KLUG Privacy Policy

In compliance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter “the Law”), we allow ourselves to inform you of the following:

Daniel Mauricio Bonilla González (hereinafter “KLUG”), indicating for the purposes of this Privacy Notice, will be responsible for the personal data that is provided by the natural persons to whom they correspond (hereinafter the “Owner” ).

For the purposes indicated in this Privacy Policy, KLUG may collect the Owner’s Personal Data such as: full name, address (proof of address), official photo identification, landline number, cell phone number, email, nationality, date and place of birth, marital status, Federal Taxpayers Registry (RFC or Tax ID), Code Unique Registry Population (CURP), position, account number, economic activity and patrimonial information (relation of assets and relation of incomes) (in hereinafter and as a whole the Personal Data) in any of the following ways: i) when the Owner provides them personally or directly, ii) when KLUG obtains them indirectly, iii) when the Owner uses the website or services online from KLUG and / or iv) when obtained by KLUG through sources permitted by law.

For those people who have the character of contact of an Owner, they are informed that KLUG only requires their Personal Data corresponding to: full name, official identification with photograph, position, landline, cell phone, email, Personal Data of which the Contacts are Owners in terms of this Privacy Notice.


However, for those people who have the character of beneficiaries of the Service of an Owner, they are informed that KLUG only requires their Personal Data corresponding to: full name, official identification with photograph, address (proof of address), nationality, date and place of birth, Federal Taxpayer Registry (RFC or Tax ID), Code Unique Registry Population (CURP), economic activity, Personal Data of which the beneficiaries are Owners in terms of this Privacy Policy.


The Owners who have provided KLUG with the Personal Data of the beneficiaries or contacts, must notify the latter Owners of having provided their Personal Data to KLUG and the content of this Privacy Policy, the foregoing, regardless of the notification that KLUG will make to said Privacy Policy Owners to the first contact you have with them.


It is the responsibility of the Owner of the Personal Data to ensure that the data provided personally or directly to KLUG are true and complete, as well as to notify KLUG of any changes to them to comply with the obligation to keep the information updated.

The information on Personal Data, which is collected by KLUG from the Owner, will have the use described below:

i) For the relationship corresponding to the provision of services by KLUG (hereinafter the Services).

ii) For the fulfillment of the contracts that KLUG enters into with the Owner.

iii) For the identification of the Owner.

iv) For the administration of the Services.

v) For the analysis of the Services.

vi) For updating the Owner’s data.

vii) To evaluate the quality of the service.

viii) To contact the Holder in his capacity as beneficiary to comply with the Services.

ix) Inform about changes or new products or services that are related to the contract acquired by the client.

x) Carry out internal studies on consumer habits.

These purposes are necessary to fulfill the obligations derived from the legal relationship that KLUG has with the Owner.

Likewise, within the use that KLUG will give to the Owner’s information is i) the offer and promotion of services, ii) sending newsletters, invitations and information about the Services, as well as iii) evaluating the quality of the Services, purposes that are not necessarily required to comply with the obligations derived from the legal relationship that KLUG has with the Owner, therefore In the event that the Holder does not agree that KLUG uses their Personal Data for said purposes, they must express their opposition in accordance with the provisions of section 5 of this Privacy Notice, since, in the event that the Holder does not Express your opposition, it will be understood that you give your consent to KLUG.

The timing of the handling of the Owners Personal Data will depend on the legal relationship that is held with KLUG, as well as the obligations required by current legislation, the competent authorities and KLUG’s internal policies.

The information that is delivered to KLUG will be safeguarded, conserved and protected by the latter in accordance with the provisions of current legislation and KLUG’s internal policies in order to maintain the confidentiality of said information.

In accordance with the provisions of the Law, KLUG will give access to the Owner’s Personal Data (through referrals) to those people who have the character of Managers, such as service providers, or partners of

KLUG businesses, that have a legal relationship with the latter, that derived from said legal relationship need to know the information and assume the commitment to keep it under a strict order of confidentiality and security, also recognizing that they are aware of the terms and conditions of this Privacy Policy and committing to comply with them.

Therefore, if the Owner does not express his opposition for his Personal Data to be transferred through any of the means established in section 5 of this Privacy Policy, it will be understood that he has given his consent to do so.

In the event that the protected Personal Data is required by an authority of any kind or must be delivered to the latter in accordance with current legislation, these data will be made available to you in strict compliance with the Law, a transfer that does not require the consent of the Holder in accordance with the provisions of article 37 of said legal order.

The Owners of the information will have the right to request access, rectification, revocation, cancellation or opposition, as well as limit the use or disclosure of their data, through:


a.- Written request addressed to Daniel Mauricio Bonilla González, from 10:00 a.m. to 5:00 p.m., on business days, or


b.- Request made to the email: dataprivacy@klugassist.com


KLUG, will respond to the requests of the Information Owner, as long as any of the exceptions contained in the Law are not updated, and the applicant complies with the provisions of article 29 of said legal order that establishes the requirements that must be the requests presented by the Owners.


In order for KLUG to process the request of a Holder regarding access, rectification, revocation, cancellation, opposition and / or limitation of the use or disclosure of their data, the latter must attach the following information and documentation to their request:


i. Name of the Owner and address or other means for KLUG to communicate the response to your request.


ii. The documents with which you prove your identity or personality in the case of the legal representation of the Owner (official identification of the Owner or legal representative and power of attorney of the latter).


iii. The clear and precise description of the Personal Data with respect to which it is sought to exercise the right of access, rectification, revocation, cancellation, opposition, limitation of use or disclosure, as well as any other data or document that may facilitate the location of the Data Personal.


 


KLUG will respond to the request of a Holder regarding access, rectification, revocation, cancellation, opposition and / or limitation of the use or disclosure of their data within the terms established in the Law, that is, within twenty


(20) days after receiving the request from the Owner, a period that may be extended by KLUG in accordance with the provisions of article 32 of the Law.

In the event that KLUG requires to use your Personal Data for purposes other than those agreed or agreed to in accordance with the legal relationship that it has with the Owner and in this Privacy Policy, or requires the Owner Personal Data other than those indicated in this Privacy Policy, the Holder will be notified in writing, by telephone, electronically, or by any optical, sound, visual or other means that technology allows now or in the future, explaining the new uses that he intends to give said information In order to obtain their consent in terms of the Law. With this Privacy Policy, the holders of the information are duly informed of the data that was collected from them and with what fines, as well as the fact that the Privacy Policy can be consulted at any time on the KLUG website www.klugassist.com

KLUG, reserves the right to modify this Privacy Policy to adapt it to new legislation or jurisprudence, as well as commercial practices. In these cases, the reference changes will be announced on the website www.klugassist.com.

This Privacy Policy, as well as the general handling of the Law made by KLUG, is governed by current and applicable legislation in the United Mexican States, any controversy that arises due to its application must be aired before the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI) or before the competent Jurisdictional Bodies in Mexico City.