Customer Privacy Notice

In compliance with the provisions of the Federal Law for the Protection of Personal Data in Possession of Private Parties (hereinafter "the Law"), we wish to inform you of the following:

1. PERSON IN CHARGE OF THE PERSONAL DATA

GRUPO INVERSIÓN, S.A. DE C.V., (hereinafter "GIN"), indicating for the purposes of this Privacy Notice the address located at Reforma number 2608, 15th floor, Colonia Lomas Altas, Delegación Miguel Hidalgo, Postal Code 11950, Mexico City, will be responsible for the Personal Data provided by the individuals to whom such data corresponds (hereinafter "the Data Subject" or "the Data Subjects" indistinctly).

2. PERSONAL DATA REQUESTED FROM THE HOLDER

For the purposes indicated in this Privacy Notice, GIN may collect the personal data of the Data Owners who intend to contract or who contract any of the services, goods or products offered by GIN, such as: official identification (with photograph), full name, address, landline telephone, cell phone, fax number, email, nationality, date of birth, marital status, Federal Taxpayers Registry (RFC), Unique Population Registry Code (CURP), occupation or professional activity, bank account information and asset information (origin of income and expenses).

Likewise, only for Data Subjects interested in contracting any of the goods, products or services offered by GIN and who have performed or currently perform prominent public functions in a foreign country or in national territory (PPE) are also required the information corresponding to the function they perform or have performed and how long they have performed such function, data that due to their characteristics are treated by GIN as Sensitive Personal Data .

On the other hand, for those persons who are Beneficiaries of any of the goods, products or services contracted by a Data Subject with GIN, we inform them that the latter only requires their Personal Data corresponding to their full name, marital status, address, date of birth and relationship with the Data Subject, Personal Data of which the Beneficiaries are also Data Holders in terms of this Privacy Notice.

For those persons who are relatives (including Spouse) of a Data Subject interested in any of the goods, products or services offered by GIN and who perform or have performed prominent public functions in a foreign country or in national territory, they are informed that the latter only requires their personal data corresponding to full name, nationality, RFC, country of residence and relationship with the Data Subject who intends to contract GIN's Services (as such term is defined below) as well as their Sensitive Personal Data corresponding to the position they hold or have held and how long they have held such position, personal data and Sensitive Personal Data of which the former are Holders in terms of this Privacy Notice.

The Holders who intend to contract any of the goods, products or services offered by GIN and provide GIN with the personal data and/or Sensitive Personal Data of the Holders as Beneficiaries and/or of those persons with whom they are related and who perform or performed prominent public functions in a foreign country or in national territory shall notify the latter of having provided their personal data and/or Sensitive Personal Data to GIN and of the content of this Privacy Notice, The foregoing, regardless of the notification that GIN will make to such Data Controllers of the Privacy Notice at the first contact it has with the latter.

In terms of the provisions of Article 14 of the Regulations of the Law, when GIN does not inform the Data Controllers of this Privacy Notice directly or personally, but indirectly, the Data Controllers have a period of five (5) business days from the date the Privacy Notice was made available to them to express their opposition to the processing of their Personal Data intended to be used by GIN for purposes not necessary to fulfill a legal relationship with the latter, opposition that must be expressed in accordance with the provisions of section five (5) of this Privacy Notice, since, in the event that the Data Controllers do not express their opposition, it will be understood that they give their consent to GIN.

For the purposes of this Privacy Notice, Personal Data shall be understood as a whole as personal data and Sensitive Personal Data.

The Personal Data of the Data Subject may be collected in the following ways: i) when the Data Subject provides it personally or directly, ii) when GIN obtains it indirectly and iii) when it is obtained by GIN through the sources permitted by law.

It is the responsibility of the Data Subject to ensure that the data provided personally or directly to GIN is accurate and complete, as well as to notify GIN of any changes to such data in order to comply with the obligation to keep the information updated.

