COMPREHENSIVE NOTICE OF PRIVACY FOR SUPPLIERS

In compliance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (hereinafter referred to as the “Law”) and its Regulations, this Privacy Notice is issued under the following terms:  

1.- IDENTITY AND ADDRESS OF THE CONTROLLER.

Inmobiliaria Buenaventuras, S.A. de C.V. (hereinafter referred to as “Inmobiliaria Buenaventuras”), is a business corporation that has been duly incorporated under Mexican law, with address at Av. Bonampak, Supermanzana 10, Manzana 2, Lote 7, Planta Baja, Torre “B”. Zip Code 77500, Cancun, Quintana Roo, Mexico. Inmobiliaria Buenaventuras is responsible for the use and protection of your personal data, which will be processed based on the principles of legality, consent, information, quality, purpose, loyalty, proportionality, and responsibility under the terms of the Law. To that end, we inform you as follows:  

2.- PERSONAL DATA TO BE COLLECTED AND SUBJECT TO PROCESSING.  

For the purposes outlined in this Privacy Notice, your data will be collected from the following sources: provided directly by you in person, via telephone, or through email.  

The personal data we obtain is as follows:

The data we collect:  

• Identification and Contact Data.- Full name, age, gender, address and data on the proof of address, telephone numbers, company where you work, nationality, social security number, Population Registration ID (CURP) or its equivalent for foreign nationals, email, Federal Taxpayer Registry (RFC) or its equivalent for foreign nationals, handwritten signature, official identification with photograph, migration documents, academic data, names of family members, and any other document that is essential for identifying you.
• ‍Legal information.- Legal powers granted to individuals who represent you or powers granted to you for representing individual and/or legal entities, articles of incorporation of legal entities, if applicable, proof of compliance with the National Workers’ Housing Fund Institute (INFONAVIT) and the Mexican Social Security Institute (IMSS), employer registration.
• ‍Financial, Asset-Related and Tax Data.- Data necessary for fulfilling a contractual relationship, such as: banking institution and branch names, bank account number(s), certificates of tax status, proof of tax status, proof of compliance with tax obligations

Inmobiliaria Buenaventuras may also collect data that the “Law” considers sensitive, which are listed below and will henceforth be understood as included within the term “Personal Data”.  

• Images for video surveillance purposes. Inmobiliaria Buenaventuras prioritizes security on its premises, which is why there is a video surveillance system to ensure the safety of the individuals who visit our facilities. This system will collect your personal image in equipment and servers operated under the strictest confidentiality. This data will be used solely for purposes related to maintaining the safety and well-being of all individuals.  

3.- PURPOSES OF PROCESSING YOUR DATA.

We use the personal data collected from you for the following purposes:  

a.- In the context of receiving individuals at the Inmobiliaria Buenaventuras facilities, the main purposes of processing personal data are:  

• To provide the necessary assistance during your visit to the Inmobiliaria Buenaventuras facilities.
• To verify your identity when registering at the Inmobiliaria Buenaventuras facilities.
• Video surveillance to maintain the safety of the individuals who visit our facilities.

b.- In the context of contractual management with our Suppliers, the main purposes of processing personal data are:  

• To create and keep the database of our Suppliers updated.
• Manage the Supplier selection and contracting process.
• Comply with the legal requirements applicable to this process.
• Confirm the identity of the Supplier and/or his legal representative.
• Receive and pay invoices and/or receipts for fees.
• Contract services.
• Ensure compliance with legal provisions on the prevention and identification of operations involving illicit resources, anti-corruption measures, and other applicable regulations through the implementation of administrative and technical procedures established for these purposes.
• Tendering processes.
• Analysis and investigation of commercial, financial, quality, security and liability aspects of the products and services offered.
• Management, control, administration, and updating of personal data related to suppliers (individual entities and legal representatives or contacts designated by legal entities).
• Compliance with supplier-related tax, labor and social security obligations.
• Video surveillance to maintain the safety of the individuals who visit our facilities.  

The above purposes are necessary for the initiation or continuation of the legal relationship between you and Inmobiliaria Buenaventuras. Additionally, you are hereby informed that the collected data will not be processed for purposes that are not strictly necessary.  

4.- TRANSFERS OF PERSONAL DATA.

The processed personal data may be transferred and handled by entities other than Inmobiliaria Buenaventuras. The recipients of such transfers are listed below:  

a). Parent companies, subsidiaries, or affiliates of Inmobiliaria Buenaventuras, for the purpose of safeguarding and consolidating information about our suppliers and visitors, managing our database by handling registration and removal of suppliers, and for conducting evaluations of contracted services.  

5.- CONSENT FOR THE TRANSFER OF DATA.

The data transfers referred to in the above subsection do not require your consent to be carried out, as provided by Article 37 of the Law.  

6.- ARCO RIGHTS (Access, Rectification, Cancellation or Opposition).

You, as owner of the Personal Data collected by Inmobiliaria Buenaventuras, have the right to request Access, Rectification, Cancellation or Opposition regarding any data you have provided to us. For further clarity, we provide the following definitions:  

Access.- The right you have to access your data and know which of them are being used in accordance with the purposes for which they were collected.  

Rectification.- The right you have to request correction or modification of your data if they are incorrect.  

Cancellation.- The right you have to request the deletion of your data from Inmobiliaria Buenaventuras’s database when you believe they are not being processed in accordance with this Privacy Notice or with the Law and its regulations. The cancellation request can apply to all your data or only some of it.  

Opposition.- The right you have to object to the processing of your Personal Data or to demand the cessation of its use.  

Exercising any of the aforementioned rights does not limit or exclude the possibility of exercising any of the others, nor is there a specific order of execution; therefore, the exercise of one right will not be a requirement for exercising the others. However, the Law establishes circumstances in which it will not be possible to comply with your request, particularly in the case of requests related to Opposition and/or Cancellation.  

You may submit your request to exercise your ARCO rights at any time and free of charge, either on your own behalf or through your legal representative. To do so, you must fill out the form called “ARCO Rights Request”. Download the ARCO Rights Request Form.

ARCO Rights requests may be submitted digitally via email sent to the address: datos@grupobd.mx  or physically in our offices, who will channel the request to the Personal Data Department. In both cases, the requests must contain the following information:  

• Your name, address, and the means through which we can inform you of the response to your request.
• The documents that verify your identity and that of your legal representative (official ID’s, power of attorney).
• A detailed description of the Personal Data you wish to subject to any of the aforementioned rights.
• Any additional information that will help locate your Personal Data.
• In the case of a request for rectification of data, the modifications to be made and the document supporting your request.  

Within a maximum period of 20 (twenty) business days from the date you made your request, Inmobiliaria Buenaventuras will send you a response through the means you specified in your request. If applicable, the approved resolution will be implemented within a maximum of 15 (fifteen) days from the date Inmobiliaria Buenaventuras communicated the response to you.  

In the case of requests for access to your Personal Data, these will be considered as duly completed when Inmobiliaria Buenaventuras makes the requested information available to you by any means or format.

ARCO Rights requests may be made by individuals other than yourself, provided that the designated person proves:  

• Your identity as the owner of the data that will be subject to the request.
• The identity of your legal representative.
• The existence of the legal representation, either through a public document, a power of attorney signed in the presence of two witnesses, or through your personal declaration.  

The request and delivery of the Personal Data will be free of charge; however, the requesting party will be required to cover the costs of shipping, certification, copies, or reproductions in other formats.  

As mentioned earlier, the Law establishes circumstances in which Inmobiliaria Buenaventuras may deny a request related to ARCO Rights. For more information on this, we suggest reviewing Article 34 (Thirty-Four) of the Federal Law on the Protection of Personal Data Held by Private Parties.  

For any questions regarding the processing of your Personal Data, contact the Personal Data Department of Inmobiliaria Buenaventuras via email at  datos@grupobd.mx or by calling (998) 272 8040 Ext. 5292 during business hours, Monday through Friday, from 9:00 a.m. to 1:00 p.m.

7.-USE OF COOKIES AND WEB BEACONS.

We hereby inform you that we do not collect personal data through the use of Cookies or Web Beacons and other technologies for obtaining personal information from you, such as the following:  

• Your type of browser and operating system.  
• The webpages you visit.  
• The links you follow.  
• The IP address.  
• The site you visited before entering ours.

8.- METHODS AND PROCEDURES FOR THE DATA OWNER, IF APPLICABLE, TO REVOKE HIS CONSENT AT ANY TIME.

You may, at any time, revoke the consent you have given to Inmobiliaria Buenaventuras for the processing of your Personal Data; however, you should be aware that revocation of consent for processing means the definitive cessation of the use of information essential for fulfilling obligations and rights derived from the legal relationship you have with Inmobiliaria Buenaventuras.

You may personally submit your revocation request via email to datos@grupobd.mx, indicating your name, attaching a copy of your official identification, and specifying the means through which we can inform you of the response to your request. You may also request it through your legal representative, provided that the designated person complies with the requirements for ARCO rights requests.

The timeframes, hours, and response mechanisms will be the same as those established for ARCO rights requests.

9.- OPTIONS AND METHODS FOR LIMITING THE USE AND DISCLOSURE OF YOUR PERSONAL DATA.

Inmobiliaria Buenaventuras will not use or disclose your personal data for purposes other than those strictly necessary for fulfilling the employment relationship between you and Inmobiliaria Buenaventuras, always in accordance with the guidelines described in this Privacy Notice. Consequently, you will receive essential documentation for maintaining the employment relationship, such as your pay slips.

Inmobiliaria Buenaventuras will not send you, either directly or through third parties, information or documentation for marketing, advertising, or commercial prospecting purposes. However, if you believe Inmobiliaria Buenaventuras is using or disclosing your Personal Data for purposes other than those described in this document, you may exercise any of the ARCO Rights of which you have previously been informed. Additionally, as general information, you are hereby informed that you have the following options to restrict the sending of unauthorized advertising:  

• Registration with the Public Registry to Avoid Publicity (REPEP), a registry managed by the Federal Consumer Protection Agency, aimed at ensuring that users’ data is not used for marketing or advertising purposes through phone calls and text messages.
• Registration with the Public Registry of Users, a registry that contains information about Users of the Mexican Financial System who do not wish to be bothered by advertising promotions from financial institutions.  

10.- SECURITY MEASURES IMPLEMENTED.

To protect your personal data, we have implemented administrative, physical, and technical security measures to prevent loss, misuse, or alteration of your information.  

When we communicate or share your information with third parties that provide us with services, we require and verify that they have the necessary security measures in place to protect your personal data, prohibiting the use of your personal information for purposes other than those established in this Privacy Notice. This is with the understanding that any non-compliance by such third parties with the provisions of the Law and its Regulations is the sole responsibility of those third parties.  

11.- MODIFICATIONS OF THE PRIVACY NOTICE.

We reserve the right to make modifications or updates to this Privacy Notice at any time.

These modifications which will be available on the website: https://www.grupobd.mx/privacidad  

12.- COMPLAINTS AND GRIEVANCES.

If you believe that your right to personal data protection has been violated or if you suspect that there has been a breach in the processing of your personal data in violation of the provisions set forth in the Federal Law on Protection of Personal Data Held by Private Parties or its Regulations, you may file a complaint or report with the National Institute for Transparency, Access to Information, and Protection of Personal Data (INAI). For more information, visit the website: https://home.inai.org.mx/.