Dear client, for “SEEKURITY- INFORMATION
SECURITY AND CYBERSECURITY FIRM”, S.A. de C.V. (hereafter SEEKURITY”),
the security of your information is of the utmost importance, this is why we
inform you that all your Personal Data will be protected and shall be treated
confidentially. Likewise, through the following Privacy Notice that we make
available, you shall be aware of how and on what your Personal Data is being
treated, as well as to facilitate the exercise of the rights that the Federal
Law on Protection of Personal Data Held by Private Parties shall grant to you.
Who shall handle your Personal Data?
“SEEKURITY”, aware of the importance to appropriately
handle your Personal Data, it shall become the Responsible party for processing
your Personal Data in accordance with the principles of legality, consent,
information, quality, purpose, loyalty, proportionality and responsibility, as
it’s established in Article 6 of the Federal Law on Protection of Personal Data
Held by Private Parties (hereinafter, the Law), as well as it is stated
by following provisions: Articles 8, 15, 16, 17, Section II, 33, 36 and 37 of
the Law; Articles 14, 24, 26, 27, 28, 30, 40, 41, 42, 68, 90 and 102 of
its Regulations; and the 10th, 18th, 20th, 21st, 22nd, 23rd, 24th, 25th, 26th,
27th, 28th, 29th, 30th, 31st, 32nd, 33rd, 37th and 41st of the Privacy Notice
Guidelines. In this manner, we shall inform you of the existence and main
characteristics of the way your Personal Data will be subjected in accordance
with what is indicated below.
How can
you contact us?
“SEEKURITY”, being responsible for the use and/or
treatment of your Personal Data, it is important to make the following means
available to you, through which you can contact us:
• Address: 4th Floor, Hamburgo 182, Juarez 06600, Mexico City, Mexico.
• Email address: [email protected]
• Internet page: https://www.seekurity.com
What type of Personal Data are we going to collect?
The type of Personal Data that “SEEKURITY” obtains, are things such as
full name, address, telephone, email, signature, RFC, CURP, date and place of
birth, age, nationality and/or marital status, directly and/or through physical
means, electronic or face-to-face, as well as from authorized public sources,
in order to fulfill the main and necessary purposes indicated in this Privacy
Notice.
Consent shall not be necessary for the
processing of Personal Data when:
• It is foreseen by the Law,
and other dispositions on the matter.
• The data appears in publicly
accessible sources.
• Personal Data are subject to a
prior dissociation procedure.
• Has the purpose of fulfilling
obligations derived from a legal relationship between the Owner of
Personal
Data and “SEEKURITY”.
• There is an emergency situation
that could potentially harm an individual in his property or person.
“SEEKURITY”, shall respect at all times your right to
privacy and protection of your Personal Data, including your financial or patrimonial
data; therefore, your information is duly protected in accordance with the
administrative, technical and physical security provisions, established in the Law,
to protect it from possible damage, loss, alteration or unauthorized access.
In all cases, for Personal Data of a
patrimonial and/or financial nature, “SEEKURITY” shall comply with its
obligations derived from the legal relationship established with the Holder,
and it is our commitment that this is treated under the strictest measures of security,
always guaranteeing your confidentiality.
Sensitive Personal Data.
Under no circumstance shall “SEEKURITY” request any Personal Data of a
sensitive nature, such as: racial or ethnic origin; health condition; genetic
information; religious beliefs; philosophical or moral; political opinions;
sexual preference, and/or those that affect the intimate sphere of their
holders, and which are not necessary for the services that “SEEKURITY”
offers.
Third Parties’ Personal Data.
In case of providing any type of Personal Data
related to another person as a reference, for the effects of this Privacy
Notice, you shall declare and accept that you have obtained the corresponding prior
consent of said person to do so.
Personal Data of Minors.
By the present document, we bring to your
attention that “SEEKURITY”, shall not receive nor deal, through any
means, Personal Data from a minor.
With what ends do we use/deal with your
Personal Data?
The main and/or necessary purposes for
which SEEKURITY” may request,
obtain, store and/or use your Personal Data, are those that resulted in a
business relationship between you and “SEEKURITY”, such as:
verify and proof your identity; elaborate proposals and quotes for contracting and,
sending information by virtue of the business relationship; carry out the
necessary steps for the legal relationship, or to contract the necessary services
for the delivery of the economic considerations and the in-kind compensation
established in the contracts; for statistical purposes, reporting and updating
of the database; to carry out all the procedures before the corresponding
authorities, management of payments and collection of contracted services; and
evaluation of the quality and satisfaction of products and services.
