PRIVACY NOTICE (Arena Communications, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Arena Communications, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to trade and industry, providing digital advertising services to third parties, whether individuals or entities, with address at Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, México, Tax ID Number ACO0001311S9.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Life México, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Havas Life México, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to plan, conceptualize, any marketing and communication action, conception of strategies, creative ideas, promotional mechanisms and advertising campaigns, public relations and direct marketing., with address at Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, México, Tax ID Number PSU990108HK1.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Manuel Gómez Morín, No 350 Int. 602; Colonia Valle del Campestre, Nuevo León, Area Code 66265, México, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Media, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Havas Life México, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to plan, conceptualize, any marketing and communication action, conception of strategies, creative ideas, promotional mechanisms and advertising campaigns, public relations and Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, México, Tax ID Number MPG941109JTA.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Media Regiones, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE PARTY
  2. Havas Media Regiones, S.A. de C.V. (“The Company”) which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to trade and industry, providing digital advertising services to third parties, whether individuals or entities, with address at Av. Manuel Gómez Morín, No 350 Int. 602; Colonia Valle del Campestre, Nuevo León, Area Code 66265, México, Tax ID Number HMM030602KC9.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Manuel Gómez Morín, No 350 Int. 602; Colonia Valle del Campestre, Nuevo León, Area Code 66265, México, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Manuel Gómez Morín, No 350 Int. 602; Colonia Valle del Campestre, Nuevo León, Area Code 66265,México, Attention: Facundo Daniel Eroles. Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Media Services, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE PARTY
  2. Havas Media Services, S.A. de C.V. (“The Company”) which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to the rendering of professional, technical, specialized advisory and consulting services in areas of management, human resources, finance, senior management, accounting, taxes, which are required by individuals and/or corporations in Mexico or abroad, with address at Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, México, Tax ID Number HMS971215TH9.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, México, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (HPH México, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE HPH México, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related with the strategic and creative development of (direct) marketing strategies, advertising campaigns, direct mail campaigns and promotions; database, applications, online advertising and any type of interactive applications; telecommunications service, with address at Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, México, Tax ID Number HSP0309255Q6.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Plus, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Havas Plus, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to trade and industry, providing digital advertising services to third parties, whether individuals or entities, with address at Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, México, Tax ID Number FMC1412123B6.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Worldwide México, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Havas Worldwide México, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related Plan, conceptualize, any marketing and communication action, conception of strategies, creative ideas, promotional mechanisms and advertising campaigns, public relations and direct marketing., with address at Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, México, Tax ID Number ERB9602136S8.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in México City, Mexico, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Paseo de la Reforma No. 296, 44th floor, Colonia Juárez, Alcaldía Cuauhtémoc, Area Code 06600, in Mexico City, Mexico, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Intellignos By Havas, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Intellignos By Havas, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to the rendering and contracting of technical, advisory services related to business activities, advertising, marketing, statistics, data analysis and consumer habits, which are required by individuals, legal entities, business groups and/or economic units, in México or abroad, with address at Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, Tax ID Number IBH210728BK6.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Havas Xchange, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Havas Xchange, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to trading and industry in general, of all kinds of goods and/or real estate, subject to trade, with address at Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, Tax ID Number HXC210728MD5

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named mx.havas.com

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on:

PRIVACY NOTICE (Motech By Havas, S.A. de C.V.)

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation on July 5th, 2010 the following Privacy Notice is herein issued.

  1. IDENTITY AND ADDRESS OF THE RESPONSIBLE Motech By Havas, S.A. de C.V. (“The Company”)
  2. which is an entity established in compliance with the Mexican laws, which its main corporate purpose is related to strategic and creative development of marketing, advertising, direct mail, and promotional campaigns, among other activities allowed by the Mexican law, with address at Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, Tax ID Number RAB220302KH8.

  3. INFORMATION
  4. “The Company” gathers certain personal data provided by its clients, suppliers, service providers, commercial partners and employees, among others, related to the digital advertising services, or any third related party with these services, which may have authorized access to the products and/or services provided by “The Company”. For purposes of documenting our relationship with each one of them, by visiting our websites or requesting information (whether verbally or written) they provide us willingly and freely, information that is included in contracts, letters, forms, databases and/or other means applicable for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated.

    Among such personal data, including, but not limited to “sensitive personal data”, the following is included:

    INDIVIDUALS

    • Complete Name (paternal surname, maternal surname and name (s))
    • Private address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Nationality
    • Date and place of birth
    • Marital status
    • Profession or current occupation
    • Activity of the business
    • Telephone number
    • Email address
    • Unique Key of the Record of Population (CURP)
    • Contributors’ Federal Record (RFC)
    • Personal reference information
    • Educational information
    • Union membership information
    • Current health and medical information (it is mentioned though not collected by the responsible party)
    • Training information
    • Safety and environmental testing information
    • Income information
    • Gender
    • Bank account information and salary
    • Tax ID number

    ENTITIES

    • Name or trade name
    • Mercantile activity or corporate purpose
    • Contributors’ Federal Record (RFC)
    • Address (street, exterior number, interior number, if applicable, ZIP code, delegation or municipality, city or population and Federative Entity)
    • Date of Incorporation
    • Nationality
    • Telephone number
    • E-mail and link to their website, if applicable
    • Name, nationality, and information of the person whose signature could force the moral person to enter into the operation, which may be: the administrator or administrators, the director, manager, legal representative or attorney-in-fact.

    Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with “The Company”, which are self-responsible for the protection of personal data that each of them collects in accordance with their own privacy policies.

  5. CONFIDENTIALITY AND HANDLING OF PERSONAL DATA
  6. Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with express consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.

    Also, “The Company” shall constantly make is best efforts through technological means and internal protection procedures, to maintain the safety of the Personal Data that is provided to “The Company” to avoid the unauthorized access to such.

    Handling: The Personal Data that is provided to “The Company” is used to meet legal requirements, to keep appropriate record of clients, personnel and providers of supplies and services, and to coordinate all services provided by and to “The Company”, including emergencies.Personal Data is the personal information provided to “The Company” that may also be used for means of publicity, promotion, website administration of “The Company”, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by “The Company” and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.

    “The Company” performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law; however, when the personal data are no longer necessary for the fulfillment of the purposes provided for by the privacy notice and the applicable legal provisions, they must be canceled.

    When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that “The Company”may further verify against documents the accuracy of said personal data and that the provider of the personal data may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to “The Company” is inaccurate, incomplete, or not updated.

    “The Company”is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when “The Company” acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case “The Company” has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the Owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.

    “The Company” may transfer the Personal Data, including sensitive personal (in such case) data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.

    It is emphasized that “The Company´s” technology service providers are self-responsible to carry out technology audit, reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

  7. LIMITATIONS OF USE AND DIVULGING OF DATA
  8. The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” (section paragraph 3) of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.

    Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the transaction requested by “The Company”. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.

    “The Company” will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for “The Company” to keep them.

    Use of Cookies: The Rules defines cookies as the data file that is stored on the hard-drive of the computer equipment or electronic communications device of The Owner when browsing on a website of “The Company”, which allows the exchange of status information between said site and the browser of The Owner, such information may reveal means of session identification, authentication or preferences of The Owner, as well as any data stored by the browser regarding “The Company´s” website;

    “The Company” will use cookies related to the business of the digital industry, when browsing the website of the same, The Owners may: a) choose to delete all or some of the cookies from your device through your browsing settings; b) choose to prevent the installation of cookies on your device by means of your browser settings; c) enable or disable the cookies we use directly on our website named www.talentohavas.mx

  9. MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA
  10. The Owner of the personal information may request to the responsible party of “The Company” at any time to access, rectify, cancel or correct Personal Data (ARCO DATA – Access, Rectification, Cancellation or Opposition Data Personal). For such end, the Owner of the Personal Data shall direct a written request to the Responsible Party, which shall contain the following information:

    1. Name of the Owner and address or other means to communicate the answer of its request.
    2. The documents that evidence the identity, or, if applicable, the legal representation of the Owner.
    3. The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.
    4. Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.

    The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that they require at [email protected] or by mail or other written notice to the following address Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, phone number 55 91 77 60 00, Attention: Facundo Daniel Eroles.

  11. REVOCATION
  12. The Owner of the Personal Data may revoke and/or cancel the current consent for the handling of his Personal Data at any time, including receiving emails from “The Company”, by submitting a request via email to [email protected] or by mail or other written notice to Facundo Daniel Eroles, Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, Attention: Facundo Daniel Eroles.Such communication shall comply with the applicable request requirements mentioned in the previous section.

  13. MODIFICATIONS TO THE PRIVACY NOTICE
  14. “The Company” reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in “The Company´s” facilities at its address mentioned above, or through written notice to employees or others.

  15. INTERNATIONAL TRANSFER OF PERSONAL DATA
  16. In the event that “The Company” transfers internationally personal data of The Owner, it will have the due diligence to transfer them recognizing and having the database of who is the recipient / third party or recipient of the personal data, either identifying each of them by name, denomination or business name; or, indicating its type, category or sector of activity, and the purposes that justify the transfers of personal data and its relationship with “The Company”.

    The Owner gives his consent to the transfer for the international transfer of personal data collected by “The Company”.

  17. ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR).
  18. “The Company” is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article 3 subsection V of The Law and articles 4, 5, Third Section of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

  19. IMPACT OF THE LAWS OF THE UNITED STATES OF AMERICA REGARDING THE PROTECTION OF PERSONAL DATA HELD BY THIRD PARTIES IN MEXICO.
  20. Due to the no existence of a federal law regarding the protection of personal data held by third parties in the United States of America; “The Company” makes available this Privacy Notice which contains the general requirements established by the authorities of that country in matters of personal data protection, The following are mentioned:

    i) Publicity of this privacy notice in written form, web site, electronic media, contracts, documents with whom “The Company” has a relationship with data Owners resident or domiciled in the United States of America; ii) “The Company” has the Privacy Notice Guidelines; (iii) It is carried out the procedures to access, cancellation, rectification and opposition of the personal data information with whom “The Company” has a relationship; iv) “The Company” set up the “policy of use and restriction of cookies”; v) it is carried out the efforts to improve security processes for the protection of personal data; vi) No personal information is collected from minors by “The Company”.

  21. CONSULTATIONS
  22. For any doubts, comments, or consultations regarding this Notice, you may file an inquiry to the following address: Av. Mario Pani No. 400, 1st floor, Colonia Santa Fé Cuajimalpa, Cuajimalpa de Morelos, Area code 05348, in Mexico City, México, Attention: Facundo Daniel Eroles.

    1. Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS.
    2. Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable in Mexico. Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
    3. This Notice was posted on: