Release Date: November 27^th, 2019.

Responsible for data processing.

Responsible for the processing of your personal data is the legal entity KARUM LATIN AMERICA, S. DE R L. DE C.V. (hereinafter “KARUM”) with address to hear and receive any type of notifications located in Avenida Patriotismo 229, Piso 8, Col. San Pedro de los Pinos, Benito Juárez, C.P. 03800, Mexico City, Mexico.

You can check this Privacy Notice on the website at any time: https://www.karum.com/aviso-de-privacidad and / or in our offices.

Services.

The main purpose for which KARUM processes your personal data is to provide you with those services derived from any service contract you sign with KARUM; any service related to the use of applications, software, websites and functionalities of your terminal equipment and / or any other services that you voluntarily decide to acquire (hereinafter and jointly referred to as the “Services”)

Categories of personal data subject to processing.

For the provision of our Services, and to comply with the purposes of the treatment indicated in this Privacy Notice, it is necessary that KARUM treat the following personal data:

Personal data resulting from the Services.

KARUM will process the following categories of personal data: identification and authentication data, contact data, property and / or financial data, tax data, demographic data, location data of your device, network and traffic data, and data about your preferences.

Children’s personal data

In general terms our website and the services we offer are not intended for minors. However, in the event that personal data of minors are obtained, used or stored, it will be done with the consent of their parents or guardians before the minor provides us with any personal data.

Indirect sources of obtaining personal data.

In those cases in which KARUM has a legitimation basis, it may obtain information linked to you through the following sources: (i) communications of personal data by affiliated companies (For the purposes of this Privacy Notice, affiliates means with respect to a given company any other company that, directly or indirectly, through one or more intermediaries has control, is controlled or is under the common control of the specified company), subsidiaries and / or control entities of KARUM (” Group Companies “); (ii) when third parties with whom KARUM has entered into commercial agreements provide you with information related to you, including credit information companies; and (iii) when the information comes from public access sources.

Obtaining information through the aforementioned sources helps us to improve the Services we provide, as well as to fulfill the primary and secondary purposes reported in this Privacy Notice.

Third-party personal data.

KARUM may process the personal identification and contact information of third parties when you provide us with this information so that said third parties are contacted in their capacity as personal references for collection fines and / or to carry out investigations and monitoring of newspapers regarding Your credit history, as well as to validate accurate information for you. By providing this information, you acknowledge having informed such third parties about the use of your data and having previously obtained their consent so that KARUM can treat them for the aforementioned fines.

KARUM may obtain identification and authentication data from third parties that the holder authorizes to perform on its behalf various procedures related to the Services. This data will be saved for possible purchases of Services.

Primary Treatment Purposes.

KARUM will treat the personal data described in this Notice to carry out some or all of the activities necessary for the development and fulfillment of the obligations that originate and derive from the Services that include the following purposes:

• Accredit and verify your identity in accordance with our procedures and policies, including the verification of your Voting Credential data and similarity of fingerprints before the National Electoral Institute.
• KARUM may contact you through telephone calls, sending communications through emails, short messages and other physical and / or electronic means of communication, as well as home visits. The foregoing, for any situation related to the use and management of the Services, as well as to inform you of any benefit to which a creditor has been made as a result thereof. Likewise, it will contact you and your contacts and / or references to validate the quality of the information provided and / or make collection efforts.
• Prepare analyzes and studies related to their consumption behavior, as well as periodic investigations and monitoring of their credit behavior.
• Perform billing activities and process payments through the forms and mechanisms enabled by KARUM, related to the use of the Services and / or goods and / or services provided by third parties.
• Management and offer of goods and / or services and / or own and / or third-party applications and / or Group Companies.
• Make reports, predictions and analysis in relation to the use and quality of the Services.
• Attend and follow up on investigations and reviews of complaints and / or claims related to the detection, prevention and combat of behaviors that could contravene the provisions of the applicable regulations and / or with the Services we offer.
• Comply with the obligation of cooperation with instances of security and justice in terms of the provisions of the applicable regulations, as well as the requirements of competent authorities in the cases provided by law.
• Maintain the security of electronic communications networks and services, detect failures or technical errors in the transmission of electronic communications, as well as any treatment that is necessary for the correct provision of services by KARUM.
• Generate and carry out dissociation procedures to generate segregated audiences for third parties, business partners and / or Group Companies to offer you products and services.

Secondary purposes of the treatment.

KARUM will process your personal data to carry out some or all of the secondary purposes mentioned below:

• Inform you of the launch or changes of new products, goods, services, promotions and / or offers of KARUM in accordance with your interests, as well as other Group Companies and / or business partners including telephone calls, sending communications through emails, short messages and other physical and / or electronic media.
• Perform treatments of massive data analysis techniques for profiling activities from combining information provided by you, obtained from public access sources, including social networks, and that information that can be inferred or obtained as a result of the application of Various data analysis technologies. The above to contact you and send you information of an advertising, promotional and / or informative nature that we consider may be of interest to you;
• Generate profiles and consumption habits so that our business partners can contact you and send you advertising, promotional and / or informative information that they consider of your interest and / or so that they can assess, according to their internal procedures, if you are able to obtain the service that you requested from said third party.

