Privacy Policy

VIGEO HUMAN CAPITAL PRIVACY POLICY

By means of this privacy policy (hereinafter the “Policy”) and in accordance with the terms of Federal Law for the Protection of Personal Information Held by Private Parties, or the Ley Federal de Protección de Datos Personales en Posesión de los Particulares, (hereinafter the “Law”), VIGEO Capital Humano, S. de R.L. de C.V. discloses to its current, former, potential and direct or indirect clients and suppliers, to its former and current employees and to its website’s visitors (hereinafter, a “Data Owner”) its personal information protection policy.

VIGEO Capital Humano, with address in 38 Coscomate Street, Toriello Guerra, Tlalpan, Mexico City, 14050 will be responsible for the processing of the personal information it receives from any Data Owner.

In accordance with paragraph V of article 3 of the Law, any information concerning an identified or identifiable individual is considered as personal information. For the purposes of this Policy, any information regarding a Data Owner that VIGEO Capital Humano receives by any printed, digital, audible or visual means, remote or local means of electronic and/or optical communication or through any other technology, and which concerns to such person, will be considered as personal information (hereinafter the “Personal Information”), and includes information belonging to any (or several) of the following categories:

1. General      information of the Data Owner, such as full name, address, phone number,      e-mail address, civil status, occupation, place and date of birth, Federal      Taxpayer’s Registry number, Unique Population Registry Code, Voter ID      number, Passport number, migration status;
2. Curriculum      vitae of the Data Owner, which, besides the general information mentioned      in the previous paragraph, could include the information related to the      education, professional experience, salary expectations, and job search      status and availability, and
3. Positions,      faculties or designations of the Data Owner within one or more companies,      as well as the powers granted in favor of the Data Owner to act on the      name and/or on behalf of one natural person or legal entity.

VIGEO Capital Humano does not collect sensitive personal information of the Data Owner. However, if the case may arise, express and written consent of the Data Owner will be obtained for its processing.

The Personal Information will be used by VIGEO Capital Humano for the following purposes (the “Purposes”):

a) Establish communication between any Data Owner and VIGEO Capital Humano regarding the rendering of the services offered by VIGEO Capital Humano to the Data Owner or to a third party whether it is an individual or legal entity, as well as to prepare services proposals;

b) Generate drafts and/or final versions of communications and legal documents such as contracts, agreements, meetings of legal entities, powers of attorney, including the possibility that such Personal Information as well as the legal documents above mentioned could be transferred to one or more public notaries, authorities and/or law firms;

c) Prepare invoices, remissions or any other accounting or tax information which VIGEO Capital Humano is legally bound to prepare;

d) Review the information with the purpose of identifying if there are possibilities of entering a labor relation as an employee of VIGEO Capital Humano, or in its case to be transferred to third-parties that may be interested in the Data Owner’s profile with enrollment purposes and subject to the Data Owner’s consent.

e) Establish communication with the Data Owner concerning the services rendered by VIGEO Capital Humano and to assist any process related to the same.

f) Manage and coordinate the provision of goods and services by third party vendors, for the benefit of VIGEO Capital Humano’s clients, in accordance with contracts and/or agreements between VIGEO Capital Humano and its clients.

The sending of the Personal Information to VIGEO Capital Humano by any Data Owner through any of the means established previously in this Policy, implies his or her acceptance and authorization to the way in which VIGEO Capital Humano will use such Personal Information, which will be used for the Purposes above mentioned when necessary or convenient in the rendering of the advisory, consultancy, business and commercial management services performed by VIGEO Capital Humano from time to time, in relation to such Data Owner, as well as in connection with the subject matter that gave rise to the existing communication between VIGEO Capital Humano and the Data Owner, and vice versa.

The Purposes mentioned in this Policy are required for the existence and maintenance of a legal relationship between VIGEO Capital Humano and a Data Owner, and therefore the Data Owner’s refusal to the processing of his or her Personal Information in accordance with the aforementioned Purposes will make it impossible to establish a legal relationship between the Data Owner and VIGEO Capital Humano.

In case the Data Owner does not accept that his or her Personal Information may be processed according to any of the Purposes established in the previous paragraphs, including paragraphs b), d) and f) that entail the possibility of a transfer of the Personal Information to the third parties there mentioned, the Data Owner must contact VIGEO Capital Humano expressing his opinion via e-mail to fernando.vera@vigeo-hc.com, submitting an application in accordance with the procedure established in this Policy, and specifying which are the Purposes to which the processing of his Personal Information is denied, being subject to the consequences derived from such denial to the processing of his or her Personal Information according to the previous paragraph.

VIGEO Capital Humano is bound to:

1. Limit      the processing of the Personal Information to the Purposes set forth in      this Policy;
2. Maintain      strict confidentiality of the Personal Information and abstain from      transferring it to any person outside VIGEO Capital Humano, except for the      cases authorized by Law or by the Data Owner;
3. Establish      and maintain the administrative, technical and physical security measures      that are necessary to protect the Personal Information against damage,      loss, alteration, destruction or the unauthorized use, access or      processing,
4. Inform      to the third parties to whom the Personal Information of any Data Owner      may be transferred, in the applicable cases, about the existence of this      Policy and the Purposes for which the Data Owner agreed to the processing      of his Personal Information, and
5. Immediately      inform of any security violation occurred during the processing of the      Personal Information in order for the relevant Data Owners who provided it      to VIGEO Capital Humano to be able to take the corresponding measures for      the defense of their rights.

Each Data Owner is entitled to the ARCO rights (Access, Rectification, Cancellation and Opposition) set forth in Chapter II of the Law, as well as to the right to revoke the consent and the right to limit the use or disclosure of the Personal Information. For the exercise of any of these rights, the Data Owner must file an application before VIGEO Capital Humano, with the following information:

1. His or      her name and address or any other mean through which VIGEO Capital Humano      can communicate its answer;
2. The      documents that prove his or her identity or, in its case, the legal      representation of the person filing the application on his or her behalf;
3. The      clear and accurate description of the Personal Information over which he      or she wants to exercise any of the mentioned rights, and its relevant      scope, and
4. Any      other element or document that may assist in the localization of his or      her Personal Information.

In case of an application for rectification of Personal Information, in addition to the requirements set forth in the previous paragraph, the person submitting the application must indicate the modifications to be made, and provide the documentation that sustains his or her petition.

In case of an application for the revocation of the consent, in addition to the aforementioned requirements, the Data Owner will have to exhibit along with its application, a description of the reasons that originate such application, where he or she must specify whether a full or a partial revocation is being requested for the processing of his or her Personal Information.

The application, filed pursuant the aforementioned terms, will be examined by VIGEO Capital Humano and must be sent by e-mail to fernando.vera@vigeo-hc.com, or in writing to VIGEO Capital Humano’s domicile indicated in the second paragraph of this Policy.

VIGEO Capital Humano will have a maximum period of twenty business days, starting from the date in which the application is received, to notify the adopted decision, with the purpose of, if the application is deemed admitted, becoming effective within the fifteen days following the date in which the decision is notified.

The terms of this Policy can change at any time, thus VIGEO Capital Humano reserves the right to modify it when it is considered necessary. The modifications to this Policy will be published in VIGEO Capital Humano’s website, vigeo-hc.com, therefore it is the responsibility of the Data Owner to be attentive of the website in order to be informed about the changes.

Any complaint by the Data Owner due to a default from VIGEO Capital Humano to the Law can be filed before the Mexican Federal Institute for Access to Information and Protection of Personal Data; for more information visit home.inai.org.mx.