PRIVACY NOTICE

This privacy notice hereinafter "THE NOTICE" is issued in compliance with the provisions of article 15 of the Federal Law on Protection of Personal Data Held by Private Parties hereinafter "THE LAW", and its correlatives of the Regulation of the Federal Law on Protection of Personal Data Held by Private Parties, hereinafter "THE REGULATION", and is made available to users who deliver personal data or information to ADO Y EMPRESAS COORDINADAS S.A. DE C.V., hereafter “ADO”.

  1. Responsible for the protection of your personal data

“ADO”, with address to receive notifications at Artilleros 123, Colonia 7 de Julio, Alcadía Venustiano Carranza, Zip Code 15390, Mexico City, Mexico; is responsible for the processing of your personal data.

"ADO" as the person responsible for the processing of personal data observes the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility, as established by "THE LAW".

  1. Form and means of contact

To contact us, you must submit a request written in Spanish, addressed to the "ADO" PERSONAL DATA PROTECTION OFFICE and send it in person or by mail to the following address: Artilleros 123, Colonia 7 de Julio, Alcaldía Venustiano Carranza, Zip Code 15390, Mexico City, Mexico, or by email to datos.personales@grupoado.com.mx

  1. Personal data and collecting sources

The personal data that we obtain from users to comply with the purposes described in this "NOTICE", are collected directly, when you provide them to us through our modules or ticket office, our website, mobile applications, attention, complaints and suggestions called "hola", by telephone, by email, instant messaging services, and when we obtain information through other public access sources permitted by "THE LAW" and "THE REGULATION".

The data we collect is the following:

  • Full name and surnames.
  • Date of birth.
  • Cell phone number.
  • Email.
  • Picture.
  • Gender.
  • Credentials or passwords for social networks or search engines (when you decide to register as a user of our technological tools through social networks or search engines).
  • Geographic location of the device generated through the use of services such as GPS (as long as you allow it).
  • Identification data of the AHORROBUS card.

In addition, since "THE LAW" allows other sources of obtaining information such as telephone and service directories, physical or electronic, the data that we can obtain are name and surname, telephone number, email and address.

3.1. Personal data of minors

"ADO" does not collects personal data from minors, for what you recognize that at the time of providing your data you are of legal age, have full legal capacity and have read this privacy notice. In the event that, as an exception, personal data of minors or persons with natural or legal incapacity established by law, such as name and age, are processed, these will not be collected or processed without the prior consent of the person. Parental authority, or guardianship or legal representation, in accordance with applicable laws.

If "ADO" identifies that a minor or person with natural or legal disability has provided their personal data without the consent of the person exerting their parental authority or their guardian or legal representative, or that due to human or technical error, they have been collected personal data from minors, or people with natural or legal disabilities, that personal data will be removed from the databases that contain as soon as they are known.

4. Purposes of processing personal data

Your personal data will be used for the following purposes:

Primary Purposes: Purposes that gave rise to and are necessary for the existence, maintenance and fulfillment of the legal relationship between you and "ADO":

  • The creation, update, customization, maintenance and authentication of your user account.
  • Keep you updated on the movements of your AHORROBUS card.
  • Attention to doubts, complaints, comments, suggestions, clarifications and follow-up on them.
  • Purposes of compliance with legal and regulatory obligations, as well as requirements of Federal, State or Municipal government or judicial authorities and/or regulatory entities.
  • To evaluate the quality of the service, generate profiles, carry out studies on consumption habits and preferences.
  • Identification and contact purposes.
  • Security purposes.

Secondary Purposes: Different purposes that do not give rise to the legal relationship between you and "ADO", but which are very useful to us to provide you with a better service and develop new products and services:

  • Statistical purposes.
  • Marketing and commercial prospecting purposes, which include offering our range of services, communicating promotions, offers, surveys, news, updates and events, research and development of functionalities, or any other activity for promotional, advertising or satisfaction purposes by of "ADO".

