PRIVACY

NOTICE

MONEYTRAX CENTRO CAMBIARIO S.A. DE C.V. PRIVACY NOTICE

RESPONSIBLE FOR THE PROTECTION OF YOUR PERSONAL DATA.

MONEYTRAX CENTRO CAMBIARIO S.A. DE C.V. («MONEYTRAX«) is a Mexican corporation duly incorporated under the terms established and regulated by the Laws of the United Mexican States. Domiciled at: Avenida Tamaulipas number 150, Colonia Hipódromo, Alcaldía Cuauhtémoc, C.P. 06100, in Mexico City. Telephone: 55 5521 9591; is committed to the protection of your personal data in accordance with the provisions of the Federal Law on the Protection of Personal Data in Possession of Private Parties («The Law») and other applicable provisions, as it is responsible for its use, handling and confidentiality, and in this regard expressly informs you of the following:

PERSONAL DATA THAT WILL BE SUBJECT TO PROCESSING.

For the purposes indicated in this Privacy Notice, we may collect your personal data by any of the means listed below:

When you provide them directly to us.
When you visit our Site on the world wide web called the Internet.
When you use any type of mobile application developed or used by MONEYTRAX in addition to the programs, products and services it provides.
When information is obtained through other sources that are permitted by law.

To carry out the purposes described in this Privacy Notice, MONEYTRAX will use the following Personal Data:

Identification Data: Name(s) and Surname(s).
Address data: street, number, neighborhood, delegation, zip code, city and state.
Contact Details: Telephone (home, office, or mobile device) and Email.
Documentary information: Official Identifications (credential issued by the INE, passport, professional license), proof of address, Federal Taxpayers Registry (R.F.C.) card, ID card containing the Unique Population Registry Code (CURP).
Occupational data: line of business and/or commercial, labor, professional and/or business activity.
Academic Data and Employment Data.
Personal References.

MONEYTRAX will collect the following Economic, Financial and Patrimonial Data that are considered as sensitive personal data that require special protection:

Identification Data of Accounts opened with Financial Institutions.
Information contained in Customer Identification Forms.
Physical characteristics and biometric data: As part of the security measures that MONEYTRAX implements in each of its branches or applications, it will take video recording, with or without sound, during the hours when the branches or applications are open for public access. The images and/or sounds that may be captured by the video surveillance cameras will be used to safeguard the safety of the Customers and the people who work in the branches or offices. Additionally, biometric data may be requested for entry or permanence in the same according to technological advances and the improvement in the security systems of branches or applications.
Full identification of the origin of the resources for carrying out operations.
Inquiries in Credit Information Societies (Credit Bureau).
Those necessary to comply with legal provisions on the prevention and detection of acts or operations that provide support in the commission of crimes.
Those data that allow estimating and verifying their ability to pay.

In certain cases, MONEYTRAX must collect Personal Data considered sensitive by applicable law, related to your financial, economic, and patrimonial data; or to meet requirements of financial authorities in accordance with Mexican legislation or in cooperation with foreign financial authorities in terms of the International Treaties to which Mexico is a party. Additionally, the request for certain Personal Data considered sensitive is necessary to attend to certain information queries that are made in terms of the Law to Regulate Credit Information Societies, the Law, the General Law of Credit Organizations and Auxiliary Activities and other financial provisions related to them.

MONEYTRAX may not collect sensitive data unlawfully (those personal data that affect the most intimate sphere of its owner, or whose improper use may give rise to discrimination or entail a serious risk for him/her). In particular, sensitive are considered to be those that may reveal aspects such as racial or ethnic origin, present and future state of health, genetic information, religious, philosophical and moral beliefs, trade union membership, political opinions, sexual preference), which, where appropriate, will be collected solely for the protection of the holder and compliance with the insurance contracts that the responsible party may provide or contract in the name and on behalf of the holder. For the use of Personal Data considered sensitive prior to its processing, the consent of the Owner must be obtained.

THE PURPOSES OF THE PROCESSING.

