Privacy notice

Responsible for the Processing of your Personal Data

TECHREO, S.A.P.I. DE C.V. (hereinafter, “techreo”), with address located at Av. Colonia Del Valle No. 165, First Floor, Col. Del Valle, C.P. 03100, Alcaldía Benito Juárez, Mexico City, will be responsible for collecting your personal data, the treatment given to them, as well as their protection. For this reason, techreo makes this privacy notice available to you (hereinafter, the “Privacy Notice”), in compliance with the provisions of articles 15, 16 and other correlatives of the Law Federal Protection of Personal Data Held by Private Parties and its respective regulations (hereinafter, the “Law”). The personal data that you (hereinafter, the “Owner”) provide to techreo, directly or through a third party duly authorized to do so, through electronic means, will be collected and processed by techreo in accordance with the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility, in terms of the provisions of the Law.

Personal data subject to processing

To carry out the purposes described in this Privacy Notice, the personal data of the Holder that will be collected and subject to treatment, will be the following:

1. The following Identification Data:
• Name(s) and surname(s)
• Address
• Date of birth
• Mobile (cell) phone number
• Personal email address
• CURP
2. Photograph of the face (selfie)

Use of the Platform

In addition, TECHREO may collect your IP address (number assigned to your computer when you use the Internet), in order to help diagnose problems related to the services provided, and related to the use and administration of the Platform . Your IP address will also be used to help identify the Owner within a particular session, as well as to collect general demographic and statistical information.

Personal data may be collected directly from the Owner at the time of registration and/or access to the mobile application (hereinafter, the “Platform”), so that the Owner can make use of the services provided by TECHREO. Additionally, the Platform may collect information from the Owner, constantly, without any additional notice.

TECHREO and/or its affiliates, subsidiaries, holding companies, associates and/or commission agents may, but will not be obliged to, carry out the investigations and actions they deem necessary, in order to verify, through any third party, dependency or authority, the veracity of the data that was provided to them, or the power to transfer them, as well as temporarily or permanently suspend the services to those users whose data could not be confirmed.

Sensitive Data

TECHREO will not collect sensitive personal data. Notwithstanding the foregoing, in the event that TECHREO requires the collection of sensitive personal data, it will request the express written consent of the Holder for its treatment.

Processing of Personal Data

1. Primary Purposes
   

   The Owner's personal data may be used, mainly, for any of the following purposes:

• Offer products and services, within which you can offer financial, educational and others in a personalized way and according to your particular needs through the Platform;
• Contact the user for any question related to the services offered by TECHREO;
• Contact the user in relation to the requests for ARCO Rights (as defined below) that he makes, as well as give due follow-up to them;
• Carry out and follow up on inquiries, investigations and/or reviews of the activities, operations, clarifications, complaints and/or claims of the Owner, related to any of the services provided by TECHREO;
• Comply with any applicable legal provision and/or requirement by any authority, if applicable.



The aforementioned purposes are necessary to provide you with the best user experience on the Platform, as well as for compliance with the obligations of TECHREO derived from the relationship with the Owner, so in the event that you do not accept the processing of your personal data, TECHREO will be unable to provide the services requested.

In addition to the above, it is understood that the processing of personal data will be that which is necessary, adequate and relevant in relation to the purposes set forth in this Privacy Notice, as well as those purposes that are compatible or complementary related to the services provided by TECHREO.

2. Secondary Purposes

In addition, TECHREO may use the Owner's personal data to, where appropriate:

• Notify you about new services and products;
• Report on outstanding initiatives;
• Communicate about changes in the products and services offered;
• Prepare studies and/or programs to determine consumption habits;
• Carry out periodic evaluations of products and services, in order to constantly evaluate and improve their quality.

In case you do not want personal data to be used for the aforementioned secondary purposes, you can send us an email to the email address sam@techreo.mx, stating that you do not want your personal data to be used for secondary purposes in accordance with this Privacy Notice.

The refusal to use personal data for the secondary purposes mentioned in the previous paragraph may not be a reason for us to deny you our services.

