I. IDENTITY AND ADDRESS OF THE RESPONSIBLE PARTY
KRS TECNOLOGIC S.A. DE C.V. (CREA-THUM), located at Av. Baja California 274, FLOOR 2 INT 2-B, Col. Hipódromo, C.P. 06100, Mexico City, is responsible for processing the personal data of its clients (Data Subjects), which may be collected through the following means: (i) directly when the Data Subject inputs Personal Data via our website, (ii) indirectly when they transfer their Personal Data under the provisions of Article 37 of the Federal Law on the Protection of Personal Data Held by Private Parties (Law) or upon granting their consent for this purpose, and (iii) indirectly when information is obtained through publicly accessible sources permitted by the Law.
This Privacy Notice is made available to the Data Subject prior to the collection of their Personal Data, in strict adherence to the principles of information, legality, consent, quality, purpose, loyalty, proportionality, and responsibility established in the Law.
II. WHAT PERSONAL DATA DO WE COLLECT?
To fulfill the purposes described in this Comprehensive Privacy Notice, CREA-THUM will collect and process the following data:
• Full Name
• Address (street, number, neighborhood, borough/m municipality, postal code, and federal entity)
• Personal phone number
• Email address
• Tax data (RFC, fiscal address, and business name)
• Valid official identification (INE or PASSPORT)
• Proof of address from the last 3 months (telephone, electricity, or water bill)
CREA-THUM will not collect or process sensitive personal data. If you contact us via social media, we may collect data from your public profile to address your requests and/or inquiries regarding the products we offer.
III. FOR WHAT PURPOSES WILL WE USE YOUR PERSONAL DATA?
The personal data we collect will be used by CREA-THUM for the following primary purposes that are necessary to provide you with the service:
• Creation and management of your user account,
• Keeping a record of activities related to your user profile,
• Identifying and contacting the user to follow up on services offered on the site.
• Verifying and confirming the user's identity, including verification processes using biometric data according to current regulations.
• Accrediting, validating, and verifying the user's identity, which includes verifying data on the Voter ID and biometric data (such as fingerprints and facial features) against records from the National Electoral Institute.
• Complying with the Federal Law for the Prevention and Identification of Operations with Illicitly Obtained Resources and other applicable regulations.
• Resolving banking clarifications.
• Complying with requests from competent authorities in cases provided by law.
• Detecting and preventing fraud.
• Contacting through phone calls, emails, text messages, and other physical and/or electronic communication means, including instant messaging services.
• Determining the user's geographical location to offer specific content, promotions, or benefits in that area.
• Conducting quality monitoring activities of the services offered.
• Maintaining the security of electronic communications networks and services, detecting faults or technical errors in communication transmission, and performing necessary treatments for the proper provision of services.
• Complying with internal policies and procedures.
• Fulfilling obligations under applicable regulations, including responding to properly founded and motivated requests from competent authorities.
• Addressing your opinions, complaints, and/or suggestions.
• Conducting inquiries, investigations, and reviews regarding complaints or claims.
• Addressing your requests for exercising ARCO Rights and Revocation of Consent.
Additionally, we will use your personal information for the following secondary purposes that are not necessary for the requested service but allow us to provide you with better care:
• Developing customer profiles and users of the products offered by CREA-THUM.
• Sending communications related to offers, promotional messages, marketing communications, advertisements, and commercial prospecting regarding new or existing products or services.
• Conducting surveys, market studies, participating in events, contests, trivia, games, and lotteries, participating in social media, chats, and information that allows us to evaluate the quality of products and services.
• Evaluating the quality of our services.
• For analytical, statistical, and marketing purposes; the above with the sole aim of providing you with better service.
If you do not wish for your personal data to be processed for secondary purposes, you can send an email to soporte@crea-thum.com stating this and specifying that such denial is for the CREA-THUM brand. We will respond to your request within a maximum of 20 business days.
The denial for the use of your personal data for these purposes will not be a reason for us to stop providing you with the service or selling you the products you request.
