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Privacy Notice Productos Zam Fre S.A. de C.V.

In compliance with the FEDERAL LAW FOR THE PROTECTION OF PERSONAL DATA IN POSSESSION OF INDIVIDUALS dated July 5, 2010, (hereinafter the “Law”), the following Privacy Notice, the “Notice”, is issued.

Productos Zam Fre S.A. de C.V. is concerned about the confidentiality and security of the personal data of its customers and friends, and is committed to protecting their privacy and complying with the legislation applicable to the protection of personal data held by individuals.

The terms used in this Notice will have the definition assigned to them by the Law. This Notice specifies the type of data that Productos Zam Fre S.A. de C.V., S.A. de C.V. collects. collects, the purposes for which the processing of such data is carried out, as well as the rights of the owner in this regard.

FIRST. Productos Zam Fre S.A. de C.V. is the representative of the CONTINENTAL BEST® brand and is responsible for collecting personal data, the use given to them and their protection. Likewise, it will be the person who will process the requests of the holders for the exercise of the rights referred to in the Law. Productos Zam Fre S.A. de C.V. has its domicile at Circonio No. 45, Col. El Manto, Alcaldía Iztapalapa, C.P. 09830 Mexico City, Mexico”.

SECOND. RELEVANCE OF THE DATA. – The information obtained from the owners is presumed to be relevant, correct, updated and useful for the purposes for which it is collected and intended. The owner is solely responsible for the veracity and suitability of the information provided to the data controller.

The collection of data by Productos Zam Fre S.A. de C.V. is in good faith and for this reason it is presumed that the data is true, correct, complete and identifies the owner who supplies and/or provides it, so it is the owner’s responsibility that the data provided to Productos Zam Fre S.A. de C.V. complies with these characteristics and is updated as required. Likewise, Productos Zam Fre S.A. de C.V. reserves the right to exercise the actions it deems appropriate in case of false data.

THIRD. CONTENT OF PERSONAL DATA. – In accordance with the Law, “Personal Data” is understood as any information concerning an identified or identifiable individual. For the purposes of this Privacy Notice, in an enunciative but not limiting manner, “Personal Data” shall be understood as “Personal Data”:

3.1. General Data

Name(s) and surname(s), date of birth, sex, marital status, existence or not of children, address, telephone number (home or office), cell phone number, and e-mail address.

3.2. Financial or patrimonial data per transaction

When you make product purchase transactions, register for events or participate in promotions, either through the call center or through websites and microsites, in addition to general data, Personal Data will be considered those related to bank cards, such as cardholder’s name, card number, card expiration date, card type and security code, as well as the product delivery address and any other information necessary to perform the transaction by telephone or online. Also considered personal data are those related to bank accounts, such as the name of the holder, name of the bank, Standardized Bank Code (CLABE) and any other information necessary to make the payment of royalties, commissions or promotions.

Likewise, personal data are considered to be those related to the investigations carried out to grant credit to potential customers, such as personal credit references.

3.3. Sensitive Personal Data

In terms of the Federal Law for the Protection of Personal Data Held by Private Parties, Productos Zam Fre S.A. de C.V. will not collect sensitive data.

3.4. Social Networks

Social networks (such as Facebook® and Instagram®, among others) are a platform for communication and interconnection between digital platforms of different users, they are not under the responsibility of Productos Zam Fre S.A. de C.V. and, therefore, are not under its responsibility.

The information you provide within social networks in which Productos Zam Fre S.A. de C.V. participates as a user does not constitute or form part of the Personal Data subject to the protection of this Privacy Notice, being the responsibility of the company providing that platform and of whoever publishes it.

The Personal Data mentioned in sections 3.1. to 3.3. of this Notice shall be collected through the filling out of Contracts, Agreements, various forms and/or through the collection of information or documentation required by Productos Zam Fre S.A. de C.V., whether in person, by telephone, by optical means or by any other technology, as well as by electronic means in any of Productos Zam Fre S.A. de C.V.’s present or future Internet pages.

3.5. Cookies

Cookies are text files that are automatically downloaded and stored in a hard disk of the user’s computer equipment when navigating in a certain Internet page and that allow the Internet server to remember some user’s data.

By means of this Privacy Notice we inform you that we do NOT use cookies.

FOURTH. TREATMENT OF YOUR PERSONAL DATA. – In accordance with the provisions of the Law, it is considered processing of Personal Data (“Processing of Personal Data”), the collection, use, disclosure or storage of Personal Data, by any means. The use includes any action of access, handling, use, use, transfer or disposal of Personal Data.

The Processing of Personal Data by Productos Zam Fre S.A. de C.V. shall be limited to the fulfillment of the Processing Purposes set forth in this Privacy Notice and shall be subject to the following:

1. a) In the event that we intend to use your Personal Data for a purpose other than the purposes of this Privacy Notice, Productos Zam Fre S.A. de C.V. will require your consent for such purpose, once again.

1. b) It will be the one that is necessary, adequate and relevant for the purposes described in this Privacy Notice.

FIFTH. PURPOSES OF THE PROCESSING OF PERSONAL DATA. – Through this Privacy Notice, Productos Zam Fre S.A. de C.V. declares that the purposes of the processing of your Personal Data will be the following:

1. Commercial purposes, in order to let you know the commercial information of Productos Zam Fre S.A. de C.V., among which stands out the one related to trivia, promotions, contests, new product information, birthday congratulations, changes in our products, request evaluation of the quality of service, conduct internal studies on consumer habits and any other promotional or issue related to the products and / or services that are part of the business.
2. Online collection of transactions, with the purpose of making the economic charges to the bank cards of the products purchased by Productos Zam Fre S.A. de C.V. customers. This is derived from the purchase of the company’s products or services.
3. Economic purposes, at the time of requesting the granting of credit by the company, as in the case of personal or credit references before the credit institutions guaranteed by law.

SIXTH. ACCEPTANCE OF THE TREATMENT OF PERSONAL DATA. – In order for Productos Zam Fre S.A. de C.V. to carry out the processing of Personal Data, our clients and/or owners of Personal Data must grant us the express or tacit acceptance for such processing, which will be carried out by any of the following means:

6.1. Acceptance through electronic means

1. a) Publication on the Internet pages of Productos Zam Fre S.A. de C.V.

In addition to informing you of the Privacy Notice by e-mail, Productos Zam Fre S.A. de C.V. will publish this Privacy Notice on its website so that, once you are aware of its contents, you may grant or deny your consent for Productos Zam Fre S.A. de C.V. to process your Personal Data.

This shall also apply in the event that, for any reason, Productos Zam Fre S.A. de C.V. does not have your e-mail address or when your Personal Data is erroneous or out of use and does not allow us to locate you.

1. b) E-mail

Based on the information you provide or have provided to us, Productos Zam Fre S.A. de C.V. will send you this Notice by e-mail, so that, once you have been informed of its contents, you may grant or deny your consent for Productos Zam Fre S.A. de C.V. to process your Personal Data.

6.2. Acceptance or rejection of the Privacy Notice by electronic means The acceptance or rejection of the Privacy Notice of Productos Zam Fre S.A. de C.V. by electronic means shall be made in the following manner:

1. a) Productos Zam Fre S.A. de C.V. will send you the following information to the e-mail address registered in your name:

The manifestation that there is a Privacy Notice of Productos Zam Fre S.A. de C.V. or the modifications or changes made to said Notice, as the case may be.

The content of the Privacy Notice and, if applicable, any updates or adjustments made to it.

An electronic link through which you can accept or not to accept the Notice or Privacy, or the changes it may have.

1. b) Once you have read and are aware of the contents of the Privacy Notice, or the changes that are made, you will have the following options:

Accept. By accepting, you grant your consent and authorization for Productos Zam Fre S.A. de C.V. to use your Personal Data in accordance with the Processing Purposes established in the Privacy Notice.

Do not accept. When you do not accept the contents of the Privacy Notice or its modifications, you deny or cancel your consent and authorization for Productos Zam Fre S.A. de C.V. to use your Personal Data.

In this case, Productos Zam Fre S.A. de C.V. will cancel and stop using your Personal Data for the Purposes of Treatment established in the Privacy Notice.

6.3. Acceptance in a personal manner

When the Personal Data is obtained personally from the owner, Productos Zam Fre S.A. de C.V. will make this Privacy Notice available to you at the time your Personal Data is collected and in a clear and reliable manner, by means of the forms that Productos Zam Fre S.A. de C.V. uses or may use for such purpose.

6.4. Tacit acceptance

If you do not express your opposition to the content and scope of this Privacy Notice or its modifications, it will be understood that you grant your tacit consent for Productos Zam Fre S.A. de C.V. to process your Personal Data based on the Purposes of the Processing established in the Privacy Notice.

6.5. Retroactive Acceptance

For all our customers who on dates prior to the notification or publication of this Privacy Notice have provided us with their Personal Data, they will be informed of the Privacy Notice as set forth in sections 6.1. and 6.2. above, in order to grant or deny their consent (express or implied) so that Productos Zam Fre S.A. de C.V. may or may not continue to carry out the Processing of their Personal Data based on the Processing Purposes set forth in the Privacy Notice.

SEVENTH. LIMITATION OF THE USE OR DISCLOSURE OF YOUR PERSONAL DATA. –

7.1. Actions to prevent unauthorized use or disclosure.

In order to guarantee the protection of your Personal Data and to limit the unauthorized use or disclosure thereof, Productos Zam Fre S.A. de C.V. continuously performs and will perform the following actions:

1. a) Confidentiality of information. Productos Zam Fre S.A. de C.V. will keep confidentiality with respect to your Personal Data collected, which will subsist even after the end of its commercial relations or of any other nature with the client or owner of said Personal Data.

1. b) Confidentiality Notification. In the event that, for any reason, Productos Zam Fre S.A. de C.V. finds it necessary to provide your Personal Data to third parties (under the terms set forth in the Law or in this Privacy Notice), it will notify such third parties of the obligation to comply with the provisions of the Law and the confidentiality of your Personal Data.

1. c) Database Administration. The Personal Data are managed and safeguarded through the use of databases (“Database”), which are managed only by the persons designated by Productos Zam Fre S.A. de C.V. for such purpose, without allowing their use, consultation, handling or access to unauthorized persons.

1. d) Computer and information systems. Our Databases are protected by firewalls and computer systems focused on preventing and avoiding that people outside Productos Zam Fre S.A. de C.V. or unauthorized persons can access your Personal Data.

7.2. Requests to limit the use or disclosure of your Personal Data

In case you wish to limit the use or disclosure of your Personal Data, in relation to one or more of the Purposes of Data Processing, you may send the respective request.

EIGHTH. RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION (ARCO) – In accordance with the provisions of the Law, you have the right to access, rectify, cancel or oppose the Processing of your Personal Data, for which Productos Zam Fre S.A. de C.V. offers you the following procedure:

8.1. Personal Data Unit

Productos Zam Fre S.A. de C.V. has designated a unit in charge of the custody of Personal Data (“Personal Data Unit”), which will process your requests and promote the protection of Personal Data within our company.

For the above, the Personal Data Unit makes available to you the following forms of contact and reception of information and related documentation:

– E-mail: contacto-recaudacion@continentalbest.mx

– Address: Circonio No. 45, Col. El Manto, Alcaldía Iztapalapa, C.P. 09830 Mexico City, Mexico.

– Telephone: (55) 5233-0333 / (55)5612-1626

– Attention: Customer Service Department.

– Hours: Monday to Friday from 9:00 am to 6:00 pm.

8.2. Request for access, rectification, cancellation or opposition

As the owner of Personal Data, you may submit or send to the Personal Data Unit a request for access, rectification, cancellation or opposition regarding your Personal Data.

Such request must contain, at least:

Full name and address of the holder of the Personal Data, or other means to communicate the response to your request.

Documents proving the identity or legal representation of the holder of the Personal Data.

A clear and precise description of the Personal Data with respect to which the holder seeks to exercise any of the aforementioned rights.

Any other element or document that facilitates the location of the Personal Data.

Indication of the modifications to be made and/or limitations to the use of the Personal Data,

Provide the documentation supporting your request.

8.3. Resolution and communication

Productos Zam Fre S.A. de C.V. will communicate to the holder of the Personal Data the resolution adopted, within a term no longer than 20 working days from the date on which the request was received. This term may be extended by Productos Zam Fre S.A. de C.V. on a single occasion for an equal period, provided that it is justified by the circumstances of the case.

Based on the foregoing, and in accordance with the provisions of the Law, Productos Zam Fre S.A. de C.V. shall inform the holder of the Personal Data the sense and motivation of the resolution, by the same means by which the request was made, and shall accompany such resolution with the pertinent evidence, if any.

When the request is admissible, it will be made effective by Productos Zam Fre S.A. de C.V. within 15 business days following the communication of the resolution adopted.

The holder may file before the Federal Institute of Access to Information (IFAI) a request for data protection due to the response received or lack of response from Productos Zam Fre S.A. de C.V. Such request must be filed by the holder within 15 business days following the date on which the response is communicated to the holder by Productos Zam Fre S.A. de C.V. and shall be subject to the provisions of the Law.

In case of requests for access to Personal Data, it will be necessary for the applicant or his legal representative to previously prove his identity.

The obligation of access to information shall be deemed fulfilled when Productos Zam Fre S.A. de C.V. makes the Personal Data available to the owner or through the issuance of simple copies or electronic documents.

In the event that a person requests from Productos Zam Fre S.A. de C.V. access to his or her Personal Data, assuming that Productos Zam Fre S.A. de C.V. is the responsible party and it turns out that it is not, it will be sufficient for Productos Zam Fre S.A. de C.V. to so indicate to the owner by any means (of those established in this section), in order to consider the request to have been fulfilled.

The response to your request for access, rectification, cancellation or opposition of Personal Data will be free of charge. You will only have to cover the justified shipping costs or the cost of reproduction in copies or other formats, which, in due time, Productos Zam Fre S.A. de C.V. will inform you.

In the event that the same person repeats the request for access, rectification, cancellation or opposition of the Personal Data in a period of less than 12 months from the date of the last request, the response to your request may have an additional cost indicated by Productos Zam Fre S.A. de C.V. in accordance with the provisions of Article 35 of the Law.

8.4. Refusal to access Personal Data

Productos Zam Fre S.A. de C.V. may deny total or partial access to the Personal Data or to the rectification, cancellation or opposition to the processing thereof, in the following cases:

When the applicant is not the owner or the legal representative is not accredited to do so.

When Productos Zam Fre S.A. de C.V.’s database does not contain the applicant’s Personal Data.

When the rights of a third party are harmed.

When there is a legal impediment or resolution of an authority.

When the rectification, cancellation or opposition has been previously made, so that the request lacks subject matter.

8.5. Consequences of cancellation

The cancellation of Personal Data shall give rise to a blocking period after which Productos Zam Fre S.A. de C.V. shall proceed to the deletion of the corresponding data. Once the corresponding Personal Data has been deleted, Productos Zam Fre S.A. de C.V. will notify the owner.

Once the above has been done, Productos Zam Fre S.A. de C.V. may keep the Personal Data exclusively for the purposes of the responsibilities derived from the processing referred to in the Privacy Notice.

Productos Zam Fre S.A. de C.V. shall inform them of the request submitted by the owner, so that they may proceed to make such rectifications or cancellations.

Productos Zam Fre S.A. de C.V. shall not be obliged to cancel your Personal Data in the cases established in Article 26 of the Law.

Likewise, when the information collected in the Personal Data is no longer necessary for the fulfillment of the purposes set forth in this Privacy Notice and in the applicable legal provisions, your Personal Data will be cancelled from the Productos Zam Fre S.A. de C.V. Databases.

NINTH. CHANGES TO THE PRIVACY NOTICE. – Productos Zam Fre S.A. de C.V. reserves the right to make, at any time, modifications or updates to this Privacy Notice, in order to comply with new legislation or jurisprudence, internal policies, new requirements for the provision or offering of its products and services, or due to commercial practices.

Therefore, in the event that Productos Zam Fre S.A. de C.V. should modify the content of this Privacy Notice, it will inform you by any of the ways and means established in this Notice.

TENTH. TRANSFER OF PERSONAL DATA. In the event that Productos Zam Fre S.A. de C.V. should transfer your Personal Data to any of its suppliers in order to carry out the Purposes of Processing established in this Privacy Notice, it will do so after entering into confidentiality agreements and, provided that (i) the supplier or person to whom the Personal Data is transferred agrees to submit the processing of the Personal Data to this Privacy Notice, and (ii) it does not involve any of the cases established in Article 37 of the Law.

If you do not express your opposition for your Personal Data to be transferred to third parties, it will be understood that you have granted Productos Zam Fre S.A. de C.V. your consent to do so.

ELEVENTH – SECURITY MEASURES. – Productos Zam Fre S.A. de C.V. is committed to the fact that personal data will be treated under the strictest security measures to ensure its confidentiality; therefore, the necessary administrative, technical and physical security measures have been adopted to protect your personal data against damage, loss, alteration, destruction, use, access or unauthorized treatment.

When we communicate or share your information with third parties that provide us with any service, we require and verify that they have the necessary security measures to protect your personal data, prohibiting the use of your personal information for purposes other than those established.

Nevertheless, Productos Zam Fre S.A. de C.V. cannot and therefore does not guarantee that there will not be unauthorized access to your personal data or that communications will be free of any interruption, error or interception by unauthorized third parties.

Access to your personal data held by Productos Zam Fre S.A. de C.V. will be limited to the persons who need to have access to such information for the purpose of carrying out the identified purposes.

In the event that at the time of providing your personal data to Productos Zam Fre S.A. de C.V. you are assigned a user name and password, you will be responsible for keeping such information confidential. We suggest you not to share this information with anyone.