Primary purposes: Your personal data will be processed for the purposes that gave rise to or give rise to and that are necessary for the existence, maintenance and fulfillment of the obligations arising from the legal relationship between you and MONEYTRAX, which are:

Comply with the applicable provisions, and with the legal obligations set forth in and/or derived from such provisions.
The performance of each and every one of the operations and the provision of the services requested by you from MONEYTRAX and that the latter may carry out in accordance with the applicable provisions.
The creation and implementation of necessary or convenient analytical and statistical processes related to such operations, services and acts.
The execution of the acts that must or may be carried out in accordance with the applicable legal provisions and the bylaws of MONEYTRAX.
Confirm the identity of the owner of the personal data.
Detect the needs of Customers and/or Users.
Improve operations and/or claims procedures.
Confirm and correct the information provided by Clients and/or Users.
To prevent and mitigate any type of operations with resources of illicit origin by verifying the information of Clients and/or Users.
To carry out continuous improvement of the business and continue to provide added value.
To make an improvement in products, programs and/or services.
In response to requirements of Authorities in terms of the applicable provisions.
Conducting inquiries, investigations, and reviews in relation to any request, complaint, claim, or clarification submitted by a Customer or User.
Contact Tasks for Customers or Users to deal with any issue related to their personal data and this Privacy Notice.
Contact with Clients in order to verify any issue related to the legal relationship between the client and MONEYTRAX.
The performance of any complementary or auxiliary activity necessary for the performance of the above purposes.

Secondary Purposes: In addition, we use your personal information for the following purposes:

Conducting surveys for marketing or advertising purposes.
The promotion of products, services, additional benefits, discounts, promotions, bonuses, contests, market studies and sweepstakes offered by or related to MONEYTRAX or national or foreign third parties with whom it maintains commercial alliances.
The performance of any complementary or auxiliary activity necessary for the performance of the above secondary purposes.

In the event that MONEYTRAX intends to process your personal data for a purpose other than that is not compatible or analogous to the purposes set out in this Privacy Notice, we will again ask for your consent. It is important to mention that the primary purposes give rise to and are necessary to maintain the legal relationship between you and MONEYTRAX. Secondary purposes do not originate from or are necessary to maintain our legal relationship, so with regard to the latter, you may express your refusal to the processing of your personal data for these purposes through the procedure established in this Privacy Notice.

TRANSFER OF PERSONAL DATA.

In order to comply with the obligations arising from the legal relationship with you, as well as those purposes provided for in this Privacy Notice, MONEYTRAX may transfer the necessary personal data to any of its affiliates, subsidiaries, associates or persons who are part of the business or commercial group to which MONEYTRAX belongs in Mexico or abroad; competent authorities in the cases provided for by law; to third parties, both national and foreign, such as insurers, development financial institutions and/or any national or international entity that has participated in the funding of the product requested by you.

Therefore, the transfer of your personal data in the case referred to in the immediately preceding paragraph does not require your consent. In all other cases, your personal data will not be transferred to third parties without your prior and informed consent, except for the exceptions provided for in Article 37 of the Law and in any case complying with the conditions provided for in Article 17 of the Law Regulations.

For the proper functioning and fulfillment of MONEYTRAX’s objectives, personal data may exceptionally and in good faith also be processed by researchers, professional services firms, financiers, providers or accreditors, auditors, consultancies, support and verification of labor or legal information, donors, donees, in compliance with the applicable legal provisions, for which MONEYTRAX will select reliable suppliers that ensure measures that guarantee an adequate level of protection, and must agree on confidentiality and personal data protection clauses.

Third parties may use personal data, subject to agreement with MONEYTRAX, for the fulfillment of the following purposes:

In order to carry out prospecting and customer acquisition for MONEYTRAX.
In compliance with obligations set forth in contracts for the provision of professional services entered into with MONEYTRAX.
In celebration of commercial, health, or union alliances.
In compliance with prudential or trade union rules.
In compliance with requirements for MONEYTRAX to acquire financing, loans or credits, or to be able to access institutional programs.
To be able to perform audits, consulting, support and verification of labor, accounting, financial or legal information requested by and for MONEYTRAX.
For prospecting and collection of evidence requested by MONEYTRAX.
To collect donations through affiliates, subsidiaries and/or associates.
For the defense of the interests of MONEYTRAX, in the event of any legal controversy that arises due to the products, programs and/or services offered and/or granted.
In general, any activity that entails providing an adequate service of what is offered, always for the benefit of MONEYTRAX, its affiliates, subsidiaries, associates or that are part of the business or commercial group to which MONEYTRAX belongs in Mexico or abroad, for the benefit of donors and/or customers.