3. PURPOSES FOR WHICH PERSONAL DATA ARE COLLECTED

The Personal Data information collected by GIN from the Data Subjects who contract any of the services, goods or products offered by GIN, will be used as described below: (i) for the provision of the services, goods or products offered by GIN, (hereinafter the Services), (ii) identification of the Holders and knowledge of their profile in order to offer them a specific portfolio that suits their needs and financial interests, (iii) administration of the Services, (iv) analysis of the Services, v) opening of contracts in Financial Institutions, vi) updating of data, vii) having a link with the financial institutions where the investments of the Holders are located, viii) contacting the Holders to inform them about relevant news that may affect the financial market and therefore the investments of the Holders, ix) to personalize the content on the performance of the investment of the Holders, x) to request the authorization of the Holders for the acquisition of new products, xi) to monitor the withdrawals and deposits of the Holders in their investment contracts without intervening in such deposits and withdrawals, since only the Holder can intervene in such deposits and withdrawals , xii) to comply with the applicable provisions regarding money laundering, and xiv) to fill out the forms known as "Know Your Customer"; purposes that are necessary to comply with the obligations derived from the legal relationship that GIN has with the Data Controllers.
In relation to the Personal Data collected by GIN from those Data Subjects who are Beneficiaries in any of the Services contracted by a Data Subject with GIN, GIN informs them that the purposes for which the latter uses their Personal Data are only those necessary to comply with the legal relationship that GIN has with the Beneficiaries as a consequence of their designation as such, that is to say, identification of the Holders, updating the Personal Data of the Holders, complying with the provisions on money laundering and complying with the obligations that GIN has with the Holders in their capacity as Beneficiaries.

On the other hand, in relation to the Personal Data collected by GIN from those Data Subjects who are relatives (including Spouses) of a Data Subject interested in contracting or who contracts GIN's Services and who perform or have performed prominent public functions in a foreign country or in national territory, they are informed that the purposes for which GIN uses their Personal Data are only to identify the Data Subjects, to update the Personal Data of the Holders and to transmit their data in terms of section four (4) below, purposes necessary to comply with the applicable provisions on money laundering.

In relation to the Personal Data of those Data Subjects who in the past were clients of GIN and who currently are no longer clients, as well as of the Data Subjects who intend to contract any of the services, goods or products offered by GIN and who in the end do not contract them and of the Beneficiaries and/or relatives (who perform or have performed prominent public functions in a foreign country or in national territory) of such Data Controllers, are informed that GIN only keeps their Personal Data in accordance with the provisions of article 25 of the Law, that is, during the blocking period established in said legal ordinance, and therefore, once said blocking period has elapsed, their Personal Data will be deleted.

4. TEMPORALITY, REFERRALS AND TRANSFERS

The temporality of the handling of the Data Subject's Personal Data will depend on the relationship with GIN, as well as the obligations required by the legislation in force, the competent authorities and GIN's internal policies.

The information provided to GIN will be safeguarded, preserved and protected by the latter in accordance with the provisions of current legislation in order to maintain the confidentiality of such information.

In accordance with the provisions of the Law, GIN will give access to the Personal Data of the Data Controllers (through referrals) to those persons who have the character of Data Processors such as third parties, service providers, or business partners of GIN, who have a legal relationship with the latter, that derived from such legal relationship need to know the information and assume the commitment to keep it under a strict order of confidentiality and security, also acknowledging to know the terms and conditions of this Privacy Notice and committing to comply with them.

On the other hand, the Personal Data of the Data Controllers that contract any of the Services offered by GIN and of the Beneficiaries of such Data Controllers are transferred by GIN to financial institutions (banks and/or brokerage firms) in order to open stock brokerage contracts and comply with the applicable provisions on money laundering, transfers that do not require the consent of the Data Controller in accordance with the provisions of Article 37 of the Law.

With respect to the Personal Data of the relatives (including Spouses) of the Data Subjects interested in acquiring or who acquire any of the Services offered by GIN and who perform or have performed prominent public functions in a foreign country or in national territory, we inform you that GIN transfers their data to financial institutions (banks and/or brokerage firms) in order to comply with the applicable provisions on money laundering, transfers that do not require the consent of the Data Subjects in terms of Article 37 of the Law.

In the event that the Personal Data stored are required by an authority of any nature or must be delivered to the latter in accordance with the legislation in force, such data will be made available to it in strict compliance with the Law, a transfer that does not require the consent of the Holder in accordance with the provisions of article 37 of said legal ordinance.

5. RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION, OBJECTION, REVOCATION AND LIMITATION OF PERSONAL DATA

Data subjects shall have the right to request GIN to access, rectify, revoke, cancel or oppose, as well as to limit the use or disclosure of their data, by means of:

  1. Written request addressed to the Personal Data Department of GRUPO INVERSIÓN, S.A. DE C.V., at the following address: Reforma número 2608 piso 15, Colonia Lomas Altas, Delegación Miguel Hidalgo, Código Postal 11950, México Distrito Federal, from 10:00 a.m. to 5:00 p.m., on working days, or
  2. Request made to e-mail: administración-gin@ginversion.com.mx.

