Privacy Notice.

Based on the Federal Law on Protection of Personal Data Held by Private Parties (FLPPDHPP) published in the Official Journal of the Federation on July 5th, 2010, by this mean we notify you that Acero Prime S de RL de CV, located in Eje 128 No. 209, Zona Industrial del Potosi, San Luis Potosi, SLP, Mexico ZIP Code 78395, is hereby responsible for the use and protection of your personal data and undertakes to the legitimate, controlled and informed processing of the data collected from you as the holder thereof. Likewise, undertakes to not sell, rent, share or disclose your personal data to third parties for illegal or contrary purposes to those of its holder.

According to the above, this “Privacy Notice” applies to all the information, including personal data collected by Acero Prime S de RL de CV and its affiliates or subsidiaries (hereinafter Acero Prime). Given the aforementioned, and as you read this “Privacy Notice” you give your tacit consent to Acero Prime to collect and use your personal data for the purposes specified below, which will be safeguarded in a database under the strictest confidentiality, in accordance with the safety policies and procedures implemented by Acero Prime for such purpose.

(We recommend reading the glossary of terms and definition for better understanding, found at the end of this document)

What kind of information do we collect and what is its pupose?

The personal data we personally or directly collect may include, but is not limited to, the following: identification data, such as: name, personal address, date of birth, Unique Population Registry Code, landline of mobile telephone number, fax, photographs, video images and email. Educational data, such as: academic background, degree, number of professional license, professional specialty, certificates. Employment data, such as: position, address, email, landline or mobile telephone number and fax. Invoice data, such as: person or corporation to be charged, fiscal domicile, tax ID. Financial data, such as: bank account data, method of payment, economic income data.

In addition to the personal data above, for the purposes described in this Privacy Notice, we shall use the following personal data which are considered to be sensitive, requiring special protection: conditions, illnesses or diseases you suffer and medication you take, religion you practice.

In the collection and processing of such information, Acero Prime agrees and undertakes to observe and comply with the principles of legality, consent, information, quality, purpose, loyalty, proportionality and accountability. This means that all the data that we request are collected in a lawful manner in accordance with the Federal Law on Protection of Personal Data Held by Private Parties, with your consent, collecting only and exclusively relevant, accurate, current and necessary data for the purposes described below.

The personal data you provide us will be used to: Evaluate your profile, and if appropriate, hire your professional services; Training; Payment of payroll; Provide, when appropriate, the necessary information required for its incorporation before the corresponding Federal, State and Local Authorities; Establish commercial and professional services relations, in administration, operation and manufacturing services; Providing you the information about our commercial offer, new projects and promotions, whether in electronic media, writings, images, photography and social networks; Collections, billing and data assortment; Evaluate the quality of our service; Conduct internal studies on performance; To take out all kinds of insurance; For the contracting of Notary Public, Lawyers and External Consultants.

Your personal data may be used for different purposes to those described above or to those included in the Privacy Notices provided, as long as such purposes are suitable to those described and might be considered to be analogous.

How is the information used or shared?

We use the personal data that you provide to us solely for compliance with the abovementioned purposes.

In general, we do not share personal data with third parties unless they are our affiliates or subsidiaries, or a third party dully engaged with confidentiality and protection of personal data clauses. Notwithstanding, Acero Prime might transfer your personal data inside and outside the country when such transfer is provided by the Law. You agree that in case that Acero Prime is involved in any operation which may be subject to notice to the Secretariat of Finance and Public Credit in accordance with the dispositions of the Federal Law on Prevention and Identification of Operations with Resources of Unlawful Origin, or, as well, when required by any Authority to provide such information, it will proceed accordingly, without such implying any responsibility of Acero Prime in relation to the protection of personal data under the provisions of the Federal Law on Protection of Personal Data Held by Third Parties. In addition, your information may be shared with Notary Public and/or External Lawyers of Acero Prime, for the collection of debts.

In virtue of the foregoing, you irrevocably consent and authorize Acero Prime to have your personal data transferred in the terms described above.

Revocation of consent to the processing of personal data

You may at any time revoke the consent you have given for the processing of your personal data in order to stop the use of such, provided you are not subject to any legal act with Acero Prime.

For this you must submit your request in writing at the address located in Eje 128 No. 209, Zona Industrial del Potosi, San Luis Potosi, SLP, Mexico, ZIP Code 78395, which shall contain the following information:

  • Full name, address and email.
  • Copy of the holder’s ID, or in its case, a document which credits the representation of the representative or
  • Specify the reasons why you request the revocation of the consent granted.

Once your request has been submitted, Acero Prime shall respond within a term of 20 working days.

Procedure to exercise your rights for access, rectification, cancelation or opposition of your personal data

We remind you that, in the matter of Personal Data Protection, you may exercise your “ARCO” rights according to the following:

Access: You may choose the way you communicate with us either by phone, email, or in a personalized way to know if Acero Prime has possession of your personal data.

Rectification: You can ask us to correct any of your data, in case we have recorded any error.

Cancellation: You may ask us to cancel or eliminate your data as long as there is a cause to justify such action and Acero Prime has no outstanding obligation to cover.

Opposition: If you do not have relationship or legal obligation with us, you can exercise this right, not sharing any data.

