Comprehensive Privacy Notice  ​

In compliance with the Federal Law on the Protection of Personal Data held by Individuals (FLPPDHI) (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, LFPDPPP), we place at your disposal our comprehensive privacy notice. 

1.- Identity and address of the person responsible for your personal data. GRUPO WOLVENH, SAPI, DE C.V.., (hereinafter “WOLVENHALL”), domiciled at Edgar Allan Poe 85-B, Colonia Polanco, C.P. 11560, CDMX, is responsible for the handling and protection of your personal data. 

2.- Data handling purposes Your personal data is collected for the following primary and secondary purposes: a) Primary Purposes.- Purposes giving rise to and necessary for the legal relationship between you and WOLVENHALL: · Identify it. · Handle your information requests concerning our products and services. · Comply with legal and commercial obligations arising from the legal relationship, where appropriate, established with you. · In order to manage consulting, purchasing, placements, administration and operation of services and products offered by WOLVENHALL. · Quote services required by you. · Attend your inquiries, clarifications, comments and complaints. · Comply with data protection and other applicable regulations in force. b) Secondary Purposes.- Purposes that do not give rise to the legal relationship between you and WOLVENHALL, but of utmost importance for us and useful for you: · Conduct surveys, assessments and monitoring of the services provided. · Conduct market research. · Offer you new products and services that fit your needs. · Contact you and send you communications for promotional purposes. · Extend invitations to events which might be of interest to you. · For marketing, advertising and commercial prospecting purposes. · Keep you informed about innovations in products and/or services of your special interest. · Learn your opinion and experience on the services obtained. 

2.1.- Refusal to have personal data handled for secondary purposes If you do not want your personal data handled for the stated secondary purposes, you may deny your consent by sending your application to our Privacy Committee (see paragraphs 5 and 6 of the Notice herein), who will indicate the procedure to follow to exercise your right. Your refusal in this regard cannot be grounds for WOLVENHALL to deny you the services requested or terminate the relationship established with us. 

3.- Personal data we collect. In order to comply with the purposes set out in this privacy notice, we shall collect from you the following categories of personal data: (i) identification; (ii) contact details and (iii) job data. 

3.1.- Sensitive personal data We inform you that in order to comply with the purposes described in this notice, WOLVENHALL does not collect or handle your sensitive personal data. 

3.2.- Personal data of third parties Concerning personal data of third parties that you provide to us deliberately, you fully acknowledge, by means of this legal instrument, that you have previously obtained the corresponding consent (tacit and/or express and/or express written consent, in accordance with the Information that you unilaterally communicate) of these third parties, so that WOLVENHALL can lawfully handle such personal data. In the event that you do not comply with the foregoing, you will be solely responsible for the legal effects arising from your failure to comply with the FLPPDHI and, where appropriate, with the provisions stated by the competent authority. 

4.- Transfer of personal data In order to fulfill the primary purposes outlined in this privacy notice, your personal data may be transferred to the following individuals or legal entities, without their consent legally required in terms of article 37 of the FLPPDHI: I. Insurers and/or surety bond companies and/or reinsurance companies and/or other companies with which we have an executed contract or a contract to be executed, which is directly related to the products and/or services that you have decided to purchase; therefore, such transfer of information is necessary to comply with the purposes of the privacy notice herein and the subject matter of the contract agreed with you. II. Holding companies, subsidiaries or affiliate companies under common control of WOLVENHALL, or to a parent company or to any company of the same group to which WOLVENHALL belongs, which operates under the same internal processes and policies. III. Authorities, in order to comply with the corresponding legal provisions, as well as to clarify incidents or exercise any right. 

5.- WOLVENHALL´s Privacy Committee WOLVENHALL’s  Privacy Committee has been formally appointed to handle the holders’ applications for the exercise of their rights, as well as to promote and ensure the protection of the personal data we have in our possession. For everything related to your right to informational self-determination, privacy and protection of your personal data, you may contact our Privacy Committee through the following communication mechanism we have at your disposal:

6.- ARCO Rights For the exercise of any rights of access, rectification, cancellation and opposition (hereinafter referred to as “ARCO Rights”), you must fill out and submit the ARCO Rights Application (“Application”), available to you on our website (which can be sent to your email, if you request it) in order for the Privacy Committee to assist you in a timely manner. In order for the WOLVENHALL’s Privacy Committee to follow up on your application, you, or your legal representative, must properly prove your identity. To do so, all the fields contained in the ARCO Rights Application must be completed and a copy of any official identification in force indicated therein shall be attached. In the event the information provided in the Application is wrong or insufficient, or if the relevant identification documents are not attached, the Committee, within five (5) business days following receipt of the Application, may request submission of the elements or documents required to process the Application. You shall have ten (10) business days to meet the requirement, as of the day following the date in which you received the application. If there is no reply during that term, the relevant application shall be considered unsubmitted. The Committee shall communicate the decision made, within a maximum term of twenty (20) business days as of the reception date of the application, so that, if appropriate, it shall be effective within fifteen (15) business days after the response is communicated. The response should be emailed to the email address contained in the Application. 

7.- Mechanisms and procedures to revoke your consent. Under the terms of the applicable regulations, you may revoke the consent previously granted to us. However, it is important to keep in mind that not in all cases your Application shall be admitted, since we may be required by law to continue handling your personal data. To revoke your consent, you must submit your ARCO Rights Application by email to addressed to our Privacy Committee. 

8.- Limit the use and/or disclosure of personal data You may limit the use and/or disclosure of your personal data by sending your ARCO Rights Application to the WOLVENHALL’s Privacy Committee to the email address The requirements to prove your identity, as well as the procedure to fulfill your request shall be governed by the same criteria indicated in paragraph 6 of this privacy notice. If your request is approved, the Committee shall record it in the internal exclusion list for the applicable purpose. 

9.- Use of “cookies” Cookies are text files that are automatically downloaded and stored on the hard disk of the user's computer equipment when browsing a specific web page, which allow the Internet server to remember some data about this user; among them, their preferences for displaying the pages on that server, name and password. On the other hand, web beacons are images inserted in an Internet page or email, which can be used to monitor the behavior of a visitor, store information about the user's IP address, interaction time on such page and the type of browser used, among others. WOLVENHALL informs you that it does not use cookies or web beacons to get your password, nor personal information, your type of browser and operating system, pages visited in the portal, concurrence of links in the portal, portal logout, etc. These cookies and other technologies can be disabled by you at any time. To learn how to do this, we suggest you visit the following link: cookies. 

10. Modifications to this privacy notice Any change, modification and/or updating to this comprehensive privacy notice may be performed by WOLVENHALL at any time and will be announced through its website and/or through national circulation print media. Last update: January 2019. ​