Privacy Statement for business and external relations

For Manuchar Internacional S.A. de C.V. ("Manuchar") it is of utmost importance to protect the privacy of all persons from whom we collect data. We treat and protect this data with the utmost care, in accordance with the laws of Mexico and those of the different countries where our parent companies, affiliates, and subsidiaries operate. We protect the data transmitted to us against loss, destruction, disclosure and unauthorized access or improper use.

In this privacy statement, we explain who we are, when or why we need your personal data, what personal data we collect, how and for how long we process it, to whom we may transfer it, what your rights are and how you can exercise them.

This privacy statement is addressed to you if:

- You are the contact person for one of our potential customers, suppliers or professional service providers;

- You are the contact person in an instance (company, authority, chambers of industry or commerce, federation and groups of employers or workers, schools, universities) with which we want to initiate or maintain a form of contact or collaboration.

- You are visiting this site.

If you choose to voluntarily provide information to us, we will use this information in accordance with this privacy statement.

1.1. What is personal data?

The FEDERAL LAW FOR THE PROTECTION OF PERSONAL DATA IN POSSESSION OF INDIVIDUALS ( LEY FEDERAL DE PROTECCIÓN DE DATOS PERSONALES EN POSESIÓN DE LOS PARTICULARES "LFPDPPP") defines in its Article 3 "Personal Data" as follows:

Personal data: Any information concerning an identified or identifiable natural person.

When this privacy statement refers to personal data, it refers to the definition of the LFPDPPP.

1.2. Who are we?

Manuchar Internacional SA de CV with address at Dr. José María Coss 401, Int. B y C., Colonia Monterrey Centro, Monterrey, C.P. 64000, Nuevo León, is responsible for the use and protection of the personal data that we will collect from you, regulated by LFPDPPP.

1.3. When do we collect your personal data?

We collect your data from the moment you provide it to us. This can occur by email, sms, by using our site, verbally (telephone, during a visit to your company, during an event, training, ...), by handing over your business card or in any other way. It can also occur when your company or organization indicates us to you as a contact person.

We may also collect your data if it is accessible to the public, or if you have published it yourself on social networks (e.g. LinkedIn) and if your publication could suggest that you are the right contact person to initiate a dialogue within the framework of our activities.

1.4. Why do we need your personal data?

We collect your personal data for the purposes stated below and will not use such data for other purposes without first notifying you and, if necessary, seeking your consent to do so.

We use your data within the framework of the presentation and execution of our business activities to you or your company or organization, for the presentation and execution of joint projects, partnerships, for the defense of Manuchar's interests or within the framework of the provision of services as a supplier or consultant on your behalf.

More specifically, we will use your personal data to, if applicable:

To be able to provide you with information about Manuchar's activities and better tailor it to your needs and interests and those of your company or organization.
Initiate a business relationship with your company or organization, close a deal and maintain a business agreement and facilitate its execution.
To be able to exchange information with you about the products and services we offer, including billing and related accounting treatment.
To contact you for commercial offers, newsletters, events, workshops and other Manuchar marketing and promotional activities that may be of interest to you.
To be able to contact you through your position in a public institution (authority, university, professional federation, ...) to defend Manuchar's interests.
To ensure and measure the quality of our services. To this end, we or a third party designated by us may ask you to participate in surveys and use and process the information obtained to improve the quality of our services.
To guarantee the security of the companies.
Meeting management objectives, including generating management information, performing internal controls for fraud prevention and performing audits (internal/external) and accounting controls.
Allow you to exercise your rights and then demonstrate that we have acted on the request to exercise those rights.

We use and process your personal data, depending on the type of processing, based on:

Our (pre)contractual relationship and all corresponding legal obligations of Manuchar: When we negotiate or conclude an agreement with you, your company, or organization, we need a certain amount of data about you or the persons involved from your company or organization in order to be able to present and comment on a suitable proposal, to be able to prepare this agreement, to draft it and to execute it correctly afterwards. If you do not want your personal data to be processed within this framework, it will be impossible for us to initiate or execute the provision of services.

The legitimate interest of Manuchar or a third party: if necessary, we use your data to satisfy the legitimate interests of Manuchar or a third party. This may be for example for the presentation and promotion of all services and/or informational messages that are in line with what you would reasonably expect to receive from us in the context of our existing or potential relationship. This may also occur in access controls or internal audits and controls to ensure the security and continuity of our systems and business. This legitimate interest is also present when we need to retain data in connection with the initiation, exercise or support of a legal action.
Your consent: by registering online, you give us your consent to process your personal data for information requests, complaints, among other purposes.

1.5. Which of your personal data do we use?

In the first instance, we use your personal data that is necessary for the proper conduct of our business activities: your first and last name, your position (title), your business address and your business contact details (telephone or mobile number and/or e-mail address). Some additional data (e.g. preferred language, department, ...) are not always necessary, but may be relevant in the context of the development of our business relationship or to adjust our services and business activities to your interests, wishes and needs.

There are also data that are completely optional and whose only purpose is to maintain a good personal relationship with you (e.g. your date of birth, hobbies, ...). If you choose to share this type of personal data with us, we may include it in our databases.

We urge you to always notify us as soon as possible of any changes to your personal information.

