INTEGRAL PRIVACY NOTICE
WINSNES DE MÉXICO S.A. DE C.V.

1. IDENTIFICATION OF THE RESPONSIBLE AND THE ONE IN CHARGE
2. FOR THE EFFECTS OF THIS NOTICE IT IS UNDERSTOOD:
3. PURPOSES AND / OR USES OF PERSONAL DATA
4. LIMITATION OF THE USE OR DISCLOSURE OF YOUR PERSONAL DATA
5. REVOCATION OF YOUR CONSENT FOR THE PROCESSING OF DATA
6. TRANSFER TO THIRD PARTIES OF YOUR PERSONAL INFORMATION
7. MODIFICATIONS TO THE PRIVACY NOTICE
8. RIGHTS OF THE PERSONAL DATA HOLDER

I.- IDENTIFICATION OF THE RESPONSIBLE AND THE ONE IN CHARGE:

IDENTIFICATION:

WINSNES DE MEXICO SA DE CV (BöRSE) with address located at Calle 5 No. 532A, Zona Industrial, Guadalajara, Jalisco, C.P. 44940; Has developed a privacy policy that we wish to help you understand the way in which your personal information is collected, used, transferred and stored, in accordance with Article 16 of the Constitution and in compliance with the Federal Law on the Protection of Personal Data in Possession of the Individuals. Therefore, we inform you that we are the Responsible for the treatment, use and protection of your Personal Data in our possession. In the exercise of this power, we have designated as the One In Charge of said treatment: ARA SOFTWARE DESING, S.A. DE C.V., with address in Paseo de la Reforma # 222, Tower 1, Floor 12-B, Col. Juárez, Delegation Cuauhtémoc, C.P. 06600, Mexico City. Which is responsible for processing your request to revoke the consent to the processing of your personal information or to exercise your ARCO rights at that address and telephone 01 (33) 36 15 65 09, or if you wish to contact him by e-mail can do so to: operaciones@vydp.org.

II.- FOR THE EFFECTS OF THIS NOTICE IT IS UNDERSTOOD:

PERSONAL INFORMATION:

Any information concerning an identified or identifiable natural person. We collect your personal data directly when you provide them to us by various means, in our facilities, by telephone, as when you participate in our promotions or when you give us information in order to provide a service or acquire our products.

APPLICABLE LEGISLATION:

Law: Federal Law for the Protection of Personal Data in Possession of Individuals. (LFPDPPP) Regulation: Regulation of the Federal Law for the Protection of Personal Data in Possession of Individuals. (RLFPDPPP).

PRINCIPLES AND DUTIES THAT GOVERN THE PROCESSING OF YOUR PERSONAL INFORMATION:

We collect your personal data for the purposes mentioned in this Privacy Notice, these will be treated observing the principles and duties embodied in the law which are: legality, consent, information, quality, purpose, loyalty, proportionality, responsibility, confidentiality and security.

SENSITIVE PERSONAL INFORMATION:

Those personal data that affect the most intimate sphere of its owner, or whose misuse may give rise to discrimination or entail a serious risk to it. In particular, those who can reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union affiliation, political opinions, sexual preference are considered sensitive.

PERSONAL FINANCIAL OR PATRIMONIAL DATA.

If your payment method is with a bank card, you will be asked for the following information, which in terms of article 8 of the Federal Law on the protection of personal data held by individuals, is considered within the category of personal financial data or Patrimonial: The name of the cardholder, the card number, the expiration date of the card and the name of the bank. The Law requires that in the event that the personal data collected includes sensitive or patrimonial and / or financial data, the Responsible carries out acts that collect and constitute the express consent of the holder as provided in the second paragraph of Article 8 of the Law and other applicable laws, either by signing the corresponding format, printed, or using electronic means, through direct answers, and their corresponding processes for the formation of consent, by way of example but not limited, by express consent and supply by the Holder of personal data.

TACIT AND EXPRESS CONSENT.

The Tacit consent results from events or acts that presuppose it. In such a way that in the absence of your refusal, we will take into account your consent in those terms. In terms of what is established in article 9 of the Federal Law on Protection of Personal Data in Possession of Individuals, you are asked for your express consent for the processing of sensitive personal, financial and property data, indicating whether or not you accept the treatment. Recalling that in terms of Article 1803 of the Federal Civil Code, consent is expressly stated orally, in writing or by unambiguous signs.

DURATION OF THE PROCESSING OF YOUR PERSONAL DATA.

Your personal information will be treated only for the necessary time in order to comply with the purposes described in the Privacy Notice that is made available to you and, where appropriate, in accordance with the provisions of the respective legal provisions. Notwithstanding any provision of this Privacy Notice, the www.vydp.org Owner acknowledges that consent will not be required for the processing of their personal data by the Responsible Party or third parties in any of the cases indicated in article 10 of the LFPDPPP.

