INTEGRAL PRIVACY NOTICE

 VELÁZQUEZ, ACEBAL & ASOCIADOS, S.C.

Last Update: June 6th, 2023.

This Privacy Notice is issued in accordance with the provisions set forth in the Federal Law for the Protection of Personal Data in Possession of Private Parties (the “Law”), its Regulations (the “Regulations”) and the Privacy Notice Guidelines (the “Guidelines”), as follows:

 

  1. Name and Domicile of the Controller for the Processing of Personal Data.- Velázquez, Acebal & Asociados, S.C., hereinafter (“VA-Legal”), with domicile at Hegel No. 138 – 201, Colonia Polanco, V Sección, Alcaldía Miguel Hidalgo, C.P. 11560, Mexico City, Mexico, is the legal entity that acts as controller, responsible for the processing, collection, disclosure, storage, use, handling, exploitation, transfer and/or disposal (collectively, the “Processing”) of the personal data of the following individuals (collectively, the “Data Subjects”):
  • Employee candidates.
  • Employees.
  • Persons interested in obtaining information of the services offered by VA-Legal.
  • VA-Legal clients and individuals that form part of their organizations.
  • Third-party providers that render services and/or supply goods to VA-Legal from time to time.
  • Third parties related with VA-Legal’s clients, suppliers and/or services providers.

 

  1. Personal Data that will be subject to Processing.- VA-Legal may collect various personal data from the Data Subjects, as required for the purposes of the Processing and its purposes that are necessary for the provision of the legal services offered by VA-Legal, whether obtained personally or directly from the Data Subject or indirectly, as indicated below in this Privacy Notice.

 

VA-Legal hereby informs that the categories of personal data that may be collected are the following, depending on the type of Data Subject and that are necessary for the provision of its legal services:

 

  • General identification data: Name, marital status, date and place of birth, nationality, Unique Key of Population Registry (if applicable), Federal Taxpayer Registry number or tax identification number and social network profile (including, but not limited to, Instagram® and LinkedIn®).

 

  • Contact information: Contact telephone numbers (home, office and cellphone), address(es) and e-mail(s).

  • Academic information: Academic background and qualifications, including last level of studies and name of the corresponding educational institution(s) and its location, professional degree and certificate, native language and level of learned languages, information contained in the resumes of employee candidates and employees.

  • Financial and patrimonial data: Account numbers and CLABE for purposes of identifying the deposits and/or electronic fund transfers, as well as for purposes of clarifications or reimbursements, if applicable.

  • Legal information: Information that VA-Legal is obliged to collect and Process pursuant to the applicable legal provisions in force and effect from time to time.

  • Sensitive data: Perform, Process and evaluate the results of psychometric tests of the Data Subjects.

 

NOTE: In any case, VA-Legal may collect: (i) any other personal data of any nature that the Data Subject freely provides to VA-Legal by any means, through the VA-Legal website, social networks and any other electronic, optical or any other means of any other technology or nature; and/or (ii) any personal data contained in the documentation that the Data Subject provides to VA-Legal or that VA-Legal requests for the purposes of checking and verifying the information provided by the Data Subject, in relation to the Processing or for any effect related to the provision of legal services, whether through printed, electronic, optical or any other technology or nature.

 

VA-Legal may request copies of the receipts related to the aforementioned personal data, as required for purposes of the Processing.

 

  1. Sources.- Personal data may be collected through different sources:

 

  • Personally: When the Data Subject personally provides his or her personal data to VA-Legal, such as at VA-Legal’s offices.

  • In the case of employee candidates and employees, personal data may also be collected personally during the interview held with them during the hiring process.

  • Directly: When the Data Subject provides his/her personal data through any VA-Legal website, via telephone or by email or social networks to VA-Legal or any person authorized by VA-Legal or by any other electronic, optical, sound, visual or technological means.

  • Indirectly: When VA-Legal obtains the data of any Data Subject from another Data Subject, from any private or public institution, from authorities, third parties or from any other source of information available or permitted by current legislation.

