ADMINISTRADORA GLISCO, S.C. PRIVACY NOTICE CLIENTS AND SUPPLIERS

In compliance with the Federal Law of Protection of Personal Data in Possession of Individuals and its regulations (the “Data Law”) as well as the Guidelines of the Privacy Notice published in the Federal Official Gazette on January 17, 2013, (the “Guidelines”), Administradora Glisco, S.C. (“Glisco”), regarding the use and protection of personal data obtained, Glisco states the following:

I. Address and Identity of the person responsible

Administradora Glisco, S.C. will be responsible for the processing of your personal data
The person in charge of processing personal data: Carlos Schvartzman Lombrozo
Address: Paseo de los Tamarindos No. 400 A Arcos Torre I Piso 22, Colonia Bosques de las Lomas, Cuajimalpa de Morelos, Ciudad de México, C.P. 05120.
Email: cschvartzman@gliscopartners.com
Phone Number: +52 (55) 5249 4349

II. Data that will be requested and purposes of processing personal data
A. Data that will be requested:

The personal data that will be requested are listed as follows:
Name, address, email of the legal representative and/or of the person in charge of payments, billing and/or collections, phone number and CURP (Mexican Registration and Personal Identification Code)
Taxpayer Identification Card (which must include its fiscal domicile)

In case of legal entities, a copy of its Articles of Incorporation duly registered before the Public Registry of Commerce as well as any notices about any changes to the data previously requested and, a copy of the document containing the power of attorney of the Legal Representative.

In case of individuals, copy of their birth certificate and an official identification.
Bank Data, such as account numbers, bank name, holder’s name, bank branch and CLABE.
A letter on the company’s letterhead certifying the payments and duly signed by the Legal Representative.
Copy of the bank account statement.
Letters of commercial references.
Line of business of the company.
Copy of the proof of address.

B. Purposes of using your personal data

1. The information will be used for the following purposes:

All necessary purposes for the Existence, Maintenance and Compliance of the Legal Relationship between Glisco and you; To enter into contract with Glisco;
Comply with any obligations previously contracted with our clients and/or suppliers;
Comply with all regulatory obligations issued by the competent authorities and meet their requirements;
Identification purposes;
Create and maintain a commercial dossier containing all data corresponding to the holder of the personal data; and
If applicable, comply with our payment obligations.

2. Purposes not necessary for the Existence, Maintenance and Compliance of the Legal Relationship between Glisco and you 

Inform of any new services related with what was previously contracted;
Inform of any changes of our services;
Statistical purposes, Marketing, advertising, or commercial prospection purposes with other companies within the Glisco group; and Verification of authenticity of the information provided.

By providing your personal data to Glisco, you agree to let Glisco collect and use said data for the aforementioned purposes. The holder of the personal data has the right to oppose to the use of the personal data contained in point 2 above (Purposes not necessary for the Existence, Maintenance and Compliance of the Legal Relationship between Glisco and you). If you wish to exercise the right to prevent Glisco from using your data for these purposes, the holder of the personal data must do so in accordance with the procedure established in subsection III below within five (5) business days following the date on which this privacy notice has been placed at your disposal, otherwise, it will be understood that the holder consents to the use of their data for all purposes listed above.

Glisco may disclose your personal data to comply with the provisions referred to in the preceding paragraph and also to comply with any requirements made by judicial and/or administrative authorities.

III. Options and means offered by Glisco to limit the use or disclosure of the holder’s personal data

To limit the use or disclosure of your personal data, the holder of said data must communicate personally, by telephone, or through email to the corresponding department or the person in charge of processing personal data, requesting the limitation of the use or disclosure of any information.

If the holder of the personal data wishes to stop receiving promotional messages from Glisco, he or she can request it through the means established in the previous paragraph. However, if the holder limits the use or disclosure of their personal data, it may be possible that Glisco will not be able to provide the benefits to which it would otherwise have access. Glisco may take the measures it deems appropriate if its limitation of the use or disclosure of the data interrupts or in any way affects its processes and practices.

