Personal Data obtained and treated by Gonzalez Calvillo.

• Identity Data

Name and surname, signature, photograph, full address, telephone, mobile phone, e-mail and Sole Code Population Registry (Clave Única de Registro de Población – CURP).

• Tax Data

Code and file of the Taxpayers Federal Registry (Registro Federal de Contribuyentes – RFC), as well as tax domicile and regime.

• Financial and estate Data

Beneficiary name, bank account number, Standardized Bank Account Code (CLABE), bank of origin, account numbers of several other services.

• Sensible personal data

Necessary data to represent clients or potential clients for the rendering of our services in past, present or potential civil, commercial, criminal, labor and/or administrative litigation, or related to alternative dispute resolutions in which they may have participated or are or may be participating. In order to comply with applicable law, we also collect significant information related to the preventing of transactions with illegal sources, such as information related to vulnerable activities.

• Personal data obtained from sources of public access, and received via a consented Transfer

Data obtained from public registries, directories, social networks, and other legal sources available at the market, as well as personal data shared to us by third parties previously authorized by the owner.

• Personal data obtained from social networks

Personal data and information shared in social networks (such as Facebook®, Twitter®, LinkedIn®, among others), including information shared as “public”, as provided in the terms of use, privacy policies and representations of any such networks.

The personal data described above is collected through: (i) direct and voluntary sharing of your information through our printed forms; (ii) direct and voluntary sharing of Personal Data during interviews or phone calls with our authorized staff; (iii) direct and voluntary sharing of Personal Data through the use of e-mail; and (iv) the use and access to public sources and other sources available at the market.

It is worth mentioning that the personal data described above may be evidenced in various documents, in printed or digital forms, such as copies of: official identification (voting card, Passports, temporary or permanent resident visa or driver license), tax returns, tax payers identification card, CURP, statements of account, proof of domicile, education cardex, IMSS receipts and/or labor skills certification (DC-3) issued by the Ministry of Labor and Social Prevention.

Gonzalez Calvillo does not collect nor treats Personal Data of minors or interdicts, unless shared by their parents, legal representatives, or tutors, as the case may be. In the event Gonzalez Calvillo, deems that Personal Data has been shared by a minor or an interdict in violation of this Notice, we will eliminate such Personal Data immediately. If you become aware that any such Personal Data has been furnished or shared by an individual under age eighteen (18), or by an interdict, please send us an e-mail to: protecciondedatos@gcsc.com.mx.

Purposes.

At Gonzalez Calvillo, we treat personal data with the purpose of carrying out and executing activities and actions to comply with the duties arisen out of the commercial and/or legal relationship established with them; specifically:

• We consider as primary purpose: (i) prepare service quotations; (ii) understand and attend your legal requirements and necessities; (iii) authenticate transactions through electronic means, (iv) render legal consulting and prepare requested legal documents corresponding to the practice areas of the Firm, (v) prepare a corporate file, (vi) issuing invoices and digital tax evidence, (vii) issuing proof of transactions, (viii) manage information to maintain our data base updated; (ix) assure your identity and verify furnished information; (x) contact you; (xi) allow management and security of personal data; and (xii) maintain procedural, electronic and physical personal data in terms of applicable laws and regulations, and comply with commercial, civil, administrative and tax legal requirements; and,

• We consider as secondary purpose: (i) manage customer service for our clients; (ii) manage notices related to our operations; (iii) attend information requests in respect of our services; (iv) attend comments, suggestions, claims and clarifications; (v) manage your transactional history with the Firm; (vi) manage delivery of communications, notices, alerts, news, events and marketing materials through printed, electronic, digital, physical or audio-voice means, unless you manifest your desire not to receive the same; and (vii) instrument activities to promote, maintain and improve our services.

Personal Data obtained and treated by Gonzalez Calvillo.

•  General Data

Name and surname, full address (personal or from work), preferred city to consume, e-mail (personal or from work) telephone (personal or from work), mobile phone (personal or from work) and signature.

• Tax Data

Code and file of the Taxpayers Federal Registry (Registro Federal de Contribuyentes – RFC), as well as tax domicile.

• Data linked to credit and/or debit cards

Name of the card’s beneficiary, card number, expiration date, type of card and/or statements of account.

• Sensible Personal Data

Gonzalez Calvillo does not obtain nor treats Sensible Personal Data from its suppliers, and if we were to obtain and process it, we will request the consent prior to any Treatment.

