information:

• Full name, address, and email address.
• Copy of identification of the holder of the rights.
• Reasons for which you are requesting withdrawal of consent.

Once you submit your application, FEENICIA will issue a response in no more than 20 business days.

PROCEDURE TO EXERCISE THE RIGHT OF ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION (ARCO) OF YOUR PERSONAL DATA

You may, at any time, exercise your ARCO rights by submitting a written request, which must contain the following:

• Full name, address, and email address.
• Copy of identification of the holder of the rights or document proving the identity of the parent or guardian.
• A clear and accurate specification of the personal data to which you want to have access and the ARCO right (access, rectification, cancellation, or opposition) you want to exercise.
• Any other element or document that may facilitate the location of the personal data.
• In case of rectification of the personal data, you must also specify the reason why you oppose to the processing thereof.

Once the application is submitted, FEENICIA will issue a response within a maximum of 20 business days. In case the request is authorized, SERTI will put into effect your right(s) within a term of 15 business days after the aforementioned 20 days.

It is important to save the application record since it will be required if a new proceeding is filed before the Federal Institute of Transparency, Access to Information and Personal Data

Protection [Instituto Federal de Acceso a la Información y Protección de Datos].
Likewise, we inform you that the terms of storage of personal data in our database will be:

• In the case of the CLIENTS, the storage of personal data will be for a maximum term of 5 years after termination of the “SERVICE CONTRACT,” unless the contractual relationship exceeds such term.
• In the case of EMPLOYEES, the storage of personal data will be for a maximum term of 5 years after their departure and termination of the “EMPLOYMENT CONTRACT”; as well as for those employees with a “PROFESSIONAL FEES” contract.

Once these periods have elapsed, and if the purpose of the processing of the personal data has been fulfilled, the data will be cancelled and subsequently deleted from the database.

PERSONAL DATA TRANSFER

Your personal data may be transferred and processed within the country by persons other than FEENICIA. In that sense, your information may be shared with our service providers, associated entities or agents, entities with which we have marketing alliances, companies of our business group abroad, or other third parties with whom we have entered into service or commercial alliance agreements with confidentiality clauses, in order to comply with obligations contracted with them and/or to perform internal market and statistical studies on the services we provide.

Likewise, your personal data may be transferred to the different federal and local governmental authorities that may require it.
We undertake not to transfer your personal information to third parties without your consent, except for the exceptions provided in Article 37 of the Federal Law on Protection of Personal Data Held by Private Parties, as well as to make this transfer under the terms set forth in that law.

In connection with your registration of a FEENICIA Account, we share your information with verification services and credit bureaus to verify your identity.

CHANGES TO THE PRIVACY STATEMENT

We reserve the right to modify or update at any time the present Privacy Statement in order to comply with legislative news, internal policies or new requirements to render or offer our services.
Any change to this Privacy Notice may be consulted at http://www.feenicia.com

COMPLAINTS

If you believe that your right to protection of personal data has been violated by any conduct of our employees or our actions or responses, and you presume that in the processing of your personal data there is any violation of the provisions of the Federal Law on the Protection of Personal Data in Possession of Private Individuals, you may file a complaint with the INAI. For more information visit www.inai.org.mx

Once made available to you, and if you do not express your opposition to it, it will be understood that you tacitly consent to the processing of your data.

HOW TO CONTACT US

Thank you for reading our Privacy Notice. If you have any questions about it, please contact us by writing to the following address:
Shakespeare # 6, piso 3, Nueva Anzures, Miguel Hidalgo, C.P. 11590, Mexico City.

You may also contact us by telephone at 55906817 or by e-mail at ayuda@www.feenicia.com.

Sincerely

FEENICIA

Last update : August 7, 2018

 

*The present text written in English is a translation of the original text written in Spanish. In the case of discrepancy between the original text in Spanish and the text written in English, the original text in Spanish is the legally binding text.