PRIVACY POLICY

COMMERCE GRENAVEL S.A. DE C.V. (“CreatiVínculo”) is a company incorporated under Mexican law, which provides professional services in the area of digital marketing, with its registered office in Mexico City; and in accordance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (“LFPDPPP”), is committed to the protection of Personal Data (“Data”) of all persons who access the domain https://creativinculo.com/ (“Website”). CreatiVínculo assumes responsibility for the use, handling, and confidentiality of this Data through this Privacy Notice (the “Notice”).

CreatiVínculo is dedicated to safeguarding the rights of privacy, intimacy, and good reputation in the handling of personal data, always acting in accordance with the principles outlined in Articles 6 and 16 of the LFPDPPP.

Additionally, CreatiVínculo reserves the right to update this Notice at any time. Modifications will be reflected by publishing the revised terms on the Services, and the “last updated” date will be adjusted accordingly, located at the top of the document.

  1. What personal data do we collect?

At CreatiVínculo, we collect Data that you actively send us, and we may process your personal data with or without automated means, which includes the collection, organization, storage, analysis, consultation, use, disclosure by transmission, combination, restriction, deletion, or destruction of User Data.

  1. Actively submitted data: The User sends CreatiVínculo their Data when they register on our form, which aims to initiate a dialogue that allows the exchange of information, consisting of: (i) Full Name; (ii) Email Address; and (iii) Name of the Company where they work or own.

When you visit our Website, information that the web browser sends each time you visit a website may be collected. This information may include, but is not limited to, your Internet Protocol address (IP address), browser type, operating system, language preference, any web page you visited before that referred you to our site, date and time of each visitor request, information searched on our resources, and other information collected by cookies or similar technologies. See the Cookie Preferences tool (“Cookie Tool”) posted on our Website to learn more about cookies, including the types of cookies and the specific cookies we use. However, if you do not accept cookies, you may not be able to use some sections or functions of our sites or applications, as described in the Cookie Tool.

  1. What are the reasons for processing personal data?

We process your Data for various purposes; however, the main ones are: (i) To identify, recognize, and validate the identity of Users who wish to join CreatiVínculo; (ii) to manage, operate, and follow up on the Services contracted with CreatiVínculo; (iii) To send emails with information about the contracted Services; (iv) To respond to doubts, complaints, comments, requests, and to provide customer service; (v) To comply with the obligations established by the LFPDPPP, as well as the competent authorities; (vi) For market, advertising, and/or commercial prospecting purposes; and (vii) To use customer and/or user testimonials for purely advertising and commercial purposes related to the Services offered by CreatiVínculo.

We may also use your personal data for internal purposes, such as auditing, data analysis, troubleshooting, and research. In these cases, we base our processing on the legitimate interest of performing CreatiVínculo’s activities.

  1. Who do we share personal data with?

We share your personal data with third parties under the following circumstances:

  • Third-party service providers: CreatiVínculo may provide Data to third parties to process it on our behalf as data processors (e.g., payment processing, maintenance, security, data analysis, web hosting, measurement services, social media messaging controlled by data, surveys, etc.). In such cases, in accordance with this notice and applicable law, providers will be contractually obligated to protect Data against any further processing (including for marketing purposes) or transfer.
  • Legal requirements: CreatiVínculo may access and disclose your Data if we have a good faith reason to believe that such disclosure is required by a subpoena, court order, or administrative order or if required by law in any other way. Additionally, we may disclose your personal information or other information as required by law or to exercise or defend legal rights; to take precautions to avoid incurring in issues related to civil liability; to protect the rights, property, or safety of the resource, any person, or the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or illegal uses; to investigate and defend against third-party claims or allegations; or to assist law enforcement agencies.
  1. How do we protect personal data?

We apply technical and organizational measures to protect the Data we receive to prevent its loss, misuse, and unauthorized alteration and to protect its confidentiality. We periodically review our security procedures and consider new security technologies and methods.

  1. How long do we retain personal data?

We retain the collected Data, including the information collected, for a reasonable period to fulfill the aforementioned processing purposes. Then, we archive it for the period required by law or for other legal considerations. When archiving is no longer necessary, we delete the Data from our records.

  1. How can you access and correct your personal data?

We strive to maintain the accuracy of the Data and rely on you to ensure that your personal data is complete and accurate. The User may exercise any of the Access, Rectification, Cancellation, or Opposition (ARCO) rights, which are listed and explained below:

  • Access: The User may request information about the personal data that CreatiVínculo has stored and how it is used.
  • Rectification: If the personal data that CreatiVínculo has is incorrect or incomplete, the User may request its correction or update.
  • Cancellation: If the User wishes to have their personal data deleted from CreatiVínculo’s database, they can request its cancellation.
  • Opposition: The User has the right to oppose the processing of their personal data for specific purposes, such as sending commercial communications.

The User must send an email to the address [email protected] to exercise their rights, using a free-form format addressed to CreatiVínculo and containing all the elements to attend the request. The ARCO request must contain and be accompanied by the provisions outlined in Article 29 of the LFPDPPP, among others, summarized as follows:

  • The name of the holder and address or another means to communicate the response to their request;
  • The documents that prove the identity or, where appropriate, the legal representation of the holder;
  • A clear and precise description of the personal data for which any of the aforementioned rights are to be exercised; and
  • Any other element or document that facilitates the location of personal data.
  1. Competent Authorities

If deemed necessary, CreatiVínculo informs the User that they have the right to approach the National Institute of Transparency, Access to Information, and Protection of Personal Data (INAI) to assert any dissatisfaction related to the processing of their personal data by CreatiVínculo.

  1. Contact us

Questions regarding this Notice or the security of the Data we process can be sent via our email address [email protected].