• Personal data obtained from sources of public access, and received via a consented Transfer

Data obtained from public registries, directories, social networks, and other legal sources available at the market, as well as personal data shared to us by third parties previously authorized by the owner.

• Third Party Personal Data

Identity data and contact information, including name, telephone number and/or mobile phone number and e-mail, to request commercial referrals, including information related to payment behavior and precedents.

The personal data described above is collected through: (i) direct and voluntary sharing of your information through our printed forms; (ii) direct and voluntary sharing of Personal Data during interviews or phone calls with our authorized staff; (iii) direct and voluntary sharing of Personal Data through the use of e-mail; and (iv) the use and access to public sources and other sources available at the market.

It is worth mentioning that the personal data described above may be evidenced in various documents, in printed or digital forms, such as copies of: official identification (voting card, Passports, temporary or permanent resident visa or driver license), tax returns, tax payers identification card, CURP, statements of account, proof of domicile, education cardex, IMSS receipts and/or labor skills certification (DC-3) issued by the Ministry of Labor and Social Prevention.

Gonzalez Calvillo does not collect nor treats Personal Data of minors or interdicts, unless shared by their parents, legal representatives, or tutors, as the case may be. In the event Gonzalez Calvillo, deems that Personal Data has been shared by a minor or an interdict in violation of this Notice, we will eliminate such Personal Data immediately. If you become aware that any such Personal Data has been furnished or shared by an individual under age eighteen (18), or by an interdict, please send us an e-mail to: protecciondedatos@gcsc.com.mx.

Purposes.

At Gonzalez Calvillo, we treat personal data with the purpose of carrying out and executing activities and actions to comply with the duties arisen out of the commercial and/or legal relationship established with them; specifically:

1. We deem as primary purpose: (i) to allow access to our premises; (ii) solicit, engage or cancel services; (iii) record you in our supplier data base; (iv) manage payment of services; (v) issue invoices and digital tax evidence; (vi) request service quotations and information; (vii) request the rendering of services; (viii) prepare a corporate file; (ix) allow management and security of your personal data; (x) maintain procedural, electronic and physical personal data in terms of applicable laws and regulations; and (xi) comply with applicable legal requirements; and,
2. We deem as secondary purpose, manage delivery of communications, notices, alerts, news, invitations, events, and marketing materials with a promotional, marketing, and commercial end.

Consent.

To collect, Treat and Transfer your Personal Data other than financial, patrimony or sensible data, you grant us a tacit consent by not objecting or opposing to the contents of this Notice within forty-eight (48) hours following it being made available by any means, including its publication in our website, and your data having been collected.

By executing a copy hereof, you manifest that: (i) this Notice has been made available to you by Gonzalez Calvillo, prior to collecting and/or Treating and/or Remitting your financial, patrimony or sensible Personal Data, (ii) you have read and understood the terms provided in this Notice, and (iii) you grant consent for us to collect, treat, remit and/or transfer your Personal Data.

Confidentiality.

In terms and for purposes of article 21 of the Federal Law to Protect Personal Data in Possession of Third Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares), Gonzalez Calvillo, hereby expressly acknowledges that all information and Personal Data that you share with or furnish to us or that we may obtain or have access to is confidential information, and thus we hereby agree to maintain and preserve indefinitely, and to cause our officers, employees and agents to maintain and preserve at all times and indefinitely any such information and Personal Data in strict confidentiality. The above in the understanding that this confidentiality obligation shall not apply in case the Personal Data and information was furnished to Gonzalez Calvillo, by a person authorized by you to disclose such information or obtained through publicly accessed sources or when we are required to disclose by law, judicial and/or administrative resolution.

Transfers.

In order to comply with its legal, contractual and/or labor obligations, Gonzalez Calvillo, may eventually be required to share your Personal Data with Third Parties with whom we have entered contracts. Such Third Parties are obliged in terms of the relevant contract to maintain confidentiality of any such Personal Data and to observe the provisions of this Notice.

In this regard, Gonzalez Calvillo, shall only request your consent when the Transfer is made for purposes other than those provided in article 37 of the Federal Law to Protect Personal Data in Possession of Third Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares).