The transfer of your data may be carried out without your consent provided that the transfer:

It is provided for in a law or treaty to which Mexico is a party.
When the transfer is necessary for medical prevention or diagnosis, the provision of health care, medical treatment or the management of health services.
Is made to holding companies, subsidiaries or affiliates under the common control of MONEYTRAX, or to a parent company or any company of the same MONEYTRAX group in Mexico or abroad that operates under the same internal processes and policies.
Is required by virtue of a contract entered into or to be entered into in the interest of You, by MONEYTRAX and a third party.
It is necessary or legally required for the safeguarding of a public interest, or for the procurement or administration of justice.
It is necessary for the recognition, exercise or defence of a right in a judicial proceeding.
It is necessary for the maintenance or performance of a legal relationship between You and MONEYTRAX.

- RIGHTS OF THE OWNER AND ARCO RIGHTS.

If you do not wish your personal data to be transferred, you can contact the area in charge of reviewing the exercise of rights ARCO by email: moneytraxcc22@gmail.com or by phone at 55 5521 9591 from Monday to Friday from 9:00 a.m. to 6:00 p.m.

The owners of personal data are responsible for the accuracy, veracity, authenticity and validity of their data. You have the right to know what personal data we hold about you, what we use it for and the terms of use we give it (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); that we delete it from our records or databases when we consider that it is not being used in accordance with the principles, duties and obligations provided for in the regulations (Cancellation); as well as to oppose the use of your Personal Data for specific purposes (Opposition). These rights are known as ARCO rights.

If you would like to exercise your ARCO rights, you can contact the area in charge of reviewing the exercise of ARCO rights by email: moneytraxcc22@gmail.com, or by phone at 55 5521 9591 from Monday to Friday from 9:00 a.m. to 6:00 p.m. Alternatively, you may address your request to the address of MONEYTRAX set out in this Privacy Notice. The application must contain and be accompanied by the following:

Your name and address.
Indication of the means of communicating the response to your request.
Documents proving their identity or, where appropriate, legal representation.
The clear and precise description of the personal data with respect to which one of the ARCO Rights is sought to be exercised.
Any other element or document that facilitates the location of personal data.

MONEYTRAX will notify you through the means indicated in the Application and/or through the means in which it was sent, within a maximum period of 20 (twenty) business days, counted from the date on which it receives the corresponding application, the determination adopted. If the request is admissible, it will be effective within 15 (fifteen) business days following the date on which MONEYTRAX communicates the response. In the event that the information provided in your application is erroneous or insufficient, or the necessary documents to prove your identity are not attached; MONEYTRAX, within 05 (five) business days following receipt of your request, will require you to correct the deficiencies in order to process it. You will have 10 (ten) business days to respond to the request for correction, counted from the day following the day on which you have received it. The corresponding request will be considered not submitted if you do not respond within this period.

You may obtain the exercise of your ARCO rights through simple copies, electronic documents in conventional formats (Word, PDF, among others), through restricted and authorized access to the system that processes your personal data (access) or through any other legitimate means that guarantees and accredits the effective exercise of the requested right. The use of electronic means for the exercise of ARCO rights authorizes MONEYTRAX to respond to the corresponding request through the same means, unless the Owner himself indicates a specific means to receive the response clearly and expressly.

REVOCATION OF CONSENT.

At any time you may inform MONEYTRAX of your determination to revoke the consent that has previously been granted for the processing of personal data in accordance with the purposes described in this Privacy Notice, so that MONEYTRAX ceases to make use of them and provided that the consent that is intended to be revoked does not derive from a contractual legal relationship or operation agreed with MONEYTRAX, that the law allows it or that it has been expressly agreed between MONEYTRAX and the Client. In all cases, the revocation of consent will not have retroactive effects.

The requirements to prove your identity, as well as the procedure to respond to your request will be the same as those indicated in the previous paragraph of this Privacy Notice (5. Rights of the Owner and ARCO Rights).

LIMITATION OF USE OR DISCLOSURE OF YOUR PERSONAL DATA.

When the processing of your personal data does not refer to those necessary to comply with a legal or contractual obligation (compliance with legal obligations arising from the legal relationship between you and MONEYTRAX), you will have the right to request MONEYTRAX to limit the use and/or disclosure of your data.

In accordance with current legislation on the Protection and Defense of Users of Financial Services, you may express your desire not to receive advertising related to the products and services provided by MONEYTRAX, by registering in the User Registry maintained by the National Commission for the Protection and Defense of Users of Financial Services («CONDUSEF») by any of the following means: by telephone at 01 800 999 8080 at the CONDUSEF Call Center, go to any of the CONDUSEF National Service Offices or through the www.condusef.gob.mx website.

COOKIES Y/O WEB BEACONS.