GIN will respond to the requests of the Data Subject, provided that any of the exceptions contained in the Law are not met, and the applicant complies with the provisions of Article 29 of said law, which establishes the requirements that must be contained in the requests submitted by the Data Subject. In order for GIN to process the request of a Data Subject regarding access, rectification, revocation, cancellation, opposition and/or limitation of the use or disclosure of his/her data, the latter must attach the following information and documentation to his/her request.

  1. Name of the Data Subject and address or other means for GIN to communicate the response to your request.
  2. The documents proving your identity or your personality in case of legal representation of the Holder (official identification of the holder or of the legal representative and power of attorney of the latter).
  3. The clear and precise description of the Personal Data with respect to which the right of access, rectification, revocation, cancellation, opposition, limitation of use or disclosure is sought to be exercised, as well as any other data or document that may facilitate the location of the Personal Data.

GIN will respond to a Data Subject's request for access, rectification, revocation, cancellation, opposition and/or limitation of use or disclosure of his/her data within the terms established by the Law, that is, within twenty (20) days after receiving the request from the Data Subject and in case the request is accepted, it will be implemented within 15 (fifteen) days after the response is communicated to the Data Subject, terms that may be extended by GIN in accordance with the provisions of Article 32 of the Law.

The obligation of access to information shall be deemed fulfilled by GIN when, in case it is requested by the Data Subject, simple copies of his/her Personal Data are made available to the latter at GIN's domicile within 15 (fifteen) business days after the response to his/her request is communicated to the Data Subject or through any of the means established in Article 33 of the Law, which shall be notified to the Data Subject in the response to his/her request.

MODIFICATIONS TO THE PRIVACY NOTICE

In the event that GIN, requires to use your Personal Data for purposes other than those agreed or agreed upon in the legal relationship it has with the Data Controllers and in this Privacy Notice or requires from the Data Controllers Personal Data other than those indicated in this Privacy Notice or intends to make transfers other than those indicated in this document, GIN will notify the Data Controllers in writing, by telephone, electronically, or by any optical, sound, visual or other means that technology allows now or in the future, explaining the new uses of such information in order to explain the new uses of such information, will notify the Data Subjects in writing, by telephone, electronically, or by any optical, sonorous, visual or other means that technology allows now or in the future, explaining the new uses it intends to give to such information in order to obtain their authorization. With this Privacy Notice, the Owners of the information are duly informed of the data collected from them and for what purposes as well as the fact that the Privacy Notice may be consulted at any time on the website of GIN www.ginversion.com.mx.

GIN reserves the right to modify this Privacy Notice to adapt it to new legislation or jurisprudence as well as business practices and criteria of authority. In such cases, the changes will be announced on the website www.ginversion.com.mx.

This Privacy Notice, as well as the general handling of the Law by GIN, is governed by the legislation in force and applicable in the United Mexican States, any controversy that may arise due to its application must be ventilated before the Federal Institute of Access to Information and Data Protection (IFAI) or before the competent Jurisdictional Bodies in Mexico City, Federal District.

Last updated August 28, 2013.

I consent and authorize my Personal Data to be processed in accordance with the terms and conditions of this Privacy Notice.

Politically Exposed Persons (PPE): Those individuals who perform or have performed prominent public functions in a foreign country or in national territory, including, among others, heads of state or government, political leaders, high-ranking government, judicial or military officials, senior executives of state-owned companies or important officials or members of political parties. The spouse, concubine, concubine and persons with whom they are related by consanguinity or affinity up to the second degree, as well as legal entities in which the EPP has patrimonial ties, are assimilated to the EPP.

Article 3 Section VI of the Federal Law for the Protection of Personal Data in Possession of Private Parties establishes that Sensitive Personal Data are those that affect the most intimate sphere of its owner, or whose improper use may give rise to discrimination or entail a serious risk to the owner. In particular, Sensitive Personal Data are considered those that may reveal aspects such as racial or ethnic origin, present or future health status, genetic information, religious, philosophical and moral beliefs, union membership, political opinions, sexual preferences.

Article 3 Section III of the Federal Law for the Protection of Personal Data in Possession of Private Parties establishes that Blocking is: The identification and preservation of personal data once the purpose for which they were collected has been fulfilled, for the sole purpose of determining possible liabilities in relation to their processing, until the legal or contractual statute of limitations period. During this period, personal data may not be processed and after this period, it will be cancelled in the corresponding database.

Article 3, Section IX of the Federal Law for the Protection of Personal Data in Possession of Individuals establishes that the Processor is: The individual or legal entity that alone or jointly with others processes personal data on behalf of the Controller.