A. Identity and address of the person responsible.

 

Pursuant to the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (the “FLPPDPP”), its regulations (the “Regulations”) and other provisions applicable to the matter, St James International (hereinafter, the “Regulations”) Responsible” or “St James International”, interchangeably), indicating as address for all purposes applicable to this Privacy Notice and other issues related to it, the one located at Calle Río Niagara 61, Colonia Juárez, Alcaldía de Cuauhtémoc, CP06500, in Mexico City, informs you that during the processing of the personal data that you provide us, we will establish the necessary measures to comply with the principles of legality, quality, consent, information, purpose, loyalty, proportionality and responsibility established by the FLPPDPP, and the Regulations the personal data that you provide us.

 

B. Personal data collected and processed.

 

The personal data that you freely and voluntarily provide to St James International by any means that we make available to you, or that reaches us through publicly accessible means, or by any other lawful source (hereinafter and collectively “Personal Data”) considering at all times the interests that assist you in terms of the Law and Regulations, may include:

 

1. Personal information:

 

Full name, address, telephone numbers, photograph, Federal Taxpayer Registry (TIN), Voter Credential (INE) in Mexico, Unique Population Registry Code (CURP), gender, nationality, place and date of birth, level of education, address email address (e-mail), driver's license number, professional and academic training, work experience, marital status, general information about family members (parents, siblings, spouses, children), information about current and previous employment, personal references of third parties, as well as other identification data, physical characteristics, biometric data (such as fingerprints, image of your face), academic data, employment data, legal data, immigration data, as well as other data of the same nature and exclusively under this category. The personal data of third parties provided by you to St James International for the fulfilment of the identified purposes or for secondary purposes (for example, data of family members or beneficiaries), must be done so after you have informed them about the existence of the processing of your personal data and the content of this Privacy Notice.

 

1. Financial and/or Wealth Data:

 

Housing Credit Number with the Institute of the National Housing Fund for Workers (INFONAVIT), Retirement Fund Administrator (AFORE), affiliation to the IMSS, bank accounts and/or transactions, property relations, gross income and/or net, average monthly expenses, debts with third parties, personal or leased real estate and personal property and its value, bank account number(s) and “Clabe” account number(s) for electronic transfers, and data of the same nature and exclusively under this category.

 

1. Sensitive Data:

A religious, social, civic or cultural association, blood type, weight, height, diseases, current state of health, tattoos, union membership and hobbies, entertainment and and data of the same nature and exclusively under this category.

 

For consultation and verification purposes, as well as to ensure that the Personal Data that you have freely provided is correct and current, St James International may collect information from personal references, employment references and other sources such as telephone or employment directories, job boards, databases considered public, among others.

 

C. Purposes of the treatment.

 

The Personal Data that we process in accordance with this Privacy Notice will be used only to comply, in the first instance, with the purposes inherent to negotiating and specifying, where appropriate, the commercial relationship with you, as well as the negotiations, planning and carrying out of the businesses and commercial activities that we maintain with third parties or those in charge who are perfectly identified and to whom we transmit this Privacy Notice for compliance and, secondly, for purposes that do not necessarily address the employment relationship that we maintain with you, purposes that are divided into two categories, for your information:

 

Primary Purposes or Necessary Purposes:

 

1. Management, control, administration and updating of information related to clients and legal representatives of clients (in the case of legal entities) of St James International, necessary to celebrate and confirm operations, to contract services with St James International and to ensure the security and confidentiality of operations.

2. St James International clients, in accordance with current and applicable legislation.

3. St James International clients, in accordance with current and applicable legislation.

4. Management, control, and administration of communications between St James International and its clients.

5. Monitoring, control and evaluation of audits to ensure compliance actions established by national and international legislation and international treaties to which Mexico is a party.

6. Ensure compliance with obligations of confidentiality, good repute and transparency; as well as legal provisions on the prevention of money laundering and financing of terrorism and other sectoral regulations; through the implementation of administrative and technical procedures established for such purposes.

7. Management, control, and administration of judicial or extrajudicial collection of services provided by St James International.

8. Customer service and follow-up on complaints and/or clarifications through the means of communication established for such purposes by St James International.

9. Statistics and historical record of clients and legal representatives of clients of St James International.

 

b. Secondary Purposes or Non-Necessary Purposes:

 

1. Sending communications about offers and new products and/or services provided by St James International.

2. Sending information and commercial offers (electronic and physical) about products and/or services offered or produced by third parties.

3. St James International business partners.

4. Sending information about social events organized by St James International.

5. Sending information about recreational, educational, or cultural activities organized by St James International.

 

If you do not agree with the aforementioned purposes, we inform you that you will have a period of no more than (5) five calendar days from the date on which this Privacy Notice is made available to you to remove us and your refusal via email to our Personal Data Office, whose data is provided below.

 

The rights of the owner to exercise their rights to revoke consent or opposition are safeguarded, in the event that they do not express their refusal to process their personal data, prior to their delivery or use.

 

D. Transfers of personal data.

 

Your personal data may be transferred within the national territory or abroad, to the following categories of recipients and for the purposes identified below as well as those indicated in the previous section:

 

1. Parent, affiliated or subsidiary companies of St James International; for the purposes of centralized safeguarding of information; compliance with information obligations, transparency and prevention of money laundering, as well as statistical purposes and historical registration of clients and their legal representatives.

2. Public organisms; Federal, state or municipal public administrations; Commissions; Institutes and/or Regulatory Entities; for compliance with information, transparency and prevention of money laundering obligations; as well as for compliance with judicial or administrative requirements issued by competent authorities.

3. Agencies, entities or authorities abroad; for the fulfillment of requirements or requests with effects in Mexican territory, or enforceable in accordance with International Treaties to which Mexico is a party.

4. Financial entities; for compliance with information obligations, transparency, prevention of money laundering, and other legal provisions.

5. Third parties (commercial alliances): with the exclusive purpose of providing you with additional products and/or services to your contract.

 

E. Exercise of ARCO Rights.

 

In all legally appropriate cases, you may exercise your rights of access, rectification, cancellation and/or opposition (“ARCO Rights”) at any time through the procedures that we have implemented.

 

The corresponding request must comply with the requirements established in current legislation, by writing to our Personal Data Department at admin@stjamesinternational.com .
 

The request must contain and be accompanied by the following:

     

I. Name and address of the owner, or other means to communicate the response to your request.
II. Documents that prove your identity or, where applicable, legal representation.

III. The clear and precise description of the personal data with respect to which one seeks to exercise any of the ARCO Rights; and
IV. Any other element or document that facilitates the location of your personal data.

 

St James International will inform you, within a maximum period of twenty days, counted from the date on which the corresponding request is received, the determination adopted. If the request is appropriate, it will be effective within fifteen business days following the date on which St James International communicate the answer. In the event that the information provided in your request is erroneous or insufficient, or the necessary documents to prove your identity or the corresponