Privacy Policy

Last updated: 17.04.2024

This privacy policy (hereinafter, the "Privacy Policy") applies to all personal data provided by the user to Rokaware SAPI de CV (hereinafter, Netzo), with address at Corinto 206, Jardines de San Agustín, San Pedro Garza García, Nuevo León, México, C.P. 66274, through online forms, newsletter subscriptions, the use of the platform, or any other means. The Spanish version of this policy prevails in case of contradictions between language versions of this policy; they are provided for your convenience only.

General Information

For the purposes of this Privacy Policy, the term "User" shall refer to any individual interested in the services offered by Netzo through our website, applications, or any other means. The term "Registered User" shall refer to any individual who has registered on the platform and has accepted the Terms of Service and this Privacy Policy.

The objective of Netzo's Privacy Policy is to provide transparency regarding how we handle your data and to protect the information on the Internet and the data that the user provide us through different means.

Data Controller Identification

In accordance with current legislation, personal data provided to us will be processed by:

Your personal data will be handled in accordance with applicable regulations, including the Federal Law on the Protection of Personal Data Held by Private Parties and its Regulation, as well as any other related laws or regulations in force in Mexico.

Purpose of Processing Your Personal Data

This informs users that Netzo may process the personal data provided by an user through online forms or during the purchase process of any of Netzo's services for the following purposes, to the extent that there is a legal basis for each processing, as explained below:

• (a) Ensure the User's access and use of their personal space in the private area of Netzo's website for services offered by Netzo.
• (b) Manage the purchases and requests made by the User on Netzo's website.
• (c) Inform the User, through any means, including sending commercial communications to the email address provided by the User, about services similar to those acquired by the User offered by Netzo.
• (d) Carry out promotional activities related to other services offered by Netzo, including sending commercial communications to the email address provided by the User, if applicable.

Providing Personal Data

The provison of personal data is, depending on the case, mandatory or voluntary. The User is responsible for the accuracy of the data provided and for keeping it up to date. The User is also responsible for any false, inaccurate, or incomplete information provided, and for any damages, direct or indirect, that this may cause to Netzo or third parties.

User's Responsibility

We value trust and take the privacy and accuracy of your data seriously. As a User or Registered User, it's important to understand your responsibilities when providing and maintaining your personal information.

Data Accuracy and Updates

• As a Registered User, you must ensure that the information you provide to Netzo is accurate, complete, and up-to-date. It's your responsibility to maintain the accuracy of your data to reflect your current situation.
• Any false, erroneous, or incomplete information provided may lead to adverse consequences for both Netzo and third parties. To this end, you are responsible for any damages, direct or indirect, that may arise from the use of false, erroneous, or incomplete information.

Age Requirement

• All Users must be at least 18 years of age, or 16 years of age with the appropriate legal authorization from their legal guardians. By accepting this Privacy Policy, you represent and warrant that you are at least 18 years of age.
• By accepting this Privacy Policy, you represent and warrant that you meet the above mentioned age requirements. In case of unauthorized use by a minor, Netzo will attempt to delete the information as soon as possible.
• If you believe that we may have personal information about a minor, please contact us as soon as possible.

Legal Capacity and Consent

• When using our platform and/or engaging with any of Netzo's services, you assume responsibility for having the necessary legal capacity to process, provide, use, and handle personal data of third parties.
• The same applies to the data the applications you build using our platform may collect. It's your duty to comply with data protection obligations and to obtain consent from individuals whose personal data you handle.
• It's your duty to comply with data protection obligations and to obtain consent from individuals whose personal data you handle.

Purposes and Legitimacy

At Netzo, we process your personal data with clear purposes and a legitimate basis for each processing activity, as outlined below:

Execution of Contract

When you register as a Registered User, we process your personal data to fulfill our contractual obligations. This includes identifying you, generating access credentials, and validating your access to the platform.

It also covers various formalities and requests made available exclusively to Registered Users, such as purchasing goods and services offered by Netzo, accessing your private workspace, and utilizing any other platform functionalities.

As part of this process, you consent to Rokaware transferring data to affiliated companies within the group when necessary to fulfill the contract and provide the contracted services.

Marketing and Commercial Communications

With your explicit consent, Netzo may send you commercial communications about our products and services. These communications may be general or personalized based on your preferences.

You have the right to withdraw your consent at any time, as explained in the section on the Rights of the Data Subject.

