In accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, Grupo de Consultores en Cumplimiento de Delitos Financieros SA de CV ( "FINCCOM”) Makes the following privacy notice available to you.

FINCCOM, is responsible for the use and protection of your personal data, in this regard and in compliance with the legal obligations established in the Federal Law on Protection of Personal Data Held by Private Parties, through this instrument the holders of the data are informed, the information that is collected from them and the purposes that will be given to said information.

In addition to the foregoing, we inform you that FINCCOM, has its address located at:

Andador Huerto Olivos SMZ 1 MZ 1 Lt 3 Int 2, Ex Hacienda de Xalpa, Huehuetoca, Estado de México, CP 54680

The personal data that we collect from you will be used for the following purposes, which are necessary to specify our relationship with you as well as attend to the services and / or orders that you request:

Provide training, consulting and advisory services in the area of ​​Legal Compliance, prevention, detection and fight against Financial Crimes (operations with resources of illicit origin, financing of terrorism, bribery, corruption, international embargoes, sanctions, fiscal transparency, cybersecurity, fraud , ethics, conduct, new technologies, cryptocurrencies and other new technologies). Legal services, Accounting and Business Consulting, Entrepreneurship.

Strengthen the cooperation, communication and exchange of the Community FINCCOM, the nonprofit social work program of FINCCOM.

To achieve this end, we will use your data to inform you via email, telephone, social networks (Facebook, Twitter, LinkedIn, Instagram, and the like), WhatsApp or any other instant messaging provider, including SMS, about our services, events , courses, programs, workshops, meetings, conventions, talks or other events related to FINCCOM or the Community FINCCOM.

To carry out the purposes described in this privacy notice, we will use the following personal data:

Name, Surname, Telephone Number (mobile, office or any other similar), email, industry, position, company and opinions related to the events and / or programs of Grupo de Consultores en Cumplimiento de Delitos Financieros SA de CV, or your trade name: FINCCOM.

On the other hand, we inform you that your personal data will not be shared with any authority, company, organization or person other than us and will be used exclusively for the stated purposes.

You have the right at all times to know what personal data we have about you, what we use them for and the conditions of use we give them (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); likewise, you have the right to have your information removed from our records or databases when you consider that it is not being used properly (Cancellation); as well as to oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

To exercise any of the ARCO rights, the respective application must be submitted through the formats that will be available to you at:

Download the ARCO Format here

The foregoing will also serve to know the procedure and requirements for the exercise of ARCO rights.

The response to the request will be given in 4 business days. and it will be communicated as follows:

Through a phone call to the number included in the request.

The contact details of the person or department of personal data, which is in charge of processing requests for ARCO rights, are as follows:

Responsible name: Legal Area FINCCOM ®

Address: Huerto de los Olivos SMZ 1 MZ 1 Lt 3 Int 2, Ex Hacienda de Xalpa, Huehuetoca, State of Mexico, ZIP 54680

Telephone: +52 (55) 7610-4367

Email: legal@finccom.com

It is worth mentioning that at any time you can revoke your consent to the use of your personal data. In the same way, you can revoke the consent that, in your case, you have given us for the treatment of your personal data. However, it is important to keep in mind that not in all cases we will be able to attend to your request or end the use immediately, since it is possible that due to some legal obligation it is required to continue processing your personal data. Likewise, you must consider that for certain purposes, the revocation of your consent will imply that we cannot continue providing the service you requested, or the conclusion of your relationship with us.

To revoke the consent that you grant in this act or to limit its disclosure, the respective request must be submitted through the following email:

legal@finccom.com

In the same way, you can request the information to know the procedure and requirements for the revocation of consent, as well as limit the use and disclosure of your personal information, however, these requests must contain the following information:

Name, Surname, Telephone Number, Email. If applicable: Company, Address, Position, CURP.

The response to the request for revocation or limitation of disclosure of your data will be given no later than 4 business days and will be communicated as follows:

Through a phone call to the number included in the application, or via email.

This privacy notice may undergo modifications, changes or updates derived from new legal requirements; of our own needs for the products or services we offer; of our privacy practices; of changes in our business model, or for other reasons, for which, we are committed to keeping you informed about changes that may occur to this privacy notice, however, you can request information on whether it has undergone any change to through the following email:

legal@finccom.com

Last update:

9 / April / 2020


Privacy Notice for Employees


Grupo de Consultores en Cumplimiento de Delitos Financieros SA de CV (hereinafter “FINCCOM”) Respects privacy and is committed to protecting and keeping your personal data confidential, in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, its Regulations and the Guidelines of the current Privacy Notice, so we want to make sure that you know how we protect the personal data that is provided to us.

Derived from the above, and in order for you to have control and decision, we recommend that you carefully read the following privacy notice, which is available on our website. https://finccom.com/.

1. Identity and address of each person in charge:

The data of the entity that for the purposes of this privacy notice is responsible for you, as the owner of personal data, as appropriate, are the following:

Company name: Grupo de Consultores en Cumplimiento de Delitos Financieros SA de CV

Address: And Huerto de los Olivos, Mz 1, Lt3 Int 2, Fraccionamiento Ex Hacienda de Xalpa, Huehuetoca, CP 54680, State of Mexico, Mexico.

2. Principle of information:

You are informed that FINCCOM possesses, collects or will collect from you, the personal data necessary, mainly for the proper conduct of operations and provision of services, as well as for the celebration of other acts that may be carried out in accordance with the law and its bylaws. Said personal data may have been or may be obtained from you, either personally, or directly by any electronic, optical, sound, visual means, or through any other technology. Likewise, we may obtain personal data of which you are the owner, through third parties and from other sources permitted by law, such as credit information companies.