IV. Means to exercise the rights of access, rectification, cancellation, or opposition 

In accordance with the Data Law and the Guidelines, the holder of the personal data has the right to access the data held by Glisco including the details of the treatment thereof, as well as to correct them if they are inaccurate or incomplete; cancel them in compliance with the Data Law and the Guidelines or oppose the use of them in specific purposes.
Glisco, under the assumptions established in Article 34 of the Data Law, may deny access to personal data, make rectifications or cancellations, or grant opposition to the use of personal data.
Glisco, under the assumptions established in article 26 of the Data Law, will not be obligated to cancel the personal data of the holder.

The holder of the personal data can exercise the rights described above by submitting a duly signed request, either at the address of the person responsible or by email to the following address: cschvartzman@gliscopartners.com.
Glisco will respond to this request within a period not exceeding 20 (twenty) days in the same way in which the holder has made his request, by means of simple copies or electronically.

If Glisco denies the exercise of any of the rights of access, rectification, cancellation, or opposition granted by the Data Law or the Guidelines, Glisco must justify such refusals. The holder has the right to request the start of the procedure of protection of rights before the Federal Institute of Access to Information and Data Protection established in Chapter VII of the Data Law.
For more information, please contact the person in charge of processing personal data at (+52 55) 5243 4943.
If the holder does not authorize, revokes, or limits the processing of his/her personal data, it’s possible that Glisco may not be able to provide the benefits that the holder would otherwise have access too. Glisco may take the measures it deems appropriate in case the refusal, limitation to the processing and transmission of personal data, the exercise of the rights granted by the Data Law with respect to personal data or the revocation of their consent to this notice prevents, interrupts or in any way affects the processes and practices of Glisco.

V. The transfers of personal data 

Except for the stated below, and to those mentioned in article 37 of the Data Law, we undertake to not transfer personal data to third parties outside the corporate group to which Glisco belongs without the holder’s consent and to carry out the
transfer of information in the terms established by the Data Law. In any case, and without prejudice to the foregoing, in compliance with article 68 of the Data Law, Glisco will inform the holder of any transfer made involving his/her data. By accepting the terms of this privacy notice, the holder accepts all transfers of his/her data that might be made in compliance with the Data Law, Its regulations, and the Guidelines. If you do not agree with the possibility that your data may be transferred under different circumstances to those listed in article 37 of the Data Law, please communicate this opposition in accordance to the procedure established in the subsection III above.

To carry out the purposes established in this privacy notice, all information of suppliers and customers may be communicated within or outside of Mexico to comply with Glisco’s legal obligations, including but not limited to, fiscal information. Furthermore, Glisco may disclose the personal information of customers and suppliers to safeguard his rights and properties. We will be providing your information to third parties in charge of your processing (inside or outside of Mexico), to manage and process said information according to the purposes established in this privacy notice. Glisco may also share details with third parties (inside or outside of Mexico) such as auditors or legal advisors to obtain professional advice. All the tasks involving the process of information will be regulated by an agreement established by Glisco and said third party, in compliance with the applicable legal norms, and all your data protection rights will be respected in accordance with the current legislation, taking the necessary precautions to make sure that they are treated under the strictest security measures.

We could merge with or be acquired by another legal entity. To the extent permitted by law, and in accordance with the terms of this privacy notice, we may share information we have about customers and suppliers with the resulting entity.

VI. Procedure to be followed by the person responsible to communicate to the holders any changes to the privacy notice

Glisco reserves his right to make modifications or updates to this privacy notice at any time to comply with any legislative or jurisprudential reforms, internal policies, or new requirements. The updated version of the privacy notice that has been published will be the one applicable at all times.

These modifications will be made available to the public in our offices or, if needed, will be sent to the last email address provided by you.

If Glisco changes its identity, requires the collection of additional personal or financial data, changes the purposes for obtaining personal data or modifies the conditions of the transfers that may be made under the provisions of this privacy notice, Glisco will provide the holders with a new privacy notice.

VII. Sensitive personal data

Glisco does not collect sensible data from its clients or suppliers.

VII. Security measures implemented to protect the security of the databases 

For the protection of the personal data in the possession of Glisco, Glisco has implemented security measures that guarantee the confidentiality, integrity, and availability of such information, to prevent loss, misuse or alteration of said information.
When we communicate or share information with third parties, we require and verify that they have the necessary security measures to protect the personal data of the holder, prohibiting the use of your personal information for purposes other than those established in this Privacy Notice.