The information collected may be combined to assist VA-Legal for purposes of the Processing.

 

For the Processing of sensitive data, VA-Legal hereby undertakes to comply with the provisions set forth in Article 9 and other applicable provisions of the Law, its Regulations and Guidelines and to obtain the express consent of the Data Subject of such sensitive data for the Processing thereof in accordance with the purposes set forth in this Privacy Notice.

 

  1. Purposes to which the Processing of Personal Data will be subject.- The Processing of the Data Subject’s personal data collected by or provided to VA-Legal, including financial and patrimonial data and sensitive data (if applicable), has the following purposes:

 

  • Primary or necessary purposes:

  1. To know, identify and profile employee candidates and employees.
  2. Evaluate the results of psychometric tests and make decisions based thereon for purposes of the evaluation process and, if applicable, hiring of employees.
  3. Registration in VA-Legal’s directories, databases and systems for the purpose of hiring employees and providing legal services.
  4. Keeping control of access to VA-Legal’s offices.
  5. Quote and provide reports on the legal services offered by VA-Legal, when requested by any Data Subject.
  6. Provide the legal services offered by VA-Legal.
  7. Processing of transfers, bank deposits and cash payments made by the Data Subjects derived from the rendering of legal services or, if applicable, payments for official procedures, as well as, if applicable, making charges or reimbursements in connection with any payments made by the Data Subjects and, if applicable, invoicing and issuance of all types of digital tax receipts (CFDIs).
  8. Integration of Data Subjects’ files.
  9. Providing support with and through the technological tools that VA-Legal may make available to the Data Subjects from time to time.
  10. Judicial and/or extrajudicial collection, in the event of non-compliance with payment obligations related to the legal services hired.
  11. Informing about changes in VA-Legal that should be made known to the Data Subjects.
  12. Compliance with applicable legislation and regulations and meeting the requirements of competent administrative and/or judicial authorities.
  13. Administration of the relationship or possible legal and/or labor relationship between the Data Subjects and VA-Legal and compliance with the respective obligations.

 

  • Secondary or unnecessary purposes:

 

  1. To send to the Data Subjects promotional information about VA-Legal’s legal services offerings.
  2. To send to the Data Subjects informative notes and notes of interest on legal topics.
  3. Send to the Data Subjects information about relevant publications on legal matters in Mexico and/or abroad, as well as in relation to VA-Legal and its activities and/or services.
  4. Invite the Data Subjects to events, conferences and/or videoconferences organized by VA-Legal.

 

NOTE: In any case, if the Data Subject wishes to revoke his/her consent and/or express his/her refusal for his/her personal data to be Processed for any or all of the secondary or non-necessary purposes, depending on the type of Data Subject in question, he/she may do so at any time by sending an e-mail to the address contacto@va-legal.com.mx or exercise his/her right of opposition, in terms of the provisions of Section G) “Means and Procedures for the Exercise of the Rights of Access, Rectification, Cancellation and Opposition of the Data Subject” of this Privacy Notice.

For the purposes of the foregoing, VA-Legal hereby informs that it has enabled an exclusion list that applies to the aforementioned secondary or unnecessary purposes, in which the Data Subject who so requests will be registered, by sending an email to the address contacto@va-legal.com.mx or in writing through other means of contact enabled by VA-Legal.

In any case, the Processing will be such that results indispensable, necessary, appropriate and relevant in relation to the purposes set out in this Privacy Notice, as well as other purposes that are strictly compatible.

 

The Processing may also consist in purposes that are compatible with all of the above, without requiring the consent of the Data Subject to be obtained again, except when strictly necessary and subject to the limitations set forth in the applicable regulations.

