I. Identity of the Firm.

Ibarra, del Paso, Gallego y Berezowsky, S.C. (the “Firm”) with its domicile at Juan Salvador Agraz 50, 7th Floor, Santa Fe, Cuajimalpa de Morelos, México, Federal District, is an entity that complies with the Federal Law for the Protection of Personal Data Held by Private Parties (the “Law”) and other applicable legislation, including the Civil Code for the Federal District and the Law Regulating Article 5 of the Constitution, Regarding the Practice of Professions in the Federal District.

The Firm is a law firm that provides various services related to legal advice in several areas of law, hereinafter identified as the “Services”. For the offer, quotation and rendering of the Services, the Firm requires to collect and transfer personal data (including sensitive personal data, as well as financial or economic data) in order to evaluate legal contingencies, prepare documents related to the operations of its clients, contract services with third parties, such as public notaries, process and obtain official documentation from various governmental institutions at the municipal, local and federal levels, coordinate with third parties with whom its clients conduct business, carry out legal due diligence processes over assets or individuals, as well as to plan, execute and follow up on the necessary processes and procedures for its clients in connection with the Services offered by the Firm.

One of the most important priorities of the Firm is the commitment with the privacy and protection of the treatment of the personal data it collects from its holders, either prospects or clients for any of its Services (collectively the “Holders”). Therefore, the Firm makes this Privacy Notice (the “Privacy Notice”) available to the Holders, which is a commitment regulating the treatment of your personal data (including its obtainment, use, disclosure or storage) by any mean with the purpose of guarantying the privacy and the right of informational self-determination. In virtue of the foregoing, the Firm shall adopt all the necessary and sufficient measures pursuant the Law to guarantee that this Privacy Notice is observed at all times by the Firm itself or by third parties with whom it maintains privity.

II. Obtainment of personal data.

The Firm obtains personal data which are treated pursuant this Privacy Notice, through the following ways: when the Holders provide us such data by any means, when visiting our website and when obtaining information by other sources that are permitted by the Law.

We collect your personal data when you, as a Holder, provide us such data by several means, such as when you provide us with information with the purpose our preparation of a quotation of Services for you, render a Service for you or provide you with legal representation.

The data we obtain by these means might be: Federal Tax Identification Number, place and date of birth, nationality, marital status and patrimonial regime, description of certain estate assets, documents of certain operations that you perform, have performed or pretend to perform, tax and/ or financial information, place and date in which your identification document was issued and will expire, domicile for tax purposes, contact information such as phone number and e-mail address, social security number, Single Population Registration Code (Clave Única de Registro de Población “CURP”), employment description, legal, business and regulatory compliance practices, electronic advanced signature (Firma Electrónica Avanzada “FIEL”) issued by the Tax Administration Service (Servicio de Administrtación Tributaria, SAT) as well as any information that, in a case by case basis, the Firm deems convenient or requires in general for the rendering of the Services and/or related activities.

We inform you that we use cookies and beacons in order to obtain personal information from you, such as the following: your kind of navigator and operative system; the web pages you visit; the links you follow; the IP address; and/or the web site you visited before entering our web site. These cookies and other technologies may be disabled, in order to know how to do so, send us an e-mail to the electronic address mail@ibarrapg.com.

The personal data that we collect through other means permitted by Law include the business cards, either physical or electronic, that are turned in or sent to us by the Holders themselves, or the information that such Holders provide us when they contact us by phone or by e-mail.

III. Sensitive and patrimonial personal data.

The Firm informs you that, with the purpose of fulfill some of the purposes foreseen in this Privacy Notice, personal sensitive and patrimonial data shall be collected such as those referring her racial or ethnic origin, current or future health status, genetic information, religious, philosophical and moral beliefs, syndical affiliation, political opinions, sexual preferences, nationality, marital status, financial capacity, economical solvency and, if married, patrimony regime, as well as information related with certain assets or resources that might be involved in the operations that you pretend to perform. Likewise, the Firm informs you of its commitment with the Holders of such personal sensitive and patrimonial data that in this regard. Those data shall be managed under safety measures that guarantee its confidentiality.

IV. Purposes.

The information that the Firm collects from the Holders, either prospects or clients, shall be used for the following commercial legitimate purposes:

1. 1.- Provide the information related to the Services that the Holders had requested or contracted;

2. 2.- Evaluate and analyze the information received for the provision of Services in which the Firm specializes;

3. 3.- Know the profile of the Holders in their capacity of clients or prospects of the Firm;

4.- Comply with the legal relation assumed with the Holders or other clients, even after such relation is terminated, and for the statute of limitations periods for the causes of action that might derive from such relations in accordance with law;

5.- Inform the Holder about any amendments, supplements or extensions in the Services, either contracted by the Holder or those which, the Firm’s discretion, could be of the interest of the Holder;

6.-For internal purposes, such as evaluate the quality of the service we provide the Holder or to perform internal surveys, such as statistical information, actuarial, consumer profile and consumption habits; as well as to compare the information received with similar cases in which the Firm participates at any moment;