The provision of the services and/or the creation of an account it implies the full and unreserved consent of the users for the processing of their Personal Data in accordance with this Privacy Notice.

In case that you wish to express OPPOSITION to your personal data being processed for the purposes described above, you must submit a written request, in Spanish, to the following address: Artilleros 123, Colonia 7 de Julio, Alcaldía Venustiano Carranza, Zip Code 15390, Mexico City, Mexico, or to the email datos.personales@grupoado.com.mx, stating what purpose or secondary purposes it opposes.

5. Limitations on the use of data

You can limit the use or disclosure of your personal data by sending us a written request in Spanish, addressed to the “ADO” PERSONAL DATA PROTECTION OFFICE, to the email datos.personales@grupoado.com.mx or to the following address: Artilleros 123, Colonia 7 de Julio, Alcaldía Venustiano Carranza, Zip Code 15390, Mexico City, Mexico, where you mention your intention to limit the use or disclosure of your personal data and indicate necessary data such as: full name and surnames , simple copy of your valid and legible official identification, customer number (if you have one), telephone number and address or email.

In addition to the procedure contemplated in the previous paragraph, you can cancel your subscription to the emails that we send you for promotional, marketing and/or advertising purposes, by clicking on the link that accompanies each of said emails, which is located at the bottom of them.

6. ARCO Rights

You or your duly accredited legal representative may exercise, when appropriate, the rights of access, rectification, cancellation or opposition hereinafter "ARCO RIGHTS" that the "LAW" provides, through the mechanism described below; It is important to mention that the exercise of any of the "ARC RIGHTS" does not prevent the exercise of another right.

6.1. Mechanisms for the exercise of ARCO rights and the revocation of consent for the processing of your personal data.

The exercise of the "ARCO RIGHTS" as well as the revocation of your consent for the processing of your personal data will be carried out through the presentation of the respective request, which must be presented in writing and in Spanish by the owner of the personal data or your legal representative, in response to the PERSONAL DATA PROTECTION OFFICE OF "ADO" at the address Artilleros 123, Colonia 7 de Julio, Alcaldía Venustiano Carranza, Zip Code 15390, Mexico City, Mexico, (shipping costs will be borne by the applicant) or to the email datos.personales@grupoado.com.mx.

Your request must indicate your full name and surnames, a simple, legible and current copy of your official identification, in case of using electronic means, you must attach the digitized version of it (scan), email or address that you designate for notifications and some number contact telephone number If your request is submitted by your legal representative, you must additionally accompany your request, the official documents that prove said representation.

In case that the information provided in your application is wrong or insufficient to attend, or the corresponding accreditation documents are not attached, a request will be made within the five business days following receipt of your application, so that you provide the elements or documents necessary to process it. You will have a period of ten business days to meet said request, counted from the day after it was issued by the "ADO" PERSONAL DATA PROTECTION OFFICE. If you do not respond to said request within the period granted, your request will be deemed not submitted.

Once the requirements indicated above have been fulfilled, within a maximum period of twenty business days from the date of receipt of your request for "ARCO RIGHTS", as well as the revocation of the processing of personal data, the PERSONAL DATA PROTECTION OFFICE OF "ADO" will answer the origin of the same, by means of an email addressed to you at the email address that you have indicated in the request itself, or by sending a notification to the address that you have indicated for such purposes (the twenty days will be fulfilled at the time of delivering the notification to the postal service). If the request is appropriate, it will be effective within fifteen business days following the date on which the response on the origin of the request is communicated.

Once the requirements indicated above have been fulfilled, within a maximum period of twenty business days from the date of receipt of your request for "ARCO RIGHTS", as well as the revocation of the processing of personal data, the PERSONAL DATA PROTECTION OFFICE OF "ADO" will answer the origin of the same, by means of an email addressed to you at the email address that you have indicated in the request itself, or by sending a notification to the address that you have indicated for such purposes (the Twenty days will be fulfilled at the time of delivering the notification to the postal service). If the request is appropriate, it will be effective within fifteen business days following the date on which the response on the origin of the request is communicated.