 

  1. Transfers of Personal Data.- VA-Legal may make the following national and/or international transfers of personal data to the extent necessary for the purposes of the specific and applicable purpose of the Processing and, where appropriate, for the origin, existence and maintenance of the corresponding legal relationship:

 

  • Primary and necessary transfers:

  • Banking Institutions. Personal identification, contact and financial data may be communicated, to the extent strictly necessary, to banking institutions and payment processors, in order to process electronic fund transfers, bank deposits and cash payments derived from the provision of legal services, payments for official procedures or any other concept, as well as, where appropriate, to make the corresponding charges and refunds or clarify undue or incorrectly applied charges and, in general, to comply with the payment obligations of the Data Subjects, in the event they are the ones who make the corresponding payments.

  • Service providers and collaborators. Personal data may be transferred to VA-Legal’s service providers and collaborators involved in the provision of the legal services offered by VA-Legal and the fulfillment of VA-Legal’s obligations to the Data Subjects.

 

  • Secondary transfers: As a non-necessary purpose, VA-Legal may share personal contact data corresponding to the Data Subject in order to send advertising, promotions and information related to its services, products or events.

 

If the Data Subject does not wish his/her respective personal data is transferred for any or all of the aforementioned secondary transfers, the Data Subject may also at any time revoke their consent or express their refusal by sending an email to the account contacto@va-legal.com.mx or exercise their right of opposition, in terms of the provisions of Section G) “Means and Procedures for the Exercise of the Rights of Access, Rectification, Cancellation and Opposition of the Data Subject” of this Privacy Notice.

 

In any case, third party recipients of personal data shall assume the same obligations and/or responsibilities of VA-Legal, to the extent and with the extent strictly necessary for the purposes of the specific Processing and in accordance with what is described in this Privacy Notice.

 

NOTE: In any case, the personal data of all types of Data Subjects may be transferred, to the extent necessary to:

 

  • Administrative and/or Judicial Authorities. In the event of any disputes arising between the Data Subject and VA-Legal, VA-Legal may transfer Data Subject’s personal data to the extent necessary to legal firms, advisors and notary publics for the proper defense of VA-Legal’s interests, as well as to the competent administrative and/or judicial authorities for such purposes; as well as, if necessary, as part of any requirement, procedure or administrative and/or judicial process, such as the National Institute of Transparency, Access to Information and Protection of Personal Data (“Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales”), judges and courts, among other authorities.
  • Subsidiaries of the same group. For the purposes of the origin, maintenance and termination of the relationship between VA-Legal and the Data Subject, personal data may be transferred to entities that form part of the group to which VA-Legal belongs, which have policies, codes and binding internal standards of privacy and data protection that meet national and international standards for the protection of personal data.

  1. Cookies and Web Beacons.- In terms of Article 14, last paragraph of the Regulations, we hereby inform you that VA-Legal may use: (i) “cookies” on its website https://va-legal.com.mx/, which are text files that are automatically downloaded and stored on the hard drive of the user’s computer equipment when browsing VA-Legal’s website, which exchange status information between the website and user’s browser; and (ii) “web beacons”, which are images inserted in the web page or email, which can be used to monitor the behavior of a user in these media, through which information can be stored on the IP address of origin, the user, duration of interaction time of the page, the type of browser used, operating system, time at which the page was accessed and, in the case of email, the association of the aforementioned data with the recipient, for better performance of the website and improve the user's experience of use and navigation. All of this process is carried out without VA-Legal having knowledge of the name of the user and Data Subject or any other information that could identify the user. While the user visits the VA-Legal website, he/she does so anonymously, unless the user expressly decides to identify him/herself to VA-Legal through the means made available by VA-Legal.

 

The personal data that VA-Legal may collect from these tracking technologies are the following:

 

  • Identifiers, username and passwords of a session.
  • User’s preferred language.
  • Region in which the user is located.
  • User’s browser type.
  • Type of user’s operating system.
  • Date and time of the start and end of a user’s session.
  • Web pages visited by a user.
  • Searches performed by a user.
  • Advertising reviewed by a user.
  • Lists and consumption habits on shopping pages.

These “cookies” and other technologies can be disabled in the configuration options of the browser being used, unless they are necessary for technical reasons.