Within the Site of the worldwide network called the Internet and the applications used, MONEYTRAX uses cookies, web beacons and other technologies through which it is possible to monitor your behavior as an Internet User; the foregoing to provide you with a better service and user experience when browsing the Site. For the purposes of this section, the Site and/or the pages that are part of it include the use of data interface applications and/or mobile applications.

A «cookie» is a piece of programming information contained in a very small text file that is placed in your Internet browser or on your hard drive. You can control the acceptance of cookies by modifying your Internet browser preferences. The User has the possibility to accept all cookies, be notified of a cookie or reject all cookies. It is important to note that if you choose to block all cookies (including essential cookies), you will not be able to access all or part of the Site and/or the pages that are part of it and may not be able to use those services or engage in activities that require the placement of cookies. MONEYTRAX uses cookies to distinguish users and to compile aggregate statistics on the use of the Site.

A Web Beacon is small electronic images embedded in web content or e-mail messages and are not normally visible to Users. Such tracking technology allows MONEYTRAX to crawl the pages and content accessible and accessible to users on the Site and/or any pages that are part thereof. The use of these technologies allows MONEYTRAX to refine the content of the Site and personalize the User’s experience.

10 MODIFICATIONS TO THIS PRIVACY NOTICE.

MONEYTRAX may make changes or modifications to this Privacy Notice at any time. Any changes made to it will be made known through the designated electronic means.

11 MEASURES TO RETAIN YOUR PERSONAL DATA.

MONEYTRAX guarantees the security of the data of Clients and Users in accordance with the following, actions that tend to guarantee the privacy of the same when accessing this Site:

Compliance with the Federal Law on the Protection of Personal Data in Possession of Private Parties, the Law for the Protection and Defense of the User of Financial Services, the Law for the Transparency and Regulation of Financial Services, and any complementary or related provisions, and that is applicable to MONEYTRAX.
The Privacy Notice can be consulted
All MONEYTRAX processes are constantly monitored and evaluated internally in order to give adequate care and protection to the Personal Data of Individuals.
The Site does not automatically recognize any data regarding the identity of visitors to each of the pages that make it up.
MONEYTRAX will only disclose information to Authorities in accordance with applicable provisions.
MONEYTRAX, under the terms entered into by the respective Agreement, may use the information provided to offer other products and services.
In compliance with the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin and other similar or complementary provisions, it may request information from Clients and/or Users through this Site in order to prevent and detect operations related to money laundering and terrorist financing; and disclose such information to the Authorities in accordance with applicable law.
The information obtained by MONEYTRAX will be kept only for the time established in accordance with the applicable legislation.
MONEYTRAX may obtain further information from Customers and Users to ensure that the data collected was obtained correctly and completely. These sources of information may come from consultations with Authorities, International Organizations and Credit Information Societies. Consultations that require prior approval in accordance with the applicable legislation will be carried out after the aforementioned authorization is obtained.
All personal data collected will be confidential information. All employees, suppliers and collaborators of MONEYTRAX are committed to carefully handling the personal data of Clients and/or Users.
MONEYTRAX takes all reasonable measures to ensure the security of its computerized databases and safeguard all information obtained.
MONEYTRAX may use personal data to improve the quality of the service, for which it must have the express consent of the owner of the Personal Data with a handwritten signature, with the understanding that such consent will at no time be a condition for the contracting of any product and/or service. This data may be used and disclosed to affiliated companies, under the terms established by applicable legislation.

NOTICE OF NON-DISCRIMINATION:

MONEYTRAX does not DISCRIMINATE against any person on the basis of race, sex, physical ability, religion or otherwise. Every person has the right to protection and respect for his or her honor, dignity, morals, and reputation, and therefore any act of discrimination that aims to undermine and limit the recognition, enjoyment, and exercise of human rights, and/or the exercise of his or her ARCO Rights, is prohibited.

The foregoing declaration is issued in order to fully comply with the provisions of the fifth paragraph of article one of the Political Constitution of the United Mexican States, and articles 4 and 5 of the Federal Law to Prevent and Eliminate Discrimination.

ATTENTION TO COMPLAINTS AND DENUNCIATIONS.

If you consider that your right to personal data protection has been violated by any conduct, action or response of MONEYTRAX; you can contact the area in charge of reviewing the exercise of rights ARCO at email: moneytraxcc22@gmail.com or telephone 55 5521 9591 from Monday to Friday from 9:00 a.m. to 6:00 p.m.; and without prejudice to your right to go to the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI). For more information, visit www.inai.org.mx.