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PRIVACY NOTICE

Updated on January 31th, 2020.

Alanis, Flores & Cía., S.C., (hereinafter “AFC”) located at Blvd. Adolfo Lopez Mateos 180, San Pedro de los Pinos, Alvaro Obregon, ZIP 01180, Mexico City, Mexico; in compliance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties, the Privacy Notice Rules and the Binding Self-Regulation Parameters (hereinafter the “Law”), by this mean makes of general knowledge which practices are followed in AFC, in the case that your personal data is collected, processed, stored or used.

The privacy notice herein contains all the characteristics related to the processing of personal data that AFC carries out as responsible for it, through the website: www.alanisflores.com  (hereinafter the "Website") or at their offices. In case that the User after reading this document continues to use the website or continues to request the provision of any Service by AFC, or continue to provide any product or service on behalf of AFC, or intent to register and access to the offices of AFC, you will be expressing your full and express acceptance of this privacy notice and by what means your personal data will be processed.

Otherwise the User must leave the website, or to refrain from accessing the offices of AFC, moreover, refraining from maintaining any type of communication with AFC.

RESPONSIBLE FOR PERSONAL DATA

 

The Responsible of obtaining, disclosing, storing, using, handling, exploitation, transfer and/or disposition of the personal data of clients leads (the "Leads"), real clients (the "Clients") and other individuals (any of the above, a "User"), in connection with the provision of legal services (the "Treatment") is Alanis, Flores & Cía., S.C., ("AFC"), located at Blvd. Adolfo Lopez Mateos 180, San Pedro de los Pinos, Alvaro Obregón, ZIP 01180, Mexico City, Mexico.

PERSONAL DATA COLLECTED

Personal data refers to any information that identifies or makes any individual identifiable (including the email address and / or the IP address in the event that it unequivocally identifies the interested parties) and per user, any individual identified or identifiable that in any way communicates your data to the AFC.

 

a) Regarding Leads:

1. General identification data: name, email and phone number.

2. Legal Information: Information that AFC is obliged to collect and process in accordance with applicable legal provisions.

 

b) Regarding Clients:

1.General identification data: name, date of birth, address, country of citizenship, nationality, place of birth, CURP, social security number, marital status, gender, tax identification number and documentation attesting accrediting legal entry and stay in the country (in the case of foreigners).

 

2. Contact details: phone numbers (home, office and cell phone) with country and area keys and extensions, email and personal and work address.

 

3.Professional or business information: occupation, name of the Client´s company(s) or business(s) as well as the Companies that such Clients provides their services, the industry to which such company(s) belongs, as well as the tax address and telephone number(s) of the same company(s); support documentation of the operations carried out by the Client that are the subject of the legal services.

 

4. Financial data: income and expenses, including information contained in tax and/or fee receipts, invoices, proof of payment and/or electronic funds transfers, proofs covering deductibility of expenses, bank statements, tax returns and information, tax contribution regime, account numbers and CLABE, FIEL and, if the Client wishes, password.

 

5.Legal Information: Information that AFC is required to collect and process in accordance with applicable legal provisions

 

c) Regarding personal data of employees of the Client:

 

In the event that the Client has provided to AFC personal data of its employees for the purposes of providing the legal services, AFC may collect from them:

 

1. General identification data: name, date and place of birth, address, nationality, CURP, social security number, sex, marital status, tax identification number and documentation attesting accrediting legal entry and stay in the country (in the case of foreigners).

2. Professional or business information: occupation, name of the company, industry to which that company belongs, as well as the tax address and telephone of the same, department and position of the employee, type of contract and / or day.

3. Financial data: income and expenses, including information contained in tax and/or fee receipts, invoices, proof of payment and/or electronic funds transfers, proofs covering deductibility of expenses, bank statements, tax returns and information, tax contribution regime, account numbers and CLABE, FIEL and, if the Client wishes, password.

4. Legal Information: Information that AFC is required to collect and process in accordance with applicable legal provisions.

 

In the event that the Client voluntarily provides personal data of its employees or other third parties to AFC, the Client shall ensure and represent that is authorized by the relevant third party to provide AFC with such data and/or that by sharing it with AFC it does not breach any legal or contractual obligation or provision, on the understanding that, in the event of a breach of this paragraph by the Client, the Client shall indemnify, reimburse, and keep and hold harmless AFC from any claim, suit, legal action, fine or procedure in connection with such breach.