7. Transfer of national and international personal data

Your personal data will not be transferred nationally or internationally to third parties without your consent, except for the provisions of article 37 of "THE LAW":

  • When the transfer is made between controlling companies, subsidiaries or affiliates under the common control of "ADO", or to a parent company or to any company of the same group of "ADO" that operates under the same internal processes and policies.
  • When the transfer is necessary for prevention or medical diagnosis, the provision of health care, medical treatment or the management of health services.
  • When the transfer is necessary by virtue of a contract entered into or to be entered into that is in your interest, by “ADO” and a third party, in order to grant you benefits.
  • When the transfer is necessary for the maintenance or fulfillment of a legal relationship between "ADO" and you, such as suppliers, chambers of commerce, among others.
  • When the transfer is necessary or legally required to safeguard a public interest, or for the administration or administration of justice, or when requested by competent authorities.

 

8. Information on the Internet

We inform you that we have electronic technologies (cookies and web beacons) on our website, so that when you access it, we receive information regarding your browser type and operating system, the web pages you have recently visited, the links you have recently followed, the IP address of your computer and the site you closed before coming to our web page.

You can disable or adjust the use of these technologies by following the procedures of the Internet browser you use to access our website.

8.1. Exclusion of liability of our website or application

When browsing or using our website or applications, you may find hyperlinks, links, banners, buttons owned by third parties that may request your personal data (hereinafter "Third Party Sites"). The personal data that you provide through these portals or Internet sites will be subject to the Privacy Notices displayed and applicable to these portals and Internet sites, therefore "ADO" will not be responsible for the use, publication, disclosure and/or or disclosure you make of your personal data through the aforementioned Third Party Sites. We recommend that users be careful and responsible about the personal information they provide on these sites.

9. Data retention

 "ADO" will keep your information for as long as it is needed for the purpose for which it was collected, unless you ask us to delete it, and, in such case, as long as "ADO" no longer has the need to keep it. your information for other reasons. “ADO” may keep your personal data for periods longer than those required by applicable law, if it is in our legitimate business interest and the law does not prohibit it.

Please note that where we have collected your personal information based on your consent and you withdraw that consent, or exercise your ARCO rights (to delete your personal information), we may keep your information blocked and available for as long as required to comply with the applicable laws and so that "ADO" complies with its responsibilities derived from the processing of your data.

10. Modifications to this privacy notice

"ADO" reserves the right to make changes or updates to this "NOTICE" at any time. The modifications that are made will be made available to users through one or more of the following means: via our website, mobile applications, via email to the most recent address we have for you, through posters, sound, video or personal recordings when visiting any of our facilities.

11. Definitions

For the purposes of this "NOTICE" the following is understood:

  1. Cookies: These are text files that are automatically downloaded and stored on the hard drive of the user's computer equipment when browsing a specific Internet page or portal, which allow the Internet server to store certain data, among them, information about your preferences and browsing patterns.
  2. Days: By provision of Article 3 in its section VII of the Federal Law on Protection of Personal Data Held by Private Parties, the terms and times stipulated in days will be counted in business days.
  3. ARCO Rights: These are the Rights of Access, Rectification, Cancellation and Opposition, enshrined in "THE LAW" which by its acronym forms said word.
  4. Law: Federal Law on the Protection of Personal Data Held by Private Parties published in the Official Gazette of the Federation on July 5, 2010.
  5. Regulations: Regulations of the Federal Law on Protection of Personal Data Held by Private Parties published in the Official Gazette of the Federation on December 21, 2011.
  6. Transfer: Any communication of personal data inside or outside of Mexican territory, made to a person other than the owner, the person in charge or the person in charge.
  7. Web beacons: It is an image used exclusively to quantify the number of visits or monitor user behavior.