7.- Take advantage of and enrich the infrastructure of the Firm at the local and international levels, as well as the supervision and monitoring of the performance of different clients and alliances with other law firms of the Firm (both at local and international level); reflect the information of the Holder in the Services that the Firm prepare for her as well as for advertising and promotional purposes at the Firm’s our Internet webpage and the various materials and media that we produce and update from time to time for such purposes;

8.- Notify immediately to the Holders in the event of a security violation occurred in the data base that significantly affect patrimonial or moral rights of them. If any security violation exists in the safety measures implemented to protect the personal data, the Firm shall notice immediately through the e-mail the Holders, so they can exercise what which serve her interests and protect her interests;

9. Perform any obligations (either administrative, regulatory or normative) to which the Firm, the Services or the Holders are obligated before any competent authority, including without limitation the Federal Law for the Prevention and Identification of Transactions with Illicit Source Resources (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita) its Regulations and General Character Rules to which such law refers; and

10. Communicate the Holders the changes that, as the case may be, the Firm makes to this Privacy Notice.

V. Consent.

The Holder grants her consent so that the information that she has provided to the Firm is treated pursuant this Privacy Notice and the applicable legal provisions. Likewise, the Holder grants the Firm the power to obtain, use (the use might cover any access, handling, utilization, transfer or disposal of personal data), disclose or store her personal data through the means that the Firm deems suitable and during the time that the Firm deems necessary subject to the limits set forth by the Law, with the purpose of fulfilling the purposes foreseen in this Privacy Notice and abide by the applicable legal provisions to which the Firm, the Services or the Holders themselves are subject to.

VI. Transfers of personal data.

Through this Privacy Notice, the Firm informs the Holders that their personal data might be transferred and handled inside and outside of the country, to persons other than the Firm. Scilicet, such transfers might be made to persons that are not related parties of the Firm, as well as law firms and other service providers, such as public accountants, business analysts, surveyors, expert translators, public notaries and trainers, and other professionals and/or suppliers that are required for the provision of the Services and related activities or services, that are directly related with the Firm, and who will be informed about the limitations and purposes of this Privacy Notice, when necessary for:

1. Evaluate and analyze the request for the performance of any Service offered by the Firm;

2. Perform the necessary acts so that the Firm performs its obligations with the person who requests a Service and with whom the Firm holds a relation for such purposes;

3. Make consultations, researches and reviews in connection with the Services provided by the Firm;

4. Establish, hold or comply with a legal relation acquired with the Holders or other clients, even after such relation is terminated, during the statute of limitations period of the causes actions that may derive from such relations; and

5. For internal purposes of the Firm, such as comparison of information for studying purposes, internal training or others.

In accordance with the foregoing, the information of the Holder might be shared with public notaries, offices of the Public Registry of Property and/or Commerce of different states or at the federal level, governmental offices of all kind, including but not limited to ministries of the executive administrations, both at the federal government and the states of the Mexican Republic, municipal authorities or other authorities, third parties with which the Holder pretends to establish, has established or has had established commercial relations of any nature and/or with the advisors of same, several service providers, including without limitation national and international courier, certifications, validations, verifications, and attestations, as well as apostille and formalization procedures of any nature, firms of advisors with which the Firm holds strategic alliances, financial institutions and insurance companies.

If you in your capacity of Holder do not express your opposition for the transfer of your personal data, it will be understood that as of this moment you authorize it and that further you have granted your consent thereof.

VII. Principles.
The Firm commits itself to take measures to ensure that treatment of the personal data is carried out in accordance with the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility that the Law establishes. Likewise, the Firm commits itself to keep the personal data contained in its data base in exact terms, in such manner that the same are pertinent, correct and updated for the purposes for which they were collected, and to handle them in a manner that results necessary, adequate and relevant in connection with the purposes foreseen hereof and pursuant to what is agreed under this Privacy Notice.

The lapse of time that the firm shall keep the personal data it collects, shall be the necessary for the fulfillment of the purposes of this Privacy Notice and the obligations that the Firm has acquired with the holders of such personal data.

VIII. Safety Measures.

The firm maintains and shall adopt the safety, administrative, physical and technical measures, actions, procedures and mechanisms that privilege the Holder’s interests and which guarantee the due treatment and protection of the personal data that it collects, in the same way it guards its own.

IX. Exclusion lists.

If you wish stop receiving advertising e-mails or postal mails from the Firm, you may request so in the “Unsubscribe” section of our web page or request it through the e-mail address mail@ibarrapg.com.

X. Exercise of the access, rectification, cancelation and opposition rights (hereinafter the “ARCO Rights”) to the treatment of the Holder’s personal data.