In any case, AFC will process the personal data of the third parties in compliance and in accordance with this Privacy Notice.

 

d) Regarding other third parties:

 

In the event that the third party makes payments and/or deposits related to the legal services to be provided to the Client, the AFC may collect account numbers, CLABE, information from the User, as well as, for billing purposes, the key of the Federal Taxpayer Registry or tax identification number; information contained in the document(s) provided to AFC, as well as information that AFC is required to collect and process in accordance with applicable legal provisions.

 

In the event that any User voluntarily provides personal data of third parties to AFC, the User must ensure and declare that it is authorized by the relevant third party to provide AFC with such data and/or that by sharing it with AFC does not breach any legal or contractual obligation or provision, on the understanding that, in the event of a breach of this paragraph by the User, the User shall indemnify, reimburse, and keep and hold harmless AFC against any claim, suit, legal action, fine or procedure in connection with such breach.

In any case, AFC will process the personal data of the third parties complying and in accordance with this Privacy Notice.

 

e) In the case of representatives or legal representatives of the User:

 

AFC, if is applicable, may obtain, regarding the representative or legal representative of the User, its name, date and place of birth, country of citizenship, nationality, address of work, telephone(s) of contact and information to be collected in accordance with the applicable legal provisions or that is necessary for the purposes of the proper accreditation of the personality and powers of the representative or legal representative of the User; and information contained in the document(s) that are provided to AFC in order to prove the identity, legal capacity and powers of attorney of representative or legal representative of the User, as necessary for the purposes of the Treatment. In the event that the User´s representative or legal representative makes payments and/or deposits related to the legal services to be provided to the Client, AFC may collect account numbers, CLABE, information from the owner, as well as, for billing purposes, the key of the Federal Taxpayer Registry or tax identification number; information contained in the document(s) provided to AFC, as well as information that AFC is required to collect and process in accordance with applicable legal provisions.

In any case, AFC will process the personal data of the representative or legal representative of the Owner in compliance with and in accordance with this Privacy Notice.

B) AFC may collect (i) any other personal data of any nature that the User freely provides to AFC by any means, including electronic or other means; and/or (ii) any personal data contained in the documentation that the User provides to AFC in connection with the Processing or for any effect related to the provision of legal services, whether through printed, electronic, optical or any other technology.

AFC may collect a copy of the proofs related to the aforementioned personal data, as required for the purposes of the Processing.

 

C) Personal data may be collected through different sources, including:

 

a) In Person: When the User provides his/her data in the offices or in person to AFC.

b) Directly: In the event that the User provides his/her data through any website or by telephone to AFC or any person authorized by such, by email, or by any other electronic, optical, sound, visual or technological means.

c)Indirectly: In the event that AFC obtains the Data from the User by third parties or any other source of information available or permitted by applicable law.

 

The information collected may be combined to assist AFC for treatment purposes.

PURPOSES OF THE PROCESSING OF PERSONAL DATA AND USER CONSENT

 

Main or necessary purposes:

The main or necessary purposes of the processing of personal data of the User, collected by or otherwise provided to AFC, including financial data are the following:

a)    Regarding the Leads:

1. The identification, profile and knowledge of the Lead.

2. The attention to legal requirements of competent authorities.

3. The quote and reports of the legal services that AFC provides.

4. Registration in databases and systems of AFC for the purposes of the legal services offered by AFC, prior to and after the provision of such services.

5. Contact, rectification and updating of information.

6. Compliance with applicable legislation and regulations, and attention to requirements of competent authorities.

7. The management of the business relationship or possible legal relationship between the Lead and AFC, and the fulfilment of the respective obligations.

 

b)    Regarding the Clients:

1. The provision of legal services and training courses that AFC offers.

2. Assistance in carrying out formalities and procedures before the competent administrative and/or judicial authorities, without the legal representation of the Client.

3.Incorporate the Client´s data into the AFC database for customer service.

4. To provide training and updating courses in legal issues that have been hired.

5. To issue invoices, collection and processing of payment for the provision of the legal services hired.

7. To contact the Client for the purposes of the provision of the legal services hired.

8. To carry out collection and recovery procedures regarding any consideration for legal services provided.

9. To compliance with applicable legislation and regulations, and attention to requirements of competent authorities.

10. The maintenance and compliance with the legal relationship between the Client and AFC in accordance with the legislation applicable to the services provided.

c)    Regarding the employees of the Client:

1. To provide legal services to the Client.

2. Registration and/or discharge of the employee with tax, social security, labour and other administrative authorities for compliance with the legislation in such matters.