 

If the Data Subject uses the services on any of VA-Legal’s websites, this means that he/she has read, understood and accepted the terms set out above. If he/she does not agree with them, the Data Subject must not provide personal information or use the services of VA-Legal’s websites.

 

In the case of the use of “cookies”, the “help” button on the toolbar of most browsers will tell you how to avoid accepting new “cookies”, how to have the browser notify you when you receive a new “cookie”, or how to disable all “cookies”.

 

The security and confidentiality of the data provided by users will be protected by a secure server in such a way that the data sent will be transmitted encrypted to ensure its safekeeping.

 

To verify that you are in a protected environment, make sure that an “S” appears in the navigation bar (Example: httpS://.) However, and in spite of having more secure tools every day, the protection of the data sent through the Internet cannot be guaranteed 100% (one hundred percent), so once received, everything possible will be done to safeguard the information.

 

  1. Means and Procedures for the Exercise of the Rights of Access, Rectification, Cancellation and Opposition of the Data Subject.- The Data Subject may exercise his/her rights of access, rectification, cancellation and opposition (subject in any case to the provisions of the applicable regulations), as well as to express his/her refusal for the Processing of his/her personal data for the purposes that are not main or necessary indicated in this Privacy Notice, by sending an e-mail to the address contacto@va-legal.com.mx, between 9:00 and 19:00 hours, in the understanding that, in any case, such Data Subject must provide: (i) its full name, address and email address; (ii) the legal relationship it has or has had with VA-Legal; and (iii) the information and copy of the identification that allows to reliably identify the Data Subject. In the event that Data Subject's request is made through its legal representative, the latter must additionally submit the information and documentation proving his or her identity in order to make the request on behalf of Data Subject.

 

Likewise, Data Subject must clearly and precisely indicate: (i) which personal data are subject of the request; (ii) which right(s) he/she wishes to exercise in relation with the personal data; and (iii) any other particulars that he/she deems necessary or convenient.

 

In the case of requests for rectification of personal data, Data Subject must indicate, in addition to the above, the modifications to be made and attach the documentation supporting the merits of such request.

 

In the event Data Subject's request has been received by VA-Legal on a non-business day, it shall be deemed to have been formally received as of the business day following the day it was received.

 

If the request does not comply with the above requirements, VA-Legal may ask the Data Subject to complete said requirements within a period of 5 (five) business days following receipt of the request and the Data Subject will have 10 (ten) business days to comply with said request, in the understanding that if the request is not complied with by the Data Subject within said period, Data Subject’s request will be considered as not having been submitted.

 

VA-Legal will proceed, through the email provided by the Data Subject, to communicate to the Data Subject, within a maximum period of 20 (twenty) business days as from the date the request is duly completed and delivered, the determination adopted in relation to such request by email, telephone or address provided by the Data Subject, or any other means of public or private communication referred to in any of the documents delivered by the Data Subject and/or his representative or legal representative, to VA-Legal. This period may be extended for 20 (twenty) additional business days when there are reasons that justify it, a situation that will be notified to the Data Subject in accordance with the provisions set forth in Article 97 of the Regulations.

 

If the request is accepted, VA-Legal will carry out the actions related to the request within 15 (fifteen) business days following communication of the response to the request from the Data Subject or, if applicable, their representative or legal representative, in the understanding that VA-Legal may only refuse in the cases permitted by the Law or its Regulations and, if applicable, will notify this to the Data Subject through the aforementioned means. This period may be extended for an additional 15 (fifteen) business days when there are reasons to justify it. In all cases in which the request is appropriate, in terms of the provisions set forth in articles 32, 33, 34 and 35 of the Law, the delivery of the personal data will be free of charge through the e-mail address provided by the Data Subject for such purposes as long as it is technically possible for the purposes of the adequate fulfillment of the request. If the Data Subject requests or due to the circumstances of the case it is necessary that the information is delivered in a different way, the Data Subject shall only cover the justified shipping costs and/or the cost of reproduction in copies or other formats that may be generated.