Likewise, “SEEKURITY” may also collect your Personal Data for
secondary purposes, which are not necessary or inherent to the business
relationship, but are useful, since they allow and facilitate the ways to offer
you a better service, said purposes are: statistics; security of people; credit
validation and payment; assessment of the risk of fraud in transactions; said
aimed to improve the services offered and the care provided to users; and similarly,
the purposes of a promotional and/or informative nature to offer services that “SEEKURITY” provides and
that we consider may be of interest to you.
This way, by signing the present document, you
authorize that your Personal Data be collected to fulfill the main purposes, as
well as secondary or accessory purposes, however, in the event that you decide
to revoke your consent for your Personal Data to be collected for secondary or
accessory purposes, you shall have 5 days to express your refusal in regards to
the use of your information being utilized for the secondary purposes specified
above.
In no case shall any Personal Data collected be
used for anything other than the purposes indicated here, unless there is a
change in this Privacy Notice.
To what Third Parties may we transfer your
Personal Data to?
As part of the way we treat your Personal Data
in “SEEKURITY”, no Personal Data transfers are made, including those of
a patrimonial and/or financial nature, in case it is necessary, said transfer
shall not take place without prior expressed and written consent from the
Holder, with the exception to those previously mentioned ends to which the
Personal Data has been referred to in the last paragraph, and all of those
mentioned below.
Personal Data may be transferred legally,
without the Holders consent, in the following cases:
a)
When
it is stated in the Law or in a Treaty, in which Mexico is a member of.
b)
To be
transferred to any subsidiaries, affiliates, branches, controllers, and/or SEEKURITY” companies within the national territory or abroad.
c)
When
transferring this data is necessary to provide the products and services, or to
comply with the contracted labor or business relations.
d)
To be
transferred to third parties for customer services and studies related matters
in accordance to the provisions of “SEEKURITY” products and services.
e)
When the data is necessary for the recognition,
exercise of defense of any rights in a judicial process.
How can you exercise your ARCO Rights?
As a Holder for Personal Data, YOU have ARCO
Rights (for its acronym in Spanish, Access, Rectification, Cancelation
and Opposition), in regard to the treatment and usage of your Personal Data.
Said rights are known as ARCO Rights, that form this “word given its initial
letters and with are based on the Law.
The mechanism by which the Holder may exercise
these ARCO Rights it’s by a Request of Access, Rectification, Cancelation
and/or Operation, (ARCO Request). Likewise, this may also be presented to limit
the use and/or disclosure of your data, or in any case, to renew the consent
for the usage and treatment of your Personal Data.
The ARCO Request may be carried out via email
at Attention to Personal Data “SEEKURITY” through the following email
address: [email protected].
Said request must contain and be accompanied by the following:
1.
The Holder’s name, address and/or any other
means to communicate the response to the request;
2.
Documents that prove the identity or, in its
case, the legal representation of the Holder;
3.
The clear and precise description of the
Personal Data that concern the request to exercise an of the ARCO Rights;
4.
Any other element or document that may
facilitate the location of the Holder’s data, as well as their RFC and/or CURP
code to avoid any homonymy.
5.
To clearly specify if the request is being made
for access, rectification, cancellation, opposition; to limit the
use/disclosure, or revoke of consent.
6.
The reason for soliciting the request.
7.
The modify data and/or information, given the
request is made to rectify any Personal Data, and deliver any documents to
support said request.
In the event that the information provided in
the ARCO Request is insufficient or erroneous to attend to it, or if it is not
accompanied by the necessary documentation to conduct the execution of said
request, “SEEKURITY” for one time only, shall make a request to the
Holder, or its proxy, within the first 5 business days after receiving of the
Request, so that the necessary elements or documents may be provided to
commence the pertinent procedure. Subsequently, the Holder, or its proxy, shall
have a period of 10 business days to respond to said request, counted from the
day after this was issued by SEEKURITY”. In case that no response is
made to said request within the granted period of time, your request shall be
considered as not submitted.
Once the aforementioned terms have been exhausted,
“SEEKURITY shall respond to the ARCO Request with a verdict, within a period
of 20 business days from the reception of the Request, or in case additional
information or documents where requested, within a period of 20 busines days
counting from the next day of having presented the requirements response.