3. Compliance with applicable legislation and regulations, and attention to requirements of competent authorities.

d) Regarding the third parties:

1.Incorporate the Client´s data into the AFC database for customer service.

2.Contact the third party for the purposes of providing the legal services contracted, if necessary.

3.Providing legal services to the Client, including performing withholding tax calculations.

4.To issue invoices, to collect and process any payment for the provision of the legal services hired, in case that the third party makes such payment.

5. The complementation to legal requirements of competent authorities.

e)    Regarding the User´s legal representatives:

1.  Verification of the identity, legal capacity and powers of attorney of the representative or legal representative of the User and, in general, for the purposes of representation of the User.

2.  The integration of the User´s data to the AFC database for customer service.

3.  The issue of invoices, collection and processing of any payment for the provision of the legal services hired.

4. Contact the representative or legal representative in order to follow up the legal services provided.

5. To carry out collection and recovery procedures regarding any consideration for legal services provided.

6. To compliment any legal requirements of competent authorities.

ADDITIONAL OR SECONDARY PURPOSES

In the case of Leads, Clients and/or legal representatives or representatives, AFC may use the general personal identification and contact data:

 

1.The improvement of the customer service procedure.

2. To provide information about products, services or events, including advertising, newsletters and surveys, as well as the granting of acknowledgements and attention.

 

If the User does not want such personal data to be processed for any or all of the additional or secondary purposes, the User may also at any time manifest such refusal by sending an email to the address info@afc.mx.  In the event that the User does not manifest his refusal, at any time the User may exercise his right to revoke the consent or opposition in terms of this Privacy Notice, the Law, its Regulations and Guidelines.

 

In order to limit the use and disclosure of the User´s data, AFC makes available an exclusion list applicable with respect to the aforementioned additional or secondary purposes, in which the User shall request such action by sending an email to the address info@afc.mx

 

In any case, the Processing will be the one that is indispensable, necessary, adequate and relevant in relation to the purposes provided for in this Privacy Notice, as well as for the different purposes that are strictly compatible.

 

The Processing may also consist of purposes that are compatible with all of the above, without for this purpose, when strictly necessary, it is

necessary to obtain the consent of the Owner again, and subject to the limitations established in the applicable regulations.

TRANSFER OF PERSONAL DATA

AFC may transfer, its partners, affiliates, employees, customers, suppliers and professional associations to which it is linked, whether they are located in Mexico or abroad, all or part of the personal data provided by the user, as well as to third parties that are legally, professionally or commercially related AFC, in order to meet the objectives for which the user provided his/her information and for the purposes described in this privacy notice, or those described in the registration forms, or when a service is offered through the website or at the domicile of AFC. AFC may also transfer your personal data in the cases set forth and authorized by the applicable legal provisions.

Apart from the above, AFC is only intended to carry out transfers or communications of personal data as required by the legal provisions, and with the aim of meeting its legal obligations.

Furthermore, the User is herein informed that any other transfer of personal data to be performed, will be made of your knowledge when so required by the legal provisions, stating explicitly, precisely and unequivocally who are the recipients of the information, the purpose for which the data will be used and the nature of the transferred data, or whenever required by the legal provisions, prior, unequivocal, specific and informed consent from the user will be prompted.

EXERCISE OF THE RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION. LIMITATION TO THE USE OR DISCLOSURE OF DATA AND REVOCATION OF CONSENT.

The user has the right to access his/her personal data held by AFC, as well as to know the characteristics of the processing given to them; to rectify them if inaccurate, not current or incomplete; to request that they are canceled if the user considers that they are unnecessary for the purposes for which they were collected and not being processed in accordance with the principles and duties established by the legal provisions and to oppose their processing for specific purposes. Similarly, the user may request that the use or disclosure of his/her personal date is limited, and to revoke any consent previously granted.

The user can address his/her opposition by sending an email to the email address info@afc.mx, using the reference opposition as well as the right to revoke its consent requesting the unsubscription to the service for receiving commercial communications, by sending an email to the address aforementioned with the reference “unsubscribe.