IV. WITH WHOM DO WE SHARE YOUR INFORMATION AND FOR WHAT PURPOSES?
CREA-THUM may transfer your personal data to third parties without the need to obtain your consent in the cases established in Article 37 of the Federal Law on the Protection of Personal Data Held by Private Parties.
V. HOW CAN YOU EXERCISE YOUR ARCO RIGHTS AND/OR REVOKE YOUR CONSENT?
At any time, you or your duly accredited legal representative may exercise any of the rights of Access, Rectification, Cancellation, or Opposition (hereinafter "ARCO Rights"), as well as revoke your consent for the processing of your personal data.
To exercise your aforementioned rights, you must send your request to our Information Privacy department at the email address soporte@crea-thum.com.
In the email, you should specify whether you wish to exercise any of your ARCO rights or revoke your consent and indicate that your request is for the CREA-THUM brand. Once we receive your request, we will send you the ARCO Rights Request Form and its procedure, or the Consent Revocation Form and its procedure, as applicable.
The response time for your request will be 20 business days from the day the corresponding request for access, rectification, cancellation, and opposition is received. The response will be communicated within the aforementioned period to the email address you provided in your request or by sending a letter to the address provided in the same. Once this notification is received, CREA-THUM will have 15 business days to make it effective if applicable.
CREA-THUM may deny access to Personal Data or to carry out the rectification, cancellation, or grant the opposition to their processing in the following cases:
• When the requester is not the Data Subject, or their legal representation is not duly accredited.
• When the Personal Data is not found in CREA-THUM's database.
• When the rights of a third party are violated.
• When there is a legal impediment or a resolution from a competent authority restricting access to the Personal Data or preventing its rectification, cancellation, or opposition, and
• When access, rectification, cancellation, or opposition has already been performed.
For more information on the procedures, requirements, and timelines for exercising your ARCO Rights and/or revoking consent, contact the Information Privacy Department.
VI. HOW TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL DATA?
If you wish to limit the use or disclosure of the personal data you have provided us for advertising and/or marketing purposes, send us an email at soporte@crea-thum.com indicating that you do not want your data to be processed for secondary purposes, or you can unsubscribe automatically from the emails we will send you by clicking on the "Unsubscribe" link.
We commit to include your information in an Exclusion List to suspend all activities related to sending advertising and/or marketing.
VII. NATIONAL INSTITUTE FOR TRANSPARENCY, ACCESS TO INFORMATION AND PERSONAL DATA PROTECTION (THE “INAI”)
If the Data Subject believes that their right to protect Personal Data has been violated due to improper processing by CREA-THUM and/or its personnel, they may file a complaint or report with the INAI. Please visit the website www.inai.org.mx for more information.
VIII. USE OF TRACKING TECHNOLOGIES ON OUR WEBSITE (COOKIES)
We inform you that on our website we use cookies, web beacons, and other technologies through which it is possible to monitor your behavior as an internet user, to provide you with a better service and experience while navigating our site, as well as to offer you new products and services based on your preferences.
The personal data we obtain from these tracking technologies are as follows: (i) browser used, (ii) server name, (iii) IP address, (iv) date, time, and duration of internet browsing and, on our website, or mobile application, (v) sections consulted, and (vi) web pages accessed before our website.
These technologies can be disabled by following these steps: 1. Access our website, 2. Click on the "Cookies" subsection of your browser; 3. Click on the link to activate the cookie disabling mechanism.
IX. UPDATE OF THE PRIVACY NOTICE
This privacy notice may undergo modifications, changes, or updates due to: (i) new legal requirements; (ii) our own needs regarding the products or services we offer; (iii) our privacy practices; changes in our business model, or other causes.
We will notify you of any changes to our Privacy Notice through our website, so we ask you to review it periodically.
X. ACCEPTANCE OF THE PRIVACY NOTICE
By using our services or purchasing our products, you authorize the processing of your personal data in accordance with the provisions of this Privacy Notice.
Last update: October 2024