Data Transfer

TECHREO may transfer your personal data to third parties, national or foreign, when the transfer: (i) is provided for in any law or treaty to which Mexico is a party; (ii) is made to holding companies, subsidiaries or affiliates under the common control of TECHREO, to a parent company or to its associates; (iii) is necessary by virtue of a contract entered into or to be entered into, in the interest of the Owner, by TECHREO and a third party, or by the Owner and a third party; (iv) is necessary or legally required to safeguard a public interest, or for the procurement or administration of justice; (v) is necessary for the recognition, exercise or defense of a right in a judicial process, and (vi) is necessary for the maintenance or fulfillment of a legal relationship between the Owner and TECHREO. In any other case, TECHREO will require authorization from the Owner to carry out the data transfer that is necessary for the provision of the requested services.

Use of Cookies

We inform you that on the Platform we use Cookies (small files that are installed on the hard drive, with a limited duration in time that help to personalize the services), web beacons and other technologies similar to these, through the which it is possible to monitor your behavior as an internet user, as well as provide you with a better service and user experience when browsing the Platform. The Owner can deactivate the saving of cookies in his browser, delete them or manage their use through the configuration of his browser at any time, with the understanding that said actions could cause a deficiency in the performance and/or operation of the Platform. , derived from the fact that it offers certain functionalities that are only available through the use of Cookies.

ARCO Rights

The Owner has the right to access, rectify, and/or cancel the personal data that TECHREO has collected, as well as to oppose its treatment in whole or in part (hereinafter, the “ARCO Rights”). For the purpose of the foregoing, the Owner must send via email, addressed to the in charge of personal data protection: Karen Fernanda Núñez Blancas, to the address sam@techreo.mx, the respective request, which must contain, at least, the following: (i) full name and email of the Owner to communicate the response; (ii) copy of the document that proves the identity of it or, where appropriate, the legal representation of the Holder; (iii) the description of the personal data of which one seeks to exercise any of the ARCO Rights; (iv) any other element that facilitates the location of personal data; (v) the ARCO Rights that she intends to exercise, and (vi) a brief statement of the motives or reasons why she intends to exercise the corresponding ARCO Rights. Once this is done, TECHREO will notify you of the corresponding response, within a period of 20 (twenty) business days following the submission of your request. The cancellation of your data will be subject to the provisions of the Law.

Revocation of Consent

The Owner may revoke their consent for the processing of their personal data, as well as oppose their processing for secondary purposes, for which they must send the respective request via email to the address sam@techreo.mx, accompanied by the information and documentation mentioned in the previous section under the heading "ARCO Rights". Notwithstanding the foregoing, it is important that you take into account that, for certain purposes, the revocation of your consent could imply that TECHREO is not in a position to continue providing the service you requested, or the conclusion of your relationship with TECHREO. Likewise, you must consider that not in all cases we will be able to attend to your request or stop the use immediately, derived from the possibility that due to some legal obligation it is required to continue processing your personal data for an additional period of time.

Limiting the use or disclosure of personal data

The Owner may limit the use and/or disclosure of their personal data, including, without limitation, their refusal to receive communications and promotions from TECHREO, through any of the following means: (i) written request in accordance with the procedure described in the section called "ARCO Rights" of this Privacy Notice, or (ii) by registering in the Public Registry to Avoid Publicity in charge of the Federal Consumer Attorney's Office (PROFECO) and/or in the Public Registry of Users by the National Commission for the Protection and Defense of Users of Financial Services (CONDUSEF), in order that your personal data is not used to receive advertising or promotions from companies of goods or services. For more information on these records, consult the internet portal of PROFECO and/or CONDUSEF, or contact the corresponding agency directly.

Modifications to Privacy Notice

TECHREO reserves the right to make changes and modifications to this Privacy Notice at any time, in which case it will communicate them to the Owner through the Platform, or by email to the address provided by the Owner. The Holder will have a period of 10 (ten) business days from the publication of the modifications on the Platform or, where appropriate, from the receipt of the respective email, to express any objection or disagreement to said modifications.

Any questions or comments regarding this Privacy Notice, as well as the exercise of any other rights that correspond to you by virtue of the Law, should be addressed to the person in charge of Privacy Notices of TECHREO at the email address sam@techreo.mx. In addition, you can contact the customer service area in the Contact section located on the Platform for any questions or clarifications.

Notwithstanding the foregoing, in the event that you consider that your right to the protection of your personal data has been injured by any conduct or omission on our part, or you presume any violation of the provisions set forth in the Law, you may go to the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI). For more information, we suggest you visit their official website www.inai.org.mx. This Privacy Notice is available to you on the Platform and at the internet address techreo.mx

The Owner consents that their personal data be processed for the purposes and in accordance with the guidelines contained in this Privacy Notice.

Last update date 01/14/2022