In case the ARCO Request is approved, “SEEKURITY”
shall make effective the concluded decision within a period of 15 business days
counting from the day the response is communicated to the Holder, or proxy. In
regards of an ARCO Request concerning access for Personal Data, the delivery of
said information shall be made after accreditation of identity of the Holder,
or its proxy.
The
response periods for an ARCO Request may be extended by SEEKURITY”,
and/or to enforce the reached conclusion, for one time only, for equal periods
to those indicated in each case, provided that it considers that the
circumstances of each case warrant them. In such cases, “SEEKURITY”
shall notify the Holder, or its proxy, the circumstance (s) for the warrant
extension, within each of the original deadlines to respond or make the
determination made effective. The responses of any ARCA Requests shall be
delivered to the Holder, or to its proxy, in simple copies or in electronic
files according to the type and quantity of documents in each case.
To revoke a consent, a simple Request from the Holder shall
suffice, made through the same means used for the ARCA Request, SEEKURITY
may later make said request
effective, as long as it is not any Personal Data necessary for the existence,
maintenance and/or compliance with your business relationship with the Holder
of Personal Data. However, it is important that you bear in mind that not in
all cases we will be able to respond to your Request or terminate the use of
your data immediately, given it is possible that, due to some legal obligation,
we will need to continue treating your Personal Data.
In addition to the above, YOU must
consider that, for certain purposes, the revocation of your consent will imply
that we cannot continue to provide the service you requested, or the conclusion
of your relationship with “SEEKURITY”.
What limits the ARCO Request?
“SEEKURITY may deny Access, Rectification, Cancellation or Opposition
to the treating of your Personal Data, in the following cases:
• When the applicant is not the Holder
of the Personal Data, or the proxy is not duly accredited for it.
When the applicant's Personal Data
is not found in its database.
• When the rights of a third party
are injured.
• When there is a legal impediment,
or the resolution of a competent authority that restricts access to
Personal Data or that
does not allow their rectification, cancellation or opposition.
• When the rectification,
cancellation or opposition has been previously made.
What is SEEKURITY obliged to? And, What do we require of YOU as the Holder
of Personal Data?
To comply with this Privacy Notice purposes, “SEEKURITY” commits to have
sufficient and necessary legal and security measures to guarantee that your
Personal Data remains confidential and secure.
Furthermore, as the Holder of the Personal
Data collected, YOU shall be responsible for keeping updated your Personal Data
in possession of “SEEKURITY”. Likewise, YOU guarantee and respond, in
any case, to the veracity, accuracy, validity and authenticity of the Personal
Data provided, and undertake to keep this information duly updated,
communicating any change to “SEEKURITY”.
What technologies are used through this
website?
We inform you that our Webpage uses cookies, web beacons and other technologies
through which it is possible to monitor your behavior as an Internet user, as
well as to provide you with a better service and a user experience when
browsing through our page.
The visitor can configure their browser to accept or reject all cookies or
web beacons by default, or to receive a warning on the screen of the receipt of
each cookie or web beacons and decide at that time whether or not to implement
it on their hard drive. The cookies or web beacons used on the “SEEKURITY” websites do not provide
references that allow the visitor’s name and surname to be deduced and they
cannot read data from their hard drive or include viruses in their texts.
In the event that the Holder provides their Data by any of these means,
including the Website (Internet) of “SEEKURITY”,
the Holder understands, accepts and acknowledges that:
A.
The “SEEKURITY”
website may include links to third party websites, which, if accessed, shall
cause the user to exit the “SEEKURITY website, therefore “SEEKURITY”
assumes no responsibility in relation to said third party sites.
B.
The “SEEKURITY”
website may include links to other sites that manage social media networks, in
which case, the Holder accepts that, by providing any type/kind of information
or Data within said sites, may cause this data to be read, viewed, accessed,
retransmitted and processed by anyone, and therefore released “SEEKURITY”
from any responsibility and liability.
The present Privacy Notice may undergo
modifications, changes or updates derived from new legal requirements; of our
own needs given the products or services we offer; given our privacy practices;
by changes in our business model, or any other causes. It is our commitment to
keep you informed about the changes that the present comprehensive Privacy
Notice may undergo.
This Privacy Notice shall become effective
as of July 31st, 2020.
Last update: July 8th, 2021.
