XAL DIGITAL, S.A. DE C.V., (from now on XD), with address at Jesús del Monte No. 41, 9th floor, Col. Jesús del Monte, Z.C. 52764, Huixquilucan, Estado de México, with telephone number +52 1 55 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 protecting your Personal Data, assuming the correct use, handling, storage, and confidentiality under the provisions of the Federal Law for the Protection of Personal Data in Possession of Individuals (from now on referred to as LFPDPPP, for its acronym in Spanish). The following Privacy Policy is issued to provide information regarding the main characteristics of the treatment to which your Personal Data will be subject.
1. What Personal Data will be subject to processing by XD as a customer?
During the process of contact and establishment of a business relationship with you as a Client, XD will collect the following data:
- Contact data: telephone number, e-mail, and position.
- Identification data: Name and company name of the legal entity; in case of an individual, its name and surname; address with its respective proof of address, nationality, and documents proving its incorporation, power of attorney, and identification of its legal representative.
- Invoicing information: its Tax Status Certificate, bank account, and Federal Taxpayers’ Registry.
Sensitive Personal Data.
XD informs you that, to comply with the purposes outlined in the Privacy Policy for the case of Clients, it is not required to collect sensitive Personal Data.
2. What Personal Data will be subject to treatment 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:
- Contact and identification data: names and surnames, personal address, telephone number, e-mail, nationality, and, if applicable, immigration status with the documents that accredit it, passport, citizenship, and photographs.
- Professional and academic data: information about the contents of the shared curriculum vitae, such as education and qualifications; previous employment records, such as payroll data, salary, bonuses, benefits, performance evaluations, and letters of recommendation (if applicable).
- Financial and compensation data: Proof of Tax Status, Federal Taxpayer Registry, and information for payroll and other benefits (if recruited).
Sensitive Personal Data.
XD informs you that, to comply with the purposes outlined in the Privacy Policy for the case of recruitment, XD may collect some of your sensitive Personal Data, such as your Marital Status, photographs, and, if applicable, medical information. In these cases, XD enabled a check box so that, under your express authorization and consent, it shows us that you agree and that we can collect such data.
3. Purposes of the treatment of your Personal Data.
XD collects your Personal Data to use for the following purposes:
a. To establish a commercial relationship.
b. To manage the business relationship.
c. Identify and contact candidates for possible employment with XD in recruitment cases.
d. To administer the contractual relationship, including all its technical, administrative, and accounting aspects.
e. To elaborate controls and statistics about the people who visit our website.
f. To answer the questions, you include them in the message box on the contact screen.
g. To contact you if you request it and channel you with commercial and/or technical areas, 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 Policy. XD may transfer your Personal Data to such entities only to comply with the purposes described in the Privacy Policy. It may also transfer them in the cases outlined in the LFPDPPP.
Also, in case of being recruited by XD, external service providers may obtain your information to offer their services to employees, for example, insurance companies. These external service providers must comply with the provisions of this Privacy Policy and the LFPDPPP.
For the two preceding paragraphs, XD enabled a check box so that, under your express authorization and consent, it serves to express 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 implemented as indicated in the Regulations of the LFPDPPP to protect and guarantee against damage, loss, alteration, destruction, or unauthorized use, access, or treatment. To ensure the appropriate security and confidentiality of your Personal Data, we implement 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 processing your Personal Data.
You have the right to exercise your ARCO rights to (i) Access your Personal Data in XD’s custody 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 five 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. 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 the following e-mail: privacidad@xaldigital.com accompanied by the following information and documents:
Your name, address, and e-mail address to inform you about the response to your request;
Copy of your ID, passport, or any other official identification.
A clear and precise description of the Personal Data on which you want to exercise any ARCO Rights.
If you need rectification of your Personal Data, you must indicate the modifications you require and 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 processing your Personal Data following the procedure mentioned for exercising your ARCO Rights.
The processing of personal data of owners who are residents or whose nationality is of a country belonging to the European Union will be under 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 facilitate your site visit 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 drive of the user’s computer equipment when browsing a specific Internet page; they allow the Internet server to remember some data about this user, among them, his preferences for viewing pages on that server, name, and password. 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 from the social networks facebook.com and Twitter can be added to our website. Facebook Inc. and Twitter Inc., respectively, provide the associated services. 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 the hiring of our services, you give us your consent to use your data for the purposes and scope provided above in this Privacy Policy.
10. Updates.
Any update of this Privacy Policy’s terms will be notified on our website so users can consult them.
Sincerely,
Xal Digital, S.A. de C.V.
Date of last update: March 2023.