The personal data collected or that is collected includes those that are detailed below as well as those that the regulation applicable to FINCCOM requires you under its own corporate purpose:

  • Identification and contact information: full name, address, home, cell and / or work phone, marital status, signature, electronic signature, email, username and password, IP address, RFC, CURP, place and date of birth, age, gender, names of relatives, dependents and beneficiaries, as well as their addresses and dates of birth.
  • Labor data: occupation, position, area or department, address, telephone and work email, labor references, personal references and commercial references.
  • Financial or patrimonial data: movable and immovable property, credit history, income and expenses, bank accounts, insurance, afores, bonds and contracted services.
  • Sensitive personal data: race, complexion, religion and data on the current and future health status of the Owner, since these data may appear in any document that you provide us.

3. Purposes of the processing of personal data:

The processing of personal data will be that which is necessary, appropriate and relevant in relation to the purposes set out in this privacy notice. The person in charge will process the personal data collected, including especially those financial or patrimonial, as well as sensitive, where appropriate, in order to carry out the provision of your services in front of FINCCOM, as well as to comply with the contractual obligations of FINCCOM in front of you, as well as the celebration of the other acts that the person in charge can carry out in accordance with the applicable law and its bylaws.

The processing of personal data will be limited: (i) comply with the legislation applicable to FINCCOM for the identification, operation, and administration as well as to any requirement of the competent authorities, (ii) to fulfill the contractual obligations of FINCCOM in front of you, (iii) and carry out analysis and review of your credit history, as part of compliance with our internal and external policies as well as applicable regulations.

4. Data transfer:

To fulfill the purposes set out in this privacy notice, if FINCCOM would require transfer of personal data within and even outside the Republic of Mexico. FINCCOM undertakes to verify that all the legal principles of protection regarding the transfer of your personal data are complied with and states its commitment so that this privacy notice is respected at all times.

Derived from the foregoing, by virtue of this privacy notice, the owner accepts the transfer of their data, with the understanding that: (i) the person responsible intends to transfer the personal data to third-party nationals or foreigners, other than the person in charge, to whom said Responsible will communicate this privacy notice and the purposes to which the owner subjected their treatment; and (ii) the third party receiver will assume the same obligations that correspond to the person responsible or transmitter of the data, so the data will be processed in accordance with the provisions of this privacy notice.

National or international data transfers may be carried out without the consent of the owner, provided that the transfer: (i) is made to holding companies, subsidiaries or affiliates under the common control of the person in charge, or to a parent company or any company in the same group as the controller that operates under the same internal processes and policies and (ii) is required by virtue of a contract concluded or to be concluded in the interest of the owner, the controller and a third party.

5. Department of personal data:

FINCCOM as responsible for the treatment of your personal data designates the email legal@finccom.com through which the owners of the data may process requests for the exercise of the rights referred to in the Federal Law on Protection of Personal Data in Possession of Individuals (access, rectification, cancellation and opposition, as well as limitation to the use or disclosure of data and revocation of consent), which is available to the general public.

6. Means to exercise the rights of access, rectification, cancellation and opposition:

Subject to the provisions of the Federal Law on Protection of Personal Data Held by Individuals, as of January 6, 2012, the owner, by himself or through duly accredited legal representative, may exercise their rights of access, rectification, cancellation and opposition, formulating the respective request in the unique format called "Procedure for exercising ARCO rights" which is available on our website https://finccom.com/ for your consultation and use. The same must be sent through the email indicated in the preceding paragraph.

The exercise of any of them is not a prerequisite or prevents the exercise of another. For your knowledge, each of the aforementioned rights, respectively, allows you to: (i) Access your personal data held by FINCCOM, as well as knowing the Privacy Notice to which the treatment is subject. The person responsible will make the personal data available to them, or will issue simple copies, electronic documents or any other means.

The delivery of personal data will be free, the owner must cover only the justified shipping costs or the cost of reproduction in copies or other formats. Said right shall be exercised by the owner free of charge, upon accreditation of his identity before FINCCOM.

However, if the owner reiterates his request in a period of less than twelve months, the costs will not be greater than three days of the General Minimum Wage in force in Mexico City unless there are substantial modifications to the privacy notice that motivate new consultations. (ii) Rectify any of your personal data that is inaccurate or incomplete. (iii) Cancel your personal data. If the request is appropriate, personal data will enter the blocking period in which it cannot be processed. Once the data is canceled, the owner will be notified. (iv) Oppose at all times and for legitimate cause the processing of your personal data.

7. Options and means to exercise the rights to limit the use or disclosure of data and mechanisms and procedures to revoke consent:

You may also at any time: (i) choose to limit the use or disclosure of your personal data; or (ii) revoke your consent to process your personal data, with the understanding that all processing of personal data will be subject to the consent of its owner, except for the exceptions provided by the Federal Law on Protection of Personal Data Held by Individuals and its Regulations.

To exercise any of these rights, you must formulate the respective request through free writing, which must be submitted only through the electronic address indicated in this Privacy Notice and through which you will be given attention and / or response your request.

8 Consent:

By this means you consent, at the time of signing this Privacy Notice, in the treatment that FINCCOM will make your Personal Data and / or Sensitive Personal Data and / or Financial and Patrimonial Data, in the manner and for the purposes indicated in this notice and that they be transmitted to any member, company or subsidiary member of the group of FINCCOM in the terms indicated in this Privacy Notice.

9. Procedure and means by which changes to the privacy notice will be communicated:

FINCCOM reserves the right to make changes or modifications to this privacy notice at any time, whether for the attention of legislative, regulatory or jurisprudential developments, internal policies or market practices.

Any changes made to this privacy notice will be incorporated into it by FINCCOM and it will be released through our website https://finccom.com/