1.6. With whom do we share your personal data?

Manuchar may transfer some of your personal data only if it is necessary for the fulfillment of the purposes set out in point 1.3, the performance of the agreement between us, the fulfillment of a legal obligation (on the part of Manuchar or a third party) or the defense of a legitimate interest (of Manuchar or a third party):

To all other Manuchar group companies in order to, among other things:

Fulfillment of the objectives of our business relationship.
Internal services (administrative issues, service checks, invoicing, customer and supplier accounting, credit management, ...).
Promotions and marketing activities in connection with the provision of our services.
Information related to management.
Internal audits.
Internal services.
Investigation of individuals within the framework of the relevant legislation on financial sanctions.

To subcontractors and suppliers of Manuchar, for, among other things: the provision of services or the execution of tasks and assignments in the name and on behalf of Manuchar (e.g. IT providers, cloud service providers, research agencies, access security, ...).
To our internal auditors, audit and certification agencies, for, among other things:

The review of our annual accounts.
Obtain and retain certain certificates.
Audit of subsidy files.

To various government authorities in the framework of inspections and investigations, such as:

Federal and regional inspection and certification services.
Social security entities.
Authorities.

To all other third parties when we are required to do so by law, court order or judgment.

Manuchar does not sell, rent or make your personal data available to third parties for commercial purposes.

When our suppliers process your personal data on behalf of Manuchar, they act as data processors, as set out in the LFPDPPP. We make every effort to ensure that your personal data is sufficiently protected.

In certain exceptional cases, your personal data may be transferred outside of Mexico. In this case, Manuchar takes all contractual and technical security measures to ensure that all transferred personal data is adequately protected against loss or unlawful processing. For further questions you can consult our legal department.

1.7. How long do we keep your personal data?

Your personal data is retained for the time necessary to fulfill the purposes described in point 1.3 and to comply with legal obligations.

1.8. Safety measures?

Manuchar makes every effort to protect your personal data in the best way against unlawful use, by applying physical, administrative and technological measures.

For example: only authorized persons may access our office and systems and this access is limited to systems that they need for business purposes. These persons must be aware of and correctly apply our internal privacy and data protection policy. To the extent that data is transferred to third parties, Manuchar agrees with these third parties that they will ensure maximum data security.

1.9. What are your rights?

Manuchar treats your personal data in accordance with this privacy statement. As a data subject, you have a number of rights that you may exercise at any time.

You may exercise the following rights:

Right of opposition

You can object to the processing of your personal data. You may only object to data processing that is carried out on the basis of the legitimate interests of Manuchar or a third party (see above under 1.3). When exercising this right, you will need to indicate which specific processing you object to and on what specific grounds. This is necessary in order to determine the balance of interests. It is very easy to object to the use of your e-mail address for sending newsletters, promotions and marketing activities by Manuchar. Every email we send you in this regard always includes a link that allows you to unsubscribe.

Right of access

You may request confirmation as to whether or not your personal data is being used.

If so, you may have access to such personal data and may request the following information: the purposes of the processing, the categories of your personal data that we hold, the categories of recipients of such data, (third countries or international organizations), the retention periods or the criteria for determining them, your other rights, other sources of origin of your data and the existence of an automated decision-making process. In providing this information, we must always take into account the rights and freedoms of others.

Right of rectification (correcting and completing data)

You may request that we correct or supplement any information that you believe is incorrect or incomplete. When exercising this right, you will need to indicate which specific information you want corrected or supplemented.

Right to transferability

You have the right to request that Manuchar electronically transfer to you the personal data that you have provided to Manuchar (via an e-mail address provided by you) or to another data controller designated by you (via an e-mail address provided by you).

Right to data deletion (to be forgotten).

In the cases foreseen by LFPDPPP (Federal Law for the Protection of Personal Data in Possession of Individuals).

Right to limitation of processing.

You have the right to request the limitation of the processing of your personal data when:

You question the accuracy of your personal data (during the time it takes Manuchar to check it).
The processing of your personal data by Manuchar would be unlawful but you still do not want to invoke your right to data erasure.
You have objected to the processing of certain of your personal data (during the time that the balance of interests is checked).

Right to refuse or withdraw your consent.

To the extent that consent is based on prior consent, you have the right to withdraw such consent. The withdrawal of your consent does not influence the lawfulness of the processing of such data prior to the withdrawal or the lawfulness of the processing of (a number of) the same data for other reasons, as listed in point 1.3 of this privacy statement.

In principle, you can exercise your rights free of charge. You may do so by contacting us at legal@manuchar.com.mx.

At the latest within one month after receipt of your mail, we will inform you in writing about the follow-up we have given to your request. Depending on the complexity of your request or the number of requests we receive from other persons, this deadline may be extended by two months. In such a case, we will inform you in any way about this extension within one month of receiving your mail. In some cases (e.g. legal obligations, rights of other persons, deadlines) you may not be able to exercise your rights or you may not be able to exercise them in full. You will receive a notice with the reasons why we cannot or will not be able to fully comply with your request.

1.10. Questions, comments and complaints.

If you have any questions, comments or complaints about Manuchar's protection of your personal data or about this privacy statement, you can contact our personal data department at legal@manuchar.com.mx.