1. Responsible of the handling of your personal data

INMOBILIARIA ROMIRA SAPI DE CV (ETHOS), a legal entity duly constituted in accordance to the laws of Mexico, domiciled in Boulevard Kukulcán km. 10 Lote 13-B, Zona Hotelera, CP. 77500 in Cancún, Quintana Roo, is the one responsible for handling your personal data. For the one Responsible, handling your data legitimately is a priority. This Privacy Notice serves as a complement of any other simplified privacy statements that our organization may have presented to you and serves as an addition to all those that purposely do not allude to such notices.

  1. Personal Data Department:

Address: Boulevard Kukulcán Km 10 Lote 13-B, Zona Hotelera, CP. 77500 Cancún, Quintana Roo. Email: ceo@ethoscancun.com and rcorona@sunset.com.mx Phone: +52 (998) 881 4500 ext. 6240 Cell: (998) 214 1560

  1. Objectives of the handling of personal data

The one Responsible gathers your data with the following objective:

  1. To register you as a client of our services
  2. For administrative purposes related to the implementation of the contractual obligations and the execution of the applicable legal obligations
  3. To offer promotions
  4. To follow up on the requirements of our clients
  5. To process your requests thus manage the relationship you wish to establish with Inmobiliaria Romira SAPI de CV or the one already established
  6. To follow up on the requirements and suggestions about products, services and estimates
  7. To guarantee you a correct and suitable service.

In accordance to the guidelines published in the Official Journal of the Federation on January 17th 2013, we inform you that the necessary purposes for the existence, upkeep and compliance with our legal relation appear in detail in inserts a), b) and e) above. In accordance, it is necessary that you indicate your consent for the handling of your personal data in relation to the purposes detailed in inserts c) d) f) and g), as these are not strictly necessary or essential for our legal relation.

□ I give my consent for my personal data to be handled in accordance to all the objectives listed in the terms of this privacy notice.

  1. Personal data collected

We collect the data you provide either in person at the address provided and by phone, email or through our web page. The personal data we obtain is the following:

  1. Name, telephone, address, gender, number of children or people dependent on you, Federal tax payers register number and job references.

In accordance to article 9 of the Federal Law for the Protection of Personal Data in Possession of Individuals, when the one responsible for handling your data gathers it from you, you must give your clearly stated consent, thus we will require that at that moment you indicate if you do or do not give your consent to our handling, through the electronic mechanism we have implemented for such purposes or, wherever appropriate, that you provide us with a duly signed document.

  1. Sensitive, financial and proprietary data we collect

5.1 Financial and Proprietary data.- Our organization will ask you to provide the financial and proprietary data needed for our contractual relation. Such data includes the following:

  1. Bank and bank account numbers and credit and/or debit card information.
  1. Use of Cookies and Web Beacons

We inform you that we do not collect any personal data through the use of Cookies or Web Beacons and other technology to obtain personal information that could include the following:

  • What browser or platform you need
  • The Internet pages you visit
  • The links you follow
  • Your IP address
  • The web page you visited before you clicked into ours
  1. Options and ways to limit the use or disclosure of personal data

You can stop receiving electronic, printed, or phone messages by contacting the one in charge of your Personal data.

  1. Means to exercise the right to access, rectify, cancel or object to the use of your data

You have the right to access the personal data we have in our power and the details about their handling, as well as to correct them in case they are inaccurate or incomplete; to cancel them when they turn out to be undue or unnecessary for the purposes that justified their procurement or oppose their use for a specific objective. The mechanism that has been implemented for those rights to be executed is presenting an application form (“Single form for exercising ARCO rights”) to the one Responsible for your Personal Data whether in person at the address provided or through an email. You can download the form from our web page, click here. In order to exercise your rights you can present a form (“Single form for exercising ARCO rights”) to the person Responsible including the following information: 1.- Full name and address; 2.- Proof of personality ID (Voting card issued by the IFE, valid passport, professional license, or in case you are not Mexican, valid migratory documents); 3.- In case the title holder is not the one presenting the form, a document must be presented to credit the person serving as representative; a notarized power of attorney signed with two witnesses with the title holder’s and the legal representative’s ID (IFE card, valid passport, professional License or, in case the person is of a nationality other than Mexican, valid migratory documents)

  • In the case of minors, the documents to credit the legal representation of the minor will be: birth certificate and identification papers with a photo (one given by the minor’s academic institution), official papers from the Instituto Mexicano del Seguro Social (Mexican Social Security Institute), valid passport or any other document that serves as a valid photo ID, in addition to a declaration under oath by the signee of the document to be attached to the form as the “Certification of legal representation”;
  • In the case of a person medically unable to exercise their rights, the documents to credit legal representation will be: the interdiction act and the photo ID of the person that holds that legal situation, be it an IFE card, a valid passport a professional license or official immigration papers (in the case of non-Mexicans).

