YOUR INFORMATION,
PROTECTED

DISTRIBUIDORA ORLI, S.A. DE C.V. (hereinafter referred to as the “CONTROLLER”), with registered address at Camino Real a Colima #315, Colonia Geovillas del Real, Tlaquepaque, Jalisco, Mexico, ZIP Code 45602, issues this Comprehensive Privacy Notice to any individual or legal entity with whom it maintains present or future legal and/or contractual relationships (hereinafter referred to as the “DATA SUBJECT”), in compliance with the provisions set forth in the Federal Law on the Protection of Personal Data Held by Private Parties (hereinafter the “Law”), and informs the following:

FIRST: PURPOSES.

The primary objectives of this Privacy Notice are, first, to inform the DATA SUBJECT that all personal data collected by the CONTROLLER will be handled in accordance with the principles established by the Law; and second, to make the DATA SUBJECT aware of the specific characteristics of the processing to which their personal data will be subject. The foregoing is intended to ensure that the DATA SUBJECT can make informed decisions regarding their personal information and exercise control over how it is used.

SECOND: PURPOSES

The primary purposes for which the CONTROLLER requires the DATA SUBJECT’s information are as follows:
1. To identify the DATA SUBJECT and verify their personal information and documentation.
2. To fulfill obligations arising from the existing or future legal and/or commercial relationship, including the issuance of necessary documents.
3. To communicate with the DATA SUBJECT regarding any matters derived from the legal relationship.
4. To provide services resulting from the legal and/or commercial relationship.
5. To consider relevant aspects for the development and/or termination of the existing or future legal and/or commercial relationship.
6. To implement security measures within the CONTROLLER’s facilities and processes involving the CONTROLLER and the DATA SUBJECT, to ensure a safe and controlled environment — including video surveillance and access control systems.

Additionally, the CONTROLLER may use the personal information collected for the following secondary purposes, which are not essential for the legal relationship but allow the CONTROLLER to act more effectively and respond in emergencies:

A. To contact your spouse, supervisor, or listed references in case of an emergency or urgent need.
B. To disclose your image, name, and, if applicable, academic and employment information for promotional, marketing, or commercial prospecting purposes, for your benefit and/or that of the CONTROLLER.

If you do not wish for your personal data to be used for the above secondary purposes, you may deny consent at any time by sending an email to our Privacy Officer (available at the CONTROLLER’s address or via the email address listed below), specifying which secondary purpose(s) you do not consent to. Refusal to allow secondary use of your data will not affect the continuation or execution of any existing or future legal or contractual relationship with the CONTROLLER. Please note that you have five business days to express your refusal.

To fulfill the purposes described in this Privacy Notice, the CONTROLLER may collect and process the following categories of personal data:

• Identification and contact information.
• Unique Population Registry Code (CURP)
• Reference contacts
• Academic background
• Employment information
• Tax and financial data
• Asset-related information
• Banking details (account number, bank name, interbank CLABE)
• Health-related information (only if necessary; considered sensitive personal data)

We also inform you that the CONTROLLER’s website uses cookies and/or web beacons to gather data about your browsing activity. These tools are managed by the CONTROLLER and third-party providers such as Google, AdRoll, and DoubleClick, to inform, optimize, and serve ads based on your previous visits to the website. The data collected does not include personally identifiable information such as your name, email, postal address, or phone number. You may disable cookies in your browser’s security settings if you do not wish your browsing data to be used for these purposes.

THIRD: DATA COLLECTION

The CONTROLLER may collect the DATA SUBJECT’s personal data in person or directly through electronic, optical, sound, visual, or any other technological means. Additionally, data may be obtained through third parties and other sources permitted by law. All such data will be treated as confidential information, and this obligation shall remain in force even after the relationship between the DATA SUBJECT and the CONTROLLER has ended. These personal data will not be disclosed to third parties without the DATA SUBJECT’s prior authorization.

FOURTH: DATA PROCESSING

The DATA SUBJECT’s personal information will be treated as confidential by the CONTROLLER, who implements the necessary security measures to prevent unauthorized alteration, loss, access, or processing. The DATA SUBJECT declares that the data provided are accurate, authentic, and complete, and assumes full responsibility for their veracity, thereby releasing the CONTROLLER from any related liability.

FIFTH: DATA AUTHENTICITY

The DATA SUBJECT is responsible for the accuracy, truthfulness, authenticity, and validity of the data provided. They have the right to access the personal data collected, to request corrections if the data are inaccurate or incomplete, to request the cancellation of the data when they are no longer required for the purposes set forth in this Privacy Notice, and to oppose the processing of their data or revoke any previously granted consent. These rights may be exercised through the procedures implemented by the CONTROLLER.

SIXTH: QUESTIONS AND COMMENTS

If you have any questions, comments, or wish to learn about the procedures, requirements, and timeframes established by the CONTROLLER for exercising your rights of access, rectification, cancellation, or objection (ARCO rights), as well as for revoking consent or limiting the use or disclosure of your personal data, you must contact the Privacy Officer assigned by the CONTROLLER. The officer is available at the address stated in the first paragraph of this Privacy Notice, or via the following email: info@orli.com

SEVENTH: DATA TRANSFER

Your personal data — including identification, contact, academic, employment, financial, and tax information — may be transferred to the following entities without the need for your express consent, as permitted by law:

• Authorities to whom we are legally required to provide such information, for the purpose of regulatory compliance.
• Related parties of the CONTROLLER.

Additionally, your personal data (excluding financial, sensitive, or asset-related data) may be transferred to the following third parties, in which case your express consent is required:

• Academic or non-academic institutions that issued your certificates, degrees, or diplomas, for the purpose of validation.

You may object to any data transfers that require your consent by sending an email to our Privacy Officer. If you do not express your refusal, we will understand that you have granted us your consent.

EIGHTH: ARCO RIGHTS AND REVOCATION OF CONSENT

In accordance with applicable regulations, you have the right to know what personal data we hold about you, how we use it, and the conditions under which we process it (Access). You also have the right to request the correction of your personal information if it is outdated, inaccurate, or incomplete (Rectification); to request its deletion from our records or databases if you believe it is being used in violation of applicable regulations (Cancellation); and to oppose the use of your data for specific purposes (Objection). These rights are collectively referred to as ARCO rights. Additionally, you have the right to revoke the consent you may have granted us for the processing of your personal data at any time, unless such revocation is not applicable under current law — a situation we will inform you of in our response to your request. To learn more about the procedures, requirements, and timelines for exercising your ARCO rights or revoking your consent, please contact our Privacy Officer via the email address provided above. If you wish to exercise any of these rights, you must submit your request to our Privacy Officer via email. They will process your request and address any comments, questions, or complaints you may have regarding the handling of your personal information. Our Privacy Officer will ensure the protection of your personal data at all times, in compliance with applicable regulations. We also inform you that Mexico’s Federal Institute for Access to Information and Data Protection (IFAI) is the authority responsible for overseeing compliance with the legal provisions on personal data protection.

NINTH: CHANGES

DISTRIBUIDORA ORLI, S.A. DE C.V. reserves the right to make changes to the terms of this Privacy Notice. Any modifications will be communicated in writing to the DATA SUBJECT at their address located at Camino Real a Colima No. 315, Geovillas del Real, Tlaquepaque, Jalisco, ZIP Code 45602; by phone at (33) 3268 0400; or via the following email address: info@orli.com

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