Privacy Notice

Pacto Technology México, S.A.P.I. de C.V., ("PACTO" or "we"), with address at Paseo de la Reforma 296, 38th Floor, and in compliance with the Federal Law for the Protection of Personal Data in Possession of Individuals and its Regulations (the "Law"), hereby informs you of this Privacy Notice (the "Notice"), which can be consulted in PACTO's website www.pacto.co (the "Platform"). This Notice describes your rights regarding the collection, use, storage, processing, transfer and protection of your Personal Data by PACTO.

 

1. INFORMATION COLLECTED

PACTO may collect the following personal data ("Personal Data"):

a) Personal data (the "Personal Data") that you provide us as a result of using the services offered by PACTO (the "Services"), consisting of: 

  • In the case of an individual, full name (father's and mother's surname and first names) and in the case of a legal entity, its name or corporate name; 

  • E-mail address; 

  • Cell phone number; 

  • Address;

  • RFC;

  • Banking information.

b) Personal data of third parties that you provide, such as beneficiary information, resource provider information, legal representative information, and beneficial owner information, among others.

c) Transactional data of the transactions you carry out with us or through us.

d) Personal information generated, derived from promotions, registrations for email alerts or marketing communications, membership or loyalty programs and historical use of the services and/or your advertising preferences generated or collected by virtue of the relationship between PACTO and you.

PACTO uses cookies for the functionality of the Platform, in order to remember users' settings (e.g., country of origin and destination) and for authentication purposes. Users can control the use of cookies at the individual browser level. If you reject cookies, some functions or areas of the Platform will be limited.

2. WHAT ARE THE DATA COLLECTED FOR?

The Personal Data collected by PACTO that we collect from you, we will treat them for the following purposes that are necessary for the service you request, in accordance with the following:

2.1 Primary Purposes:

  • Manage the registration to the Platform. 

  • Allow you to purchase licenses to use the services through the Platform. 

  • Manage the payments of the use licenses.

  • To comply with the legal relationship or with legal or authority requirements.

  • Validate the quality of your personal data, i.e. validate that it is accurate, complete, correct and up to date.

  • Follow up on requests, claims and/or complaints.

  • Maintain updated records of your personal data in the systems.

The fulfillment of the Primary Purposes of the processing is necessary for the existence, maintenance and fulfillment of the legal relationship between PACTO and you.

2.2 Secondary Purposes: 

  • Send you marketing notices, service updates and promotional offers.

  • Collect survey information that will be used to monitor or improve the use of our Service and the overall satisfaction of our customers.

  • Help improve and develop PACTO services and products.

  • Send you commercial communications and keep you informed about products and services, loyalty programs or other PACTO updates.

  • To enable you to receive the best experience in using the Platform including to store your preferences, passwords and other tracking information and activity on the Platform.

We will retain your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

You may modify the Personal Data you have provided us at any time through the corresponding section.

WITH WHOM DO WE SHARE YOUR INFORMATION?

Personal data will be transferred nationally and internationally, to persons or entities located in the following types, categories or sectors, for the following purposes:

  • Subsidiaries, affiliates or any company of the same PACTO group operating under the same internal processes and policies and for the purposes mentioned under the previous heading.

  • To third parties such as agents, vendors, consultants or suppliers, as well as any other third party service providers that provide certain services on our behalf, provided that their transfer is necessary for the existence, maintenance and fulfillment of the legal relationship between PACTO and you. 

  • To competent national and foreign authorities, in order to comply with any applicable law, regulation or legal provision.

Such third parties will have access to your Personal Data only for purposes of providing the services and fulfilling the purposes specified in this Notice, or to comply with applicable law and for no other purpose. These third parties are not permitted to use your Personal Data for their own purposes, and may only process it in accordance with our instructions. We require these third parties to adopt security measures that are consistent with the protections specified in this Privacy Notice and applicable law.
 

4. CLAUSE TO CONSENT TO TRANSFER

It should be considered that it will not be necessary to have their consent to carry out: 

  • The transfer indicated in paragraphs a) and c) of the previous section, for being in the assumption established in section IV of article 37 of the Federal Law for the Protection of Personal Data in Possession of Private Parties and, 

  • Those transfers that fall within the cases established in Article 37 of the Law.

 

5. ARCO RIGHTS

You, by yourself or through your duly accredited legal representative, may exercise your rights of access, rectification, cancellation or opposition to the processing of your personal data (the "ARCO Rights"). To do so, you must request an ARCO Rights exercise form by sending an email to the address hola@pacto.co.

The form for the exercise of ARCO Rights must be filled out, signed and submitted together with the following documentation, so that it can be authenticated: 

  • Valid official identification (National Electoral Institute card, Passport, National Military Service Card or Professional ID).

  • In cases where the exercise of the ARCO Rights is made through your legal representative, the official identification of the representative must be attached, as well as the corresponding notarized power of attorney that proves the legal representation conferred by you.

  • When you wish to exercise the right of rectification, you must show the documentation that proves the requested change in accordance with the personal data to be rectified.

PACTO will respond to such form after 20 business days from the date it was received. This term may be extended for up to 20 more business days, when the case warrants it, prior notification to you. PACTO will inform you of the resolution adopted through the options chosen by you in the ARCO Rights exercise form.

 

6. REFUSAL OR REVOCATION OF CONSENT TO PROCESS YOUR DATA

In case you wish to revoke your consent or refuse the processing of your personal data after signing and accepting this Notice, regarding the Secondary Purposes, you must send an email to hola@pacto.co indicating such situation.

7. CHANGES TO THE PRIVACY NOTICE

This Notice is published for consultation on the Platform. Similarly, the modifications that at any time are made to this Notice, will be published at that address https.

 

By using the Platform, you give your express consent in terms of this Notice and therefore, you consent that your Personal Data be processed by PACTO in accordance with the provisions of this Privacy Notice, used for the purposes indicated herein and transferred to the third parties established herein.