With respect to employment candidates, employees and associates, Gonzalez Calvillo, may transfer Personal Data to affiliates for corporate management and profile and performance evaluations, in which case your consent will not be required since the relevant affiliates belong to the same corporate group that have and apply the same internal processes, control measures and policies in terms of the Statutes.

Procedure to exercise ARCO Rights, and to Revoke Consent.

At all times you have the right to access, rectify and cancel your personal data, as well as to oppose to its Treatment, or to revoke the consent for Treatment that you may have tacitly or expressly granted in respect of secondary purpose activities, whether directly or through a legal representative, and for such purposes you shall submit the relevant request—using the form furnished to you by our Privacy Officer—containing the following information and documentation:

• Full name, domicile or other information—such as an e-mail—so that we can attend and process your request;
• Documents with which you evidence your identity—digital or printed copy of your voting card, passport or visa, as the case may be—and if such is the case, documents evidencing the authority with which a legal representative acts on your behalf—digital or printed copy of a proxy letter duly signed by you before two witnesses, and that of the attorney in fact, with the corresponding official identifications (voting card, passport or visa);
• Clear and precise description of the Personal Data in respect of which you wish to exercise one or more ARCO rights; and
• Any other information or document that may help us locate your Personal Data.

In connection with requests related to the Right to Access Personal Data, Gonzalez Calvillo, shall deliver your information through the means selected by you in the request, prior confirmation of your identity and, in its case, the identity of your legal representative.

In connection with requests related to the Right to Rectify Personal Data, you shall indicate the modifications required to be performed, and furnish the documentation that supports the requested modification.

Gonzalez Calvillo, shall respond to you within twenty (20) Days following the date on which our Privacy Officer receives your access, rectification, cancellation or opposition request, at the most, so that, if valid, such request is made effective within fifteen (15) Days following the date on which we notify you through our Privacy Officer the response. In any event, Gonzalez Calvillo, shall respond through the means you selected in your request, or in its case, by any other mean agreed upon with you. The timeframes above may be extended for an equal period only once when and where the circumstances justify the extension.

Delivery of the Personal Data shall be free of cost, and you shall only be required to cover justified delivery expenses or the cost of reproducing documents. In the event you withdraw from a request within a twelve (12) months period, you shall cover the corresponding costs unless there are material amendments to our Privacy Notice that motivate new requests.

To receive, record, attend and respond your requests related to the exercise of ARCO rights and other provisions of the Statutes, our Privacy Officer is available at our offices located at the address provided in the Privacy Officer section below, or you may contact us through our website or by e-mail as indicated herein.

In the event that the information you furnish is erroneous or insufficient, or the documents referred to above are not enclosed or attached to your request, we may within five (5) Days following the date of receipt ask from you to furnish information and documents required to attend and complete your request. You have ten (10) Days following the date of receipt to respond to our request. In the event we do not receive response within such period, your request shall be deemed unsubmitted.

Privacy Officer.

For any questions or comments you may have on how we protect your Personal Data, please contact our Privacy Officer at our offices located in Montes Urales 632, 3rd Floor, Lomas de Chapultepec, 11000 Mexico City, or by e-mail to: protecciondedatos@gcsc.com.mx

Limitation on the Use and Disclosure of Information.

Gonzalez Calvillo shall keep your Personal Data during all time necessary to manage the relevant commercial or legal relationship, as well as to maintain the records required by the Statutes, the Regulations, and applicable commercial, tax, labor, and/or administrative laws.

All Personal Data collected by Gonzalez Calvillo, is protected by adequate administrative, technical and physical security protocols and measures, against damage, loss, alteration, destruction or use, access or unauthorized Treatment, in accordance with the provisions of the Statutes.

To limit the use and disclosure of your Personal Data, feel free to send an e-mail with your request to protecciondedatos@gcsc.com.mx.

Video Surveillance.

For all legal purposes that may arise, you are hereby notified that in order to protect your and our safety, and that of our staff, assets and work tools at Gonzalez Calvillo, there are certain spots within our premises in which video surveillance, closed-system cameras have been installed to monitor in real time and record the premises space to which such cameras are directed.

Amendments to the Privacy Notice.

Gonzalez Calvillo reserves the right to update and amend this Privacy Notice so as to reflect changes in our data privacy practices and policies derived from our continued process improvement, as well as changes to any laws, rules, and regulations. We invite you to periodically review the contents of our Privacy Notice in our website, in which we will publish any amendments and the date on which we last updated our Privacy Notice.