Legitimate Interests

Netzo may also process your data to serve our legitimate interests, which include:

1. Preventing Anomalous Practices and Fraud Prevention

• We process data to protect our legitimate interest in preventing anomalous practices that could result in economic damage to Netzo.
• This processing is also essential for fraud prevention in recruitment processes.
• Netzo does not have a legal obligation to bear the negative economic consequences or legal breaches resulting from user actions. Technical and organizational measures are in place to ensure data confidentiality, non-transferability, and security.

2. User Opinion and Platform Improvement

• Netzo may contact users to request their opinions and assessments of our products and services.
• The results obtained from user feedback are used for analytical purposes to enhance the platform's services.
• This processing aligns with Netzo's need to continuously improve and adapt the platform to better meet user preferences. It focuses on aggregate analysis rather than individual profiling.
• You have the option to decline providing your assessment or express your objection to being contacted for this purpose.

3. Operational and Functional Enhancement

• Netzo may create user profiles based on collected data to enhance the platform's operations and functionality.
• Data collected is also used for process automation and checks that support decision-making at Netzo.
• It's important to note that automated decisions are never made that could negatively affect the vital interests or directly harm users.

These legitimate interests ensure that Netzo continually improves its services and operates efficiently, while safeguarding the rights and interests of our users.

Data Retention Duration

Registered Users

The personal data of Registered Users will be processed until one of the following conditions is met:

• The User requests account cancellation.
• The User loses their Registered User status for any other reason, including the exercise of the right to object to the processing.

Data necessary for specific requested services will be retained as long as needed for service provision. Subsequently, this data will be kept for legally established periods to address potential liabilities arising from provided services.

Contact Data for Commercial Communications

Contact data used for sending commercial communications will be processed as long as the User does not revoke their consent. The User can exercise this right as detailed in the section User's rights of this Privacy Policy.

Data Included in User Profiles may vary depending on the type of account and User created, in compliance with legal requirements for service purposes and functionalities.

Data Retention Period

All personal data collected and processed by Netzo through its platform will be securely stored for a period of two years from the last access.

Data that, due to their nature, require longer retention will be stored for periods legally established for each case. Such data may also be disclosed to competent public authorities as per Section 6 of this Privacy Policy.

Data collected during personnel selection processes will be retained for a maximum of six (6) months, unless an employment relationship is established, in which case it will be incorporated into the employee's personal file.

Data Sharing

At Netzo, we are dedicated to safeguarding your privacy and only share your personal data when it's necessary to provide the services you've requested. We may share personal data with the following entities:

1. Affiliated Companies within the Group: We share data with affiliated companies to ensure the proper execution of contracts, especially when they are involved in delivering requested services.
2. Infrastructure and Service Providers: This includes payment processors, cloud service providers, and customer support services.
3. Partners and Agencies: We may share data with partners and agencies who assist in delivering our services, such as consultants, external developers, freelancers, and other service providers, as long as they are directly involved in providing the requested services.
4. Competent Public Administrations and Agencies: We may disclose personal data to comply with applicable legislation, as required by competent public authorities and agencies.

User's Rights

You have the right to exercise your data protection rights applicable regulations at any time. These rights include:

• Right to access your personal data.
• Right to rectify inaccuracies in your data.
• Right to erase your data (under certain conditions).
• Right to restrict processing of your data.
• Right to data portability.
• Right to object to processing.

To exercise these rights, please send a written request containing:

• Your full name and ID card.
• A specific description of your request or the information you seek.
• Your address or email for notification purposes.
• Date and signature.
• Any supporting documents.

Please submit your Data Subject Request by emailing us at [email protected]. We strive to respond to all requests within 30 days, but this period may be extended due to the complexity and number of requests.

Security Measures

We take the security of your personal data seriously and have implemented technical and organizational measures to protect it. While we strive to ensure the security of your data, it's important to note that the internet and computers are not immune to all risks. In the event of a breach of security involving your personal data, we will promptly inform you if it poses a high risk to your rights and freedoms.

If you find a security vulnerability, please report it to us in accordance with our Security Policy.

Updating of Privacy Policy

Rokaware reserves the right to modify this Privacy Policy to align with our evolving needs, platform functionalities, or changes in legislation. Any such changes will be communicated through our platform to keep you informed. It is your responsibility to periodically review our Service and this Privacy Policy for updates that may impact your interests.