The Firm shall guarantee the Holders whose information appears in our data basis, that they may exercise their ARCO Rights at any time and without delay, as well as the right to limit the use of their information and to partially or totally revoke the consent that the Holder had granted us through the procedure described below:

1. The ARCO Rights shall be exercised by the Holder or her legal representative, pursuant to the following:

a. The Holder shall evidence her identity, through the presentation of a copy of her identification document and upon submitting the original for its collation.
b. By the legal representative of the Holder, prior accreditation of:
i. The Holder’s identity;
ii. The representative’s identity, and;
iii. The existence of the representation, through public deed or proxy letter granted before two witnesses, or with the Holder’s appearance and in-person statement.
2. The Holder or her legal representative shall file a request in writing addressed to the individual who is responsible of the personal data at the Firm, in its offices located at Juan Salvador Agraz 50, 7th Floor, Santa Fe, Cuajimalpa de Morelos, México, Federal District, México, Z.C. 05300 with telephone number 52 (+55) 5202-0717 or to the e-mail address mail@ibarrapg.com , which shall contain the following data:
a. Name of the Holder, domicile, telephone or e-mail address, so that the Firm’s individual responsible of the personal data is able to communicate an answer.

b. The clear and precise description of the personal data in respect of which the Holder seeks to exercise any right.

c. Any element or document that facilitates the location of the personal data in our data basis.

d. In case of requests for the rectification of personal data, the Holder shall also indicate the modifications that she pretends to carry out and provide the documentation supporting her petition.

3. The Firm shall communicate the Holder the determination that it adopts in a term that shall not exceed twenty days counted as of the date in which the request was received.

4. If the determination mentioned in the foregoing numeral is justified, the Firm shall make it effective within the next fifteen days following the date in which the answer to the Holder is communicated.

5. The Firm may deny the access, rectification or cancelation of personal data, or oppose to the treatment of same in the events foreseen in Article 34 of the Law, which in its relevant part reads:

“The responsible party may deny the access to the personal data, or to make the rectification or cancelation or allow the opposition to the treatment of same in the following cases:

I. When the requesting party is not the holder of the personal data, or the legal representative is not duly credited for such purposes;

II. When the personal data of the requesting party are not at her data base;

III. When third-party rights are harmed;

IV. When there exists a legal impairment, or the ruling of a competent authority restricting the access to the personal data, or which does not allow the rectification, cancelation or opposition of same, and:

V. When the rectification, cancelation or opposition has been previously made…”
The Firm designates Patricia Romero Escalante as the individual responsible for the personal data, who will be available at the aforementioned domicile of the Firm, at the phone number 52(+55) 5202-0717 and e-mail address mail@ibarrapg.com.

XI. Modifications to the Privacy Notice.
The Firm reserves the right to perform, at any time, modifications or updates to this Privacy Notice, for the attention of legislative novelties, internal policies or new requirements for the provision or offering of the Services or other reasons. These modifications shall be available to the public through the Internet web page of the Firm in the section “Legal Notices” and/or “Privacy Notice” or, as the case may be, will be circulated to the last e-mail address that the Holder had provided to us. Alternatively, such modifications shall also be available through visible announcements in our offices, or in leaflets or brochures available at our offices.
Last updated: June 30th, 2014.

Any messages and information issued by any member of, or entity associated with Ibarra, del Paso, Gallego y Berezowsky, S.C. (the “Firm”) or otherwise disseminated through means that are controlled by the Firm, whether in electronic, printed, oral or in any other format and/or media, as well as any attachment to same may contain confidential information subject to legal privilege and confidentiality duties and which disclosure may be forbidden by legislation currently in force and effect.

It cannot be guaranteed that Internet and/or electronic communications are timely, secure, error or virus-free. The Firm disclaims any liability and does not accept obligations of any nature due to any error or omission that arise as a result of such communications.

If you are not the intended recipient of such message/information (or otherwise the person responsible for delivering it to the addressee), by these means you are hereby notified that any review, retransmission, distribution, copying or other use or action carried out based on, or related with the data contained in such message/information and attachments thereto are prohibited.

If you are not the intended recipient of such message/information and attachments thereof or if you have received same in error, please: (i) do not read it, (ii) reply to the sender indicating that you received the message/information in error, and (iii) erase or destroy the message/information without keeping any copies of same. Thank you.

Legal advice contained in such messages/information is solely for the benefit of the Firm’s client(s) in the particular matter that is the subject of such message/information, and may not be relied upon by any other party.

The contents of the messages and information that Ibarra, del Paso, Gallego y Berezowsky, S.C. (the “Firm”) issues, are not intended nor should be construed or used at any time and under any circumstances for purposes of avoiding or evading the performance of fiscal obligations or the application of sanctions that may be imposed by competent authorities pursuant to legislation that is currently in force and effect.

Likewise, the criteria contained at the messages and information and its attachments that are issued by the Firm may differ from the criteria made available for knowledge by tax authorities in terms of paragraph h) of section I of article 33 of the Federation’s Fiscal Code (Código Fiscal de la Federación). In the same way, the legal advice that the Firm renders to its clients may be contrary to the tax authorities’ interpretation.


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