SPECIAL DATA.

We know the importance of the protection of privacy and personal data, therefore the data of people with different abilities and seniors do not collect them without the prior consent of the tutor and in the case of minors without a prior consent by the parent or guardian, being able at any time to request the cancellation of personal data in accordance with the provisions of this notice.

III.- PURPOSES AND / OR USES OF PERSONAL DATA:

Your personal data will be used depending on the particular case in which they are provided or collected, always in accordance with this Privacy Notice or updates that, in turn, are made available to meet the following necessary purposes:

• If you are our client.
• If you are our supplier.
• If you work in our organization or are in the process of selection.
• By video surveillance within our facilities.
• For access to our facilities.
• On our website.
• In contracts with third parties.

By making this Privacy Notice available to the Holder and not expressing this opposition, it will be understood that the Holder grants the Responsible one his or her consent to carry out the processing of the Personal Data that has been provided and / or that due to Some of the purposes established in this notice provide in the future.

HOW WE COLLECT YOUR PERSONAL INFORMATION:

We collect personal data of the Holder by means of direct and / or personal delivery by any means of contact between the Holder and the Responsible Person or their Managers. You can also collect personal data indirectly through public access sources and other available sources allowed by law, such as telephone directories or public databases on the Internet and whose use will be for the purpose previously agreed upon.

THE PERSONAL DATA THAT WILL BE COLLECTED AND PROCESSED ARE:

(i) Identification data (including those derived from their own physical characteristics); (ii) contact information; (iii) patrimonial data; (iv) financial data; (v) academic data; and, (vi) labor data.

The investigations and actions that they deem necessary may be carried out in order to verify through any third party, dependence or authority, the veracity of the data that was provided.

Your Personal Data will be treated based on the principles and duties embodied in the law which are: lawfulness, consent, information, quality, purpose, loyalty, proportionality, responsibility, confidentiality and security. The confidentiality of your personal data will be maintained by establishing and maintaining the administrative, technical and physical security measures in an effective manner, in order to prevent damage, loss, alteration, destruction, use, access or undue disclosure.

1.- IF YOU ARE OUR CLIENT:

Your personal data will be used for the following purposes:

If you are our client or potential client: To comply with obligations derived from a commercial legal relationship that you have or will have, that is, provide the services and products required by you, to enforce and / or execute a contract, for statistical purposes, to inform about changes or new products or services that are related to the one contracted or acquired by our clients, to evaluate the quality of the service, to determine the quality of our products and services, to exchange information necessary to attend internal, external audits and by authorities, as well as for commercial, marketing, advertising and / or commercial prospection purposes and to grant benefits and comply with obligations contracted with our clients as well as conduct internal studies on consumer habits.

2.- IF YOU ARE OUR PROVIDER:

Your personal data will be used for the following purposes:

Those necessary for the commercial legal relationship with the Responsible, evaluate it and if necessary contract it in the future as a provider, and take control of our contracted suppliers and the payment of their services for later registration and administration in systems, make transfers with their personal data to third parties in terms of the privacy notice.

3.- IF YOU WORK IN OUR ORGANIZATION OR ARE IN SELECTION PROCESS.

Your personal data will be used for the following purposes:

To comply with the obligations arising from the employment relationship that is created with you, as well as for the administration of personnel; form employee records; form medical records of employees; payment and payroll administration; payment of benefits, salaries and benefits, bonuses, reimbursements, pensions, insurance and others; contracting insurance; document and control the allocation of computing and communications assets; internal audits; creation of a work email account; preparation of the company's directory; assign work tools; assign passwords and passwords, ensure compliance with confidentiality obligations and other labor obligations; verify personal and work references; contact their relatives, economic dependents and / or beneficiaries in case of emergency. Similarly, we inform you that we can make use of your personal data for other purposes, provided that such purposes are compatible and can be considered analogous to the previous ones.

4.- BY VIDEO SURVEILLANCE WITHIN OUR FACILITIES.

The images obtained by the video cameras that are located within our facilities are for your safety and that of all our visitors and collaborators through their supervision or permanent monitoring. Images are kept for a maximum of 60 days for security reasons, after which they are permanently erased.

5.- FOR ACCESS TO OUR FACILITIES.

To enter our facilities we request that you register in a log book what includes date, full name, name and department of the person you visit, time of entry, company that comes, time of departure and signature.

6.- ON OUR WEB SITE.

We inform you that on our website we use cookies, web beacons or other technologies, through which it is possible to monitor your behavior as an internet user, as well as provide you with a better service and experience when browsing our website. The personal data we collect through these technologies, we will use for statistical purposes, marketing and to facilitate the user faster access to the site. Site cookies are only associated with an anonymous user and their computer and do not provide references that allow the user's personal data to be deduced.