If you do not want KARUM to process your personal data for any of the purposes described in this section, please send an email to datospersonales@karum.com. You can change your option at any time.

It is important to keep in mind that, in case of granting your consent, this will still be valid even when the legal relationship between you and KARUM has ended, which means that KARUM may continue to process your personal data necessary to comply with these secondary purposes.

Transfers.

Not subject to consent

KARUM may transfer your personal data to both national and foreign entities, without requiring your consent in the following cases:

• Competent authorities and third parties in the cases provided by law.
• To the National Electoral Institute (INE) for validation and authentication of your identity, in accordance with the purposes described in this Privacy Notice.
• Financial, credit information, consolidation and insurance companies to guarantee compliance with the agreed obligations derived from the Services.
• The Group Companies so that they can contact you, directly or indirectly, to carry out promotional activities and / or offer products and / or services that these companies can market and / or provide jointly with KARUM or independent way. We inform you that the Group Companies operate under privacy policies that comply with the corresponding applicable provisions.
• To third parties that you authorize to be provided with information related to the Services.

It is necessary to obtain your consent

If you do not object, KARUM may transfer your personal data to business partners and / or third parties, including banking institutions so that they can contact you and offer you goods and / or services that are of your interest, or, so that they can determine if you is subject to acquiring the goods and / or services that said business partners and / or third parties offer.

If you do not want KARUM to carry out the reference transfer, please send an email to datospersonales@karum.com You can change your choice at any time.

Means and procedure to exercise ARCO Rights and / or revocation of consent for the processing of personal data.

You or your legal representative may exercise any of the rights of access, rectification, cancellation or opposition (hereinafter “ARCO Rights”), as well as revoke your consent to the processing of your personal data by sending an email to the Department of Personal Data from KARUM to the address datospersonales@karum.com where it will be attended in a timely manner.

Your request must be made through a request to the email address datospersonales@karum.com, it must contain:

• The name of the holder, email address and address or other means to communicate the response to your request;
• Documents proving identity or, where appropriate, the legal representation of the holder;
• The clear and precise description of the personal data regarding which one seeks to exercise any of the aforementioned rights; and Any other element or document that facilitates the location of personal data.
• In the case of rectification requests, the holder must indicate, in addition to the above, the modifications to be made and provide the documentation that supports the request.

The Department of Personal Data of KARUM will inform you of the determination adopted, within a maximum period of twenty (20) business days from the date on which the request was received, so that, if appropriate, it will be effective within the fifteen (15) business days following the communication of the response. The response will be given electronically to the email address specified in your request.

Options and means to limit the use or disclosure of your personal data.

You may limit the use or disclosure of your personal data by sending your request to the Department of Personal Data of KARUM at the address datospersonales@karum.com. The requirements to prove your identity, as well as the procedure to meet your request will be governed by the same criteria indicated in the previous section.

In the event that your request proceeds as appropriate, the Department of Personal Data of KARUM will register it in the list of KARUM’s own exclusion in order to stop receiving our promotions.

Cookies and/or web beacons.

Our website automatically collects non-personal information about the use of our site, which is stored on our servers for exclusively internal purposes, such as facilitating your visit to our site, improving your online experience or for statistical access purposes.

For the aforementioned purposes, we can also use cookies, web beacons and other technologies. “Cookies” are text files that are automatically downloaded and stored on the hard disk of the user’s computer equipment when browsing a specific Internet page; They allow the Internet server to remember some information about this user, including their preferences for viewing the pages on that server, name and password. Web beacons are images inserted in an Internet page or email, which can be used to monitor a visitor’s behavior, to store information about the user’s IP address, duration of interaction time on that page and the type of browser used, among others.

The “cookies” and web beacons will allow us to adapt a web page or advertisement to your interests and preferences. In most Internet browsers you can delete “cookies” from your computer’s hard drive, block them or receive a warning before a “cookie” is installed. Please refer to your browser instructions or help screen to learn more about how these technologies work and how to disable them.

KARUM Personal Data Department.

It is important to inform you that KARUM has a Department of Personal Data which, as part of its functions, has to answer any questions you may have regarding the use of your information. Likewise, the Department of Personal Data will follow up on any complaint or claim that you may have related to the processing of your personal information.

You can contact the Department of Personal Data of KARUM by sending an email to the following email address: datospersonales@karum.com.

Changes to this Privacy Notice.

KARUM reserves the right, in its sole discretion, to change, modify, add or remove portions of this Privacy Notice at any time. In this case, KARUM will keep its Integral Privacy Notice in force on the website https://www.karum.com/aviso-de-privacidad. We recommend that you visit this page periodically in order to inform yourself if any changes to the present occur.