 

To exercise the above ARCO rights, you must file an application, under the terms set forth in the legal provisions (including: i) name and address of the data owner, or other means for receiving a response; ii) documents proving the identity or the user or the legal representation, if done by proxy; iii) a clear and precise description of the data for which the user seeks to exercise his/her rights and other items or documents to facilitate the location of the data), either in person (at the address specified earlier in this document) or send an email to the email address aflores@afc.mx, attaching a copy of his/her official identification.

DISCLAIMER

AFC warns the User that it is only responsible and guarantees the confidentiality, security and processing of the data in accordance with this notice, with respect to the personal data collected directly from the User through the  website or at the address of AFC, having no responsibility for the processing and subsequent uses of personal data that may be made by third party service providers who have access to the user's information because of the relationship that the user establishes with AFC, in terms of the transfers for which the user has been notified in this privacy notice, and that accepts that AFC may make.

Third party providers of information society services shall mean, without limitation, those natural or legal persons providing the following services: (i) Transmission by a data communication network provided by the recipients of the service. (ii) Network access services. (iii) Data storage or hosting services. (iv) Provision of content or information.

In addition, AFC is not responsible for the processing of data carried out by third parties that have hyperlinks on the AFC website.

 

DATA QUALITY

The user is hereby warned that unless acting as a legal and valid proxy, no user can use the identity of another person and communicate his/her personal data. Therefore, if you use the email services, you can only include personal data of your own identity and provided they are adequate, relevant, current, accurate and true. As a consequence of it, the user is solely liable for any direct and / or indirect damage caused to any third parties or to AFC, derived from the use of personal data belonging to another person, or their own personal data when they are false, misleading, not current, inappropriate or irrelevant.

COOKIES AND BEACONS

The user has the right to access his/her personal data held by AFC, as well as to know the characteristics of the processing given to them; to rectify them if inaccurate, not current or incomplete; to request that they are canceled if the user considers that they are unnecessary for the purposes for which they were collected and not being processed in accordance with the principles and duties established by the applicable legal provisions and to oppose their processing for specific purposes. Similarly, the user may request that the use or disclosure of his/her personal date is limited, and to revoke any consent previously granted.

The user can address his/her opposition by sending an email to the email address info@afc.mx,  using the reference opposition as well as the right to revoke its consent requesting the unsubscription to the service for receiving commercial communications, by sending an email to the email address info@afc.mx, with the reference unsubscribe.

To ensure that the website is being well managed and to facilitate improved browsing within it, AFC, as well as the Internet service providers may be using “cookies” (short text files stored on the user’s browser) or “web beacons” (electronic images that allow the website to count the number of visitors and users who have accessed a particular website and access to certain “cookies”) to store and add information. AFC can use these tools to track information on its systems and identify categories of users of the website by items such as IP addresses, domain, browser type and pages visited. This information is reported to the Webmaster of AFC and may be used to analyze the number of visitors and users of the different areas of the site and thereby ensuring the usefulness of our website as a source of useful and effective information.

Both the “cookies” as “web beacons” store personal information such as names or email addresses. Most browsers allow users to reject “cookies” (usually in the Tools menu). Note that in specific circumstances, access may be denied in certain parts of our site visitors and those users whose browsers do not allow the use of “cookies”.

SECURITY MEASURES

AFC informs the user that, in accordance to the applicable legal provisions, it has adopted the necessary technical, administrative and physical measures to ensure the security of personal data and to prevent any alteration, loss, or unauthorized access, given the state of technology, the nature of the data stored and the risks to which they are exposed, whether from human or physical action or natural environment, being the case that AFC  will only record personal data in databases which fulfill the conditions specified in these systems regarding their integrity and security and treatment centers, premises, equipment, systems and programs.

UPDATE NOTICE OF PRIVACY

From time to time, AFC will update this privacy notice.

In any event it is the sole responsibility of the user to periodically access the privacy notice posted on the website in order to know at all times the latest version.

 CONTACT

With the aim of making any comments or observations about this privacy notice, you may contact AFC either through email or via post service at the address shown below:

info@afc.mx

Alanis, Flores & Cía., S.C.

Blvd. Adolfo López Mateos 180, San Pedro de los Pinos, ZIP 01180, Mexico City, Mexico.

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