The personal data we obtain from these tracking technologies are the following: Identifiers, Language preferred by the user, region in which the user is located, type of user's browser, type of user's operating system, start date and time, and end of a session of a user, web pages visited by a user, searches made by a user, advertising reviewed by a user.

To know how these technologies can be disabled in the main browsers, see the following media:

Google Chrome

Select the Chrome menu icon > Select Settings > At the bottom of the page select Show advanced options > In the "Privacy" section, select Content settings > Select Do not allow site data to be saved > Select Done.

Internet Explorer

Click on the Tools button and then on Internet Options> Press or click on the Privacy tab> Settings> block all cookies and then click or click OK.

Safari

To set Safari cookie blocking in iOS 8, Settings> Safari> Block cookies and select Always block. In iOS 7 or earlier versions, select Never, Advertising and third parties or Always.

Firefox

Click the Menu button and choose Options> Select the Privacy panel> In Firefox you should: choose Use custom settings for the history> Uncheck the Accept cookies option to deactivate them> Close the page. Any changes you have made will be automatically saved.

For other types of browsers or versions, consult the help section in your browser.

7.- IN CONTRACTS WITH THIRD PARTIES.

In the elaboration of contracts with third parties, as in the case of leasing contracts and the rendering of professional services and others of a similar nature, we undertake to respect and give adequate treatment to the resulting personal information necessary when entering into such contract, in accordance with the provisions of the Federal Law on Protection of Personal Data in Possession of Individuals, taking into account the present privacy notice, without in any case expressing any negative opinion on the contents thereof, stating the express consent with the signing of the contract.

IV.- LIMITATION OF THE USE OR DISCLOSURE OF YOUR PERSONAL DATA:

If you wish to limit the use or disclosure of your personal information in our possession, the mechanism that has been implemented for the exercise of said rights is through the presentation of the respective request, by sending an email to the following address: operaciones@vydp.org with the subject:REQUEST FOR LIMITATION OR DISCLOSURE OF PERSONAL DATA and with the following information:.

• Name of the owner.
• Statement of facts.
• Owner address or email address to communicate response to request.
• Documents proving identity or personality to submit the application.

The documents to prove identity can be:

• Credential of the National Electoral Institute.
• Passport.
• National Military service card.
• Professional license.

The original document must be displayed for comparison; for the collation of the identity document, a prior appointment can be made at Paseo de la Reforma 222, Torre 1, Piso 12-B, Col. Juárez, Delegación Cuauhtémoc, C.P. 06600, Mexico City and / or at the Ara Software Desing branch closest to the owner.

In case the owner makes effective his limitation of the use or disclosure of his personal data through a representative, apart from the accreditation of the identity of both in the mentioned terms, we must identify the representation through the following means:

• Public instrument in which the representation is recorded;
• Power of attorney signed before two witnesses, or
• Declaration in appearance of the owner.

V.- REVOCATION OF YOUR CONSENT FOR THE PROCESSING OF DATA:

You have the right to revoke the consent you have given us for the processing of your personal information, either by tacit consent, or expressly and in writing. The mechanism that has been implemented is through the presentation of the respective request, sending an email to the following address: operaciones@vydp.org with the subject: REQUEST FOR REVOCATION OF CONSENT FOR THE PROCESSING OF PERSONAL DATA and with the following information:

• Name of the owner.
• Statement of facts.
• Owner address or email address to communicate response to request.
• Documents proving identity or personality to submit the application.

The documents to prove identity can be:

• Credential of the National Electoral Institute.
• Passport.
• National Military service card.
• Professional license.

The original document must be displayed for comparison; for the collation of the identity document, a prior appointment can be made at Paseo de la Reforma 222, Torre 1, Piso 12-B, Col. Juárez, Delegación Cuauhtémoc, C.P. 06600, Mexico City and / or at the Ara Software Desing branch closest to the owner.

In case the owner makes effective his limitation of the use or disclosure of his personal data through a representative, apart from the accreditation of the identity of both in the mentioned terms, we must identify the representation through the following means:

• Public instrument in which the representation is recorded;
• Power of attorney signed before two witnesses, or
• Declaration in appearance of the owner.

The deadline to address your request is 20 business days and we will inform you about the origin of the request through the means you provided to notify us.

VI.- TRANSFER TO THIRD PARTIES OF YOUR PERSONAL INFORMATION:

We promise not to transfer your personal information to third parties without your consent and taking into account the exceptions provided in article 37 of the Federal Law on Protection of Personal Data Held by Private Parties, as well as to make this transfer in the terms it sets that law.

