XAL DIGITAL, S.A. DE C.V., (hereinafter XD), with address at Jesús del Monte No. 41, 9th floor, Col. Jesús del Monte, C.P. 52764, Huixquilucan, Estado de México, with telephone number +52 1 52 05 20 03, will act as Responsible for the data provided by clients and candidates for possible hiring in Mexico. XD is committed to the protection of your Personal Data, assuming the correct use, handling, storage and confidentiality in accordance with the provisions of the Federal Law for the Protection of Personal Data in Possession of Private Parties (hereinafter LFPDPPP). In order to provide you with information regarding the main characteristics of the treatment to which your Personal Data will be subjected, is why the following Privacy Notice is issued.
1. What Personal Data will be subject to processing by XD as a client?
During the process of contacting and establishing a business relationship with you, as a Client, XD will collect the following data:
(i) Contact data: telephone number, email address and position you hold.
(ii) Identification data: Name and corporate name of the legal entity; in the case of a natural person, its name and surname; address with its respective proof of address, nationality, as well as the documents evidencing its incorporation, power of attorney and identification of its legal representative.
(iii) Invoicing information: your Tax Status Certificate, your bank account and your Federal Taxpayers Registry.
a. Sensitive personal data.
XD informs you that, in order to comply with the purposes set forth in the Privacy Notice for Clients, it is not required to collect sensitive personal data.
2. What Personal Data will be subject to processing by XD as a candidate during a possible recruitment process?
During a possible recruitment process as a candidate to work in any XD vacancy, the following information will be collected:
(i) Contact and identification data: names and surnames, personal address, telephone number, e-mail address, nationality and, if applicable, immigration status with supporting documents, passport, citizenship and photograph.
(ii) Professional and academic data: information on the contents of the shared curriculum vitae, such as education and qualifications; previous employment history, such as payroll data, salary, bonuses, benefits, performance evaluations and letters of recommendation (if applicable).
(iii) Financial and compensation data: Proof of Tax Status, Federal Taxpayer Registry and information for payroll and other benefits (if recruited).
a. Sensitive Personal Data
XD informs you that, in order to comply with the purposes set forth in the Privacy Notice for the case of recruitment, XD may collect some of your sensitive personal data, such as your marital status, your photograph and, where appropriate, medical information. In these cases, XD enabled the box so that, under your express authorization and consent, serves to show us that you agree and that we can collect such data.
3. Purposes of the processing of your Personal Data
XD collects your personal data in order to use them for the following purposes:
a. To establish a business relationship.
b. To administer the business relationship.
c. In cases of recruitment, to identify and contact candidates for possible employment at XD.
d. To administer the contractual relationship, including all technical, d. administrative and accounting aspects.
e. To elaborate controls and statistics about the people who visit our web site.
f. To answer the questions that you include in the message box on the contact screen.
g. To contact you if you so request and channel you to the commercial and/or technical area, if applicable.
h. For marketing, advertising and commercial projection purposes.
4. Transfer of your Personal Data.
We inform you that your personal data may be transferred within and outside the country, to the following recipients and only for the purposes described in section 3: Affiliates, subsidiaries and / or the same group of XD, who also observe the same provisions contained in this Privacy Notice. XD may transfer your personal data to such entities only in order to comply with the purposes described in the Privacy Notice, and may also transfer them in the cases set forth in the LFPDPPP.
Also, in case of being recruited by XD, external service providers may obtain your information in order to offer their services to employees, for example, insurance companies. These third party service providers are required to comply with the provisions of this Privacy Notice, as well as the LFPDPPP.
For the two preceding paragraphs, XD enabled the checkbox so that, under your express authorization and consent, it serves to show us that you agree and that we can transfer such data.
XD will not collect your personal information for dissemination or sale to third parties for consumer marketing purposes, or to send mailings on behalf of third parties.
5. Means to limit the use or disclosure of your Personal Data.
We inform you that your personal data are safeguarded under strict administrative, technical and physical security measures which have been implemented as indicated in the Regulations of the LFPDPPP, in order to protect and guarantee against damage, loss, alteration, destruction or unauthorized use, access or treatment. In order to ensure adequate security and confidentiality of your personal data, we apply the following security measures: (a) Encryption of data in transit; (b) Secure user authentication controls; (c) Data repository.
6. ARCO rights and means to revoke consent for the processing of your Personal Data
You have the right to exercise your ARCO rights in order to (i) Access your personal data held by XD and know the details about the treatment we give them, (ii) Rectify them in case they are not accurate or incomplete, (iii) Cancel them in case you consider that they are not required for any of the purposes stated in this Notice, are being used for purposes for which we have not informed you, or because the contractual or service relationship with XD ended (the Holder will have 5 days, from the date of knowledge, to state what is appropriate), and (iv) Oppose and/or limit the processing of the same for specific purposes, as provided by law. In order to exercise your ARCO Rights, and to revoke your consent, you must submit a Request to the attention of the person responsible for the Personal Data at XD, to the Contact Address or to the following email: privacidad@xaldigital.com accompanied by the following information and documents:
a. Your name, address and e-mail address in order to inform you about the response to your request;
b. Copy of your IFE, passport or any other official identification.
c. A clear and precise description of the personal data on which you want to exercise any of the ARCO Rights.
d. In case you need a rectification of your personal data, you must indicate the modifications you require together with the documentation supporting your request.
The Responsible for Personal Data at XD will follow up on your ARCO Rights Request within the terms established by Law. Likewise, you may revoke your consent for the processing of your personal data following the same procedure mentioned for the exercise of your ARCO Rights.
The processing of personal data of data subjects who are residents or whose nationality is of a country belonging to the European Union, will be in accordance with the provisions of the General Data Protection Regulation of the European Union (“GDPR”).
7. Use of Cookies and other technologies.
The XD website automatically collects information about your access to our site, which is stored on our servers for internal purposes only. This may help us to facilitate your visit to our site and improve your online experience. Also, the use of cookies helps for statistical access purposes.
For these purposes, we may also use cookies and other technologies. Cookies” are text files that are automatically downloaded and stored on the hard disk of the user’s computer equipment when navigating on a specific Internet page; they allow the Internet server to remember some data about this user, among them, his preferences for the visualization of the sections on our web page. 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.
8. Use of Social Network “Plug-ins”.
Plug-ins of the social networks facebook.com and Twitter can be added to our website. The associated services are provided by the companies Facebook Inc. and Twitter Inc. respectively. For more information about their Privacy Policies, please visit the corresponding websites.
9. Consent.
By providing the data required by XD for your recruitment process or for the hiring of our services, you give us your consent to use your data for the purposes and scope provided above in this Privacy Notice.
10. Updates.
Any updates to the terms of this Privacy Notice, will be notified on our website so that users can consult them.
Sincerely,
Xal Digital, S.A. de C.V.
Date of last update: March 2023.