You may at any time exercise your rights in the address located in Eje 128 No. 209, Zona Industrial del Potosi, San Luis Potosi, SLP, Mexico, ZIP Code 78395, through a written request, which shall contain the following:

  • Full name, address and email.
  • Copy of the holder’s ID, or the document that credits the representation of the representative or the attorney.
  • The clear and objective description of the personal data to which you wish to hace access and the ARCO right (Access, Rectification, Cancellation or Opposition) you wish to exercise.
  • Any other item or document that may facilitate the location of personal data.
  • In case of Opposition of personal data, it shall also specify the reasons why you oppose to the processing.

Contact

In case you have any questions or wish to exercise any of your ARCO rights abovementioned, you may contact us through our IT or HR department on the following telephone numbers and/or emails:
Telephone Numbers:
+51 1 (444) 870 77 19 Information Technologies Department
+52 1 (444) 870 77 21 Human Resources Management

Emails: hcontreras@aceroprime.com / mvelazquez@aceroprime.com

Once your request has been submitted, Acero Prime shall respond such within a term of 20 working days. And, in case that your request is considered appropriate, Acero Prime shall comply within a term of 15 working days, subsequent to the 20 working days previously described.

Likewise, we notice you that the personal data preservation terms in our data base shall be:

  • If there is a legal, labor, commercial or service relation in force, the personal data will be kept for the entire duration of the relation and may be retained for an additional period of 10 years from the date of termination.
  • In cases not included in the previous paragraph, the preservation of the personal data will be for a maximum period of 5 years.

Once these deadlines have elapsed, and in case the purpose of the processing of the personal data has been fulfilled, they will be canceled, for their subsequent deletion of the database.

Security Measures

Acero Prime has adopted and maintains the security, administrative, technical and physical measures necessary to protect your personal data against damage, loss, alteration, destruction or unauthorized use, access or processing. Regarding data obtained through Internet, our server is also protected by a firewall to prevent unauthorized access to any information we may store. Although these measures are typically effective, use of the internet and related computer systems is inherently vulnerable to unauthorized access or “hacking”. Given this, it is clear that no data communication over the Internet is completely secure, so Acero Prime cannot guarantee that your personal data will be free from all damage, loss, alteration, destruction or unauthorized use, access or processing.

Web Site

Acero Prime’s website may offer links to other websites, which may have information policies and practices that are different from ours. This notice addresses only Acero Prime’s website policy, and does not apply to websites that users access via links from our site. Acero Prime is not responsible for the information collecting policies of other websites, for the practices employed by websites linked to or from our website, or for the information or content contained therein. Often, links to other websites are provided solely on the basis that they may contain useful information for our visitors. Users are advised to review the privacy policy of other websites.

In order to personalize and enhance your experience on our website, we also collect information through “cookies.” Our cookies allow us to personalize your experience on our website, make your visit more convenient, and understand how you and others are using the website so that we can improve your experience on the website. We use cookies to identify repeat visitors to our website and to determine the paths visitors take on our website. We also use cookies to determine whether you visited our website from a particular Internet link or advertisement. We do not use cookies that store personal information or associate cookie information with personal information you may provide to us.

Most web browsers automatically accept cookies, but it is possible to change your browser setup to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, our website will not recognize you when you return, and some functionality may be lost. The Help section of your browser will tell you how to prevent your browser from accepting cookies.

Glossary

For ease of understanding of this privacy statement, we grant you the following meanings:

Implied consent: it will mean that the owner consents the processing of his data tacitly, when having been made the privacy notice available to him, he does not oppose.
Express consent: consent will be express when the will of the holder is manifested verbally, in writing, by electronic, optical or any other technological means, or by unmistakable signs.
Cookies: Small strings of text sent by our website to your browser which are then stored by your browser on your computer’s hard drive.
Personal Data: any information relating to the holder, for example, name, telephone number, address, photographs or fingerprints, and any other data that may help identify the owner.
Sensitive personal data: the personal data which affect the most intimate sphere of the holder, or which misuse can lead to discrimination or represents a serious risk to it. In particular, we consider those which may disclose sensitive aspects such as racial or ethnic origin, health status, past, present and future, genetic information, religious, philosophical and moral beliefs, union membership, political views, and sexual preference.
INAI: National Institute for Transparency, Access to Information and Personal Data Protection.
Holder: the natural person to whom the personal data is related.
Transfer: all communication of data to someone other than the person responsible of the processing.
Processing: the collection, use, disclosure or storage of personal data by any means. Using covers any access, management, use, transfer or disposal action of personal information.

Acero Prime reserves the right to modify at any time this Privacy Notice, which will be made known in writing and/or through a notice on the site: www.aceroprime.com

In terms of the Federal Law on the Protection of Personal Data Held by Third Parties and its Regulations, we hereby inform you that, in the event of your refusal to respond to ARCO rights requests or your nonconformity with them, you may file before the National Institute of Transparency, Access to Information and Protection of Personal Data, the corresponding Application for Protection of Rights in the terms and conditions established by the Law and its Regulations.

For further information on the Federal Law on Protection of Personal Data Held by Third Parties and its Regulations you may visit the INAI’s website: www.inai.org.mx

Last update: July, 2017