4.- A clear and precise description of the personal data which you wish to exercise ARCO rights over, detailing which right you wish to exercise and the reasons why you wish to exercise it. 5.- Any document or information that serves as proof that your personal data is being handled by Inmobiliaria Romira SAPI de CV 6.- In case of requiring the rectification of data, the modifications to be made must be specified as well as all the documents to back this request (a birth certificate, proof of address or any other by which the change to be made can be supported).

    • The one Responsible will respond to your request via email or personally in the aforementioned address within 20 (twenty) business days from the time an acknowledgement of receipt has been sent. In case the request is applicable, the response could be sent via email or presented in person. In order to respond, Inmobiliaria Romira SAPI de CV may ask you to present, at the address mentioned above, an original of the documents that you sent, together with your requisition form, within the 5 (five) business days. If the term has passed and you have yet to present the documents, your request will be filed and the Privacy notice will remain valid until you present a new request form.
    • When the request proceeds and the documents have been duly checked as to the personality and proprietorship of the ARCO rights, the terms to carry out the request will be the following:

To have access to the data: within a period of 15 (fifteen) days from the time of an affirmative response from the one Responsible; the electronic documents guaranteeing your request will be made available to you through the same means used to make your request. For the rectification of data: within a period of 15 (fifteen) days from the time of an affirmative response from the one Responsible; the electronic documents guaranteeing the rectification will be made available to you through the same means used to make your request. For the cancelation or objection to the data: first they will be blocked, from the moment a thorough check of the required documents begins, thus access to personal data will be restricted to any person until there’s a response to the request whether affirmative or negative. In the first instance, within 15 (fifteen) days from the time of an affirmative response from the one Responsible and in the latter instance the data will be unblocked to continue being handled. The terms listed in the inserts above could be postponed only once for a similar period, in case it is necessary, subject to previous notice by the one Responsible. Inmobiliaria Romira SAPI de CV could deny the exercise of ARCO rights in the following cases:

  1. When you are not the owner of the personal data or have not been duly credited as a representative of that owner ;
  2. When your personal data are not to be found in the data base of the one Responsible;
  3. When the rights of a third party are harmed;
  4. When there is a legal impediment or a resolution by a relevant authority that restrict the ARCO rights;
  5. In case of a cancellation, when the personal data are being handled for prevention or medical diagnosis or the management of health services or;
  6. When a rectification, cancellation or objection has taken place previously.

The denial could be partial, in which case Inmobiliaria Romira SAPI de CV will carry on with the procedures to access, rectify, cancel or object the applicable data. The exercise of the “ARCO rights” will be free, but if you repeat your request within a 12 (twelve) month period, the cost will be 3 (three) days of the minimum wage in force in Mexico City, plus the VAT, unless there are substantial modifications to the Privacy Notice that lead to new Requests to Exercise ARCO rights. You must cover the expenses of justified shipment costs or the cost of copies and other formats. For further information, please contact the one Responsible for personal data in the aforementioned email.

  1. Mechanisms and procedures so the owner of the data, in this case, can revoke his/her consent at any moment

At any moment you may reverse the consent you have given for the handling of your data, for that, it is necessary to contact the person Responsible for the protection of your data, where you will be told the procedure to follow.

  1. Transfer of personal data within and outside Mexico

We have made a commitment not to transfer your personal information to third parties without your consent, excepting the special cases foreseen in article 37 of the Federal Law for the Protection of Personal Data in Possession of individuals, and to make said transfer within the terms dictated by the law.

  1. Implemented safety measures

For the protection of your personal data, we have set up administrative, physical and technical safety measures in order to avoid losses, misuse or modifications to your information. When we communicate or share your information with third parties providing us with a service, we require and verify that they have the necessary safety measures to protect your personal data, forbidding the use of your personal information for uses other than those they were meant for; under the understanding that any noncompliance by said third parties with that foreseen in the Federal Law for the Protection of Personal Data in the Possession of Individuals or its Guidelines is the exclusive responsibility of said third parties.

  1. Modifications to the privacy notice

We reserve the right to carry out modifications or updates to the present privacy notice at any given moment. These modifications will be available to the public through the following: (i) noticeable announcements in the corporate office; (ii) bulletins or flyers available in the corporate office; (iii) in our web page www.ethoscancun.com; or (iv)we will send them to the last known email you provided.

  1. Right to promote the rights protection and data verification procedures that the institute advocates

Any complaint or additional information about the handling of your personal data or any doubt in relation to the Federal Law of the Protection of Personal Data in the Possession of Individuals or its Guidelines could be directed to the IFAI. For further information visit www.ifai.org.mx For further information, you can send us an e-mail to the following address ceo@ethoscancun.com.