Except in the cases of article 37 of the Law:

• When the transfer is foreseen in a Law or Treaty in which Mexico is a part.
• When the transfer is necessary for the prevention or medical diagnosis, the provision of health care, medical treatment or the management of health services.
• When the transfer is made to holding companies, subsidiaries or affiliates under the common control of the person in charge, or to a parent company or to any company of the same group as the person in charge who operates under the same internal processes and policies.
• When the transfer is necessary by virtue of a contract concluded or to be celebrated in the interest of the owner, by the person in charge and a third party.
• When the transfer is necessary or legally required to safeguard a public interest, or for the administration or administration of justice.
• CWhen the transfer is accurate for the recognition, exercise or defense of a right in a judicial process.
• When the transfer is necessary for the maintenance or fulfillment of a legal relationship between the responsible party and the owner.

We will only transfer your personal data to third parties, national or foreign, who are legally or commercially related to us to comply with the purposes described in the Privacy Notice and in their updates made available to you, so that we can transfer your personal data in the cases foreseen and authorized by the Law and in accordance with the following:

• To the Tax Administration Service, by virtue of the processes of issuing and sending Digital Tax Receipts over the Internet.
• To people affiliated and / or commercially related to us.
• To different authorities for the fulfillment of requirements or to include these in some type of legislation or regulations.

Your personal data will be processed only for the time necessary in order to comply with the purposes described in the Privacy Notice that is made available to you and, where applicable, in accordance with the provisions of the respective legal provisions.

VII.- MODIFICATIONS TO THE PRIVACY NOTICE

We reserve the right to make changes or updates to this privacy notice at any time, for the attention of new legislation, internal policies or new requirements for the provision or offering of our services or products.

These modifications will be available to the public through the following means:

• Visible ads in our establishments or customer service centers.
• Triptychs or brochures available in our establishments or customer service centers.
• On the website of our Personal Data Processing Manager (Privacy Notice Section).
• We will send them to the last email you have provided.

VIII.- RIGHTS OF THE PERSONAL DATA HOLDER:

You can exercise the rights of access, rectification, cancellation and opposition ("ARCO" rights) regarding your personal and / or sensitive data. Likewise, you can limit the use or disclosure of your personal data and revoke the consent that you have granted for the treatment of these, provided that the treatment is not a necessary treatment or that it results from a legal relationship.

ARCO RIGHTS CONSIST OF:

ACCESS.-

That you be informed of which of your personal data is contained in our system of personal data bases, what they are used for, the origin and the communications that have been made with them and, in general, the conditions and generalities of the treatment. The access obligation will be considered fulfilled when: The data is made available to the owner of the personal data or,

Through the issuance of simple copies, magnetic, optical, sound, visual, holographic, electronic documents or any other means or technology deemed appropriate.

RECTIFICATION.-

That your personal data be corrected or updated if they are inaccurate or incomplete.

CANCELLATION.-

That your personal data are canceled, totally or partially, from our database system. This request may give rise to a blocking period after which the deletion of the data will proceed.

OPPOSITION.-

Oppose for legitimate reasons the treatment of your personal data by our company.

If you wish to access the content of your personal data, rectify, cancel or oppose the use of the same, the mechanism that has been implemented for the exercise of these rights is through the submission of the respective request, by sending an email to the next adress: operaciones@vydp.org with the subject: APPLICATION FOR: ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION, (As applicable), and with the following information:

• Name of the owner.
• Statement of facts.
• Owner address or email address to communicate response to request.
• Documents proving identity or personality to submit the application.
• Documents proving identity or personality to submit the application.

The documents to prove identity can be:

• Credential of the National Electoral Institute.
• Passport.
• National Military service card.
• Professional license.

The original document must be displayed for comparison; for the collation of the identity document, a prior appointment can be made at Paseo de la Reforma 222, Torre 1, Piso 12-B, Col. Juárez, Delegación Cuauhtémoc, C.P. 06600, Mexico City and / or at the Ara Software Desing branch closest to the owner.
In case the owner makes effective his limitation of the use or disclosure of his personal data through a representative, apart from the accreditation of the identity of both in the mentioned terms, we must identify the representation through the following means:

• Public instrument stating the representation;
• Power of Attorney signed before two witnesses, or
• Declaration in appearance of the owner.
• Description of personal data on which an ARCO right is intended to be exercised.
• Any other element that allows the location of personal data and attention to the request.

If you consider that your right to protection of personal data has been damaged by any conduct of our employees or our actions or responses, or presumes that in the processing of your personal data there is a violation of the provisions of the Federal Law on Protection of Personal Data in Possession of Individuals, may file a complaint or complaint with the INAI, for more information visit: www.inai.org.mx.

The processing of your personal data under our possession will be done in accordance with these terms and conditions, so from this moment it is understood that you expressly authorize the Responsible and the Person in charge of processing your personal information for such purpose, even if you do not manifest your opposition by means of any of the elements indicated by the Law. For any matter relating to the processing of your personal information that has not been addressed in this Integral Privacy Notice, please contact the person in charge, whose information is at the beginning of the present document.