 

To limit the use and disclosure of your personal data, other than the exercise of the rights of access, rectification, cancellation and opposition or revocation of consent, VA-Legal hereby informs that it has enabled an exclusion list applicable to the additional or secondary purposes indicated in this Privacy Notice, in which the Data Subject who so requests will be registered, by sending an email to the address contacto@va-legal.com.mx or in writing through other means of contact enabled by VA-Legal.

 

If applicable, for the revocation of consent to the Processing of personal data by the Data Subject, he/she shall follow the same procedures and use the same means set forth in this Privacy Notice for the exercise of the rights of access, rectification, cancellation and opposition, subject in all cases to the provisions of applicable regulations. All of the above, in the understanding that: (i) it is important for the Data Subject to consider that not in all cases, VA-Legal will be able to meet their request or conclude the use immediately, since it is possible that due to some legal or contractual obligation with the Data Subject, VA-Legal may need to continue Processing the personal data; (ii) for certain purposes, the revocation of consent will imply that VA-Legal cannot continue providing the requested service or the conclusion of the relationship with VA-Legal and, at all times, the applicability of the request will be subject to the provisions of applicable regulations; and (iii) in the event that it is appropriate to revoke the consent, if any, given by the Data Subject with respect to the personal data that is subject of the request and which gives rise to or has given rise to and is necessary for the maintenance and fulfillment of the legal relationship, if any, existing between VA-Legal and the Data Subject, such revocation could imply the termination of the relationship between VA-Legal and the Data Subject.

 

If the Data Subject does not express his/her opposition in accordance with the procedure set forth in this Privacy Notice for their personal data to be Processed for the purposes and/or transfer of personal data indicated in this Privacy Notice, when such consent is required in accordance with the Law and its Regulations, it will be understood that they have given their consent to do so. The refusal to use your personal data for additional or secondary purposes may not be a reason for VA-Legal to deny the services that the Data Subject requests or hires with VA-Legal.

 

  1. Modifications to the Privacy Notice.- This Privacy Notice may be modified or updated as a consequence of new legal requirements, VA-Legal’s own needs, its privacy practices or for other reasons in terms of the applicable regulations.


Any change to this Privacy Notice will be informed to the Data Subject of the personal data through any of the following means:

 

  1. Publication in VA-Legal’s website: https://va-legal.com.mx/.
  2. E-mail, telephone or address provided by the Data Subject of personal data.
  3. Any other means of public or private communication provided for in the documents and practice of the relationship between the Data Subject of personal data and VA-Legal.

 

  1. Procedure.- In the event of non-compliance and/or violations of this Privacy Notice and/or the provisions of the Law, its Regulations and/or the Guidelines, the Data Subject may initiate the actions it deems appropriate before the National Institute for Transparency, Access to Information and Protection of Personal Data (“INAI”) www.inai.org.mx.

  1. Consent.- The use of the website https://va-legal.com.mx/ and/or the sending of any service or information request through the same shall mean that the Data Subject has read and understood this Privacy Notice and granted his/her consent for the Processing of his/her personal data for the main or necessary purposes and transfers set forth in this Privacy Notice, as applicable to the type of Data Subject in question and as indicated in said Privacy Notice. With respect to such personal data used for the secondary or non-necessary purposes and transfers set forth in this Privacy Notice, if the Data Subject does not revoke his/her consent, express its refusal or exercise its right of opposition in accordance with the process set forth in this Privacy Notice for its personal data to be Processed for such secondary or non-necessary purposes and/or transfers, it shall be understood that he/she has granted his/her consent to do so. The refusal to use your personal data for secondary or non-necessary purposes and/or transfers may not be a reason for VA-Legal to deny the services or information that Data Subject requests or hires with VA-Legal. In the event Data Subject wishes to exercise any of his/her rights of access, rectification, cancellation and/or opposition, limit the use or disclosure of his/her personal data or revoke his/her consent, the Data Subject must follow the procedure set forth in Section G) “Means and Procedures for the Exercise of the Rights of Access, Rectification, Cancellation and Opposition of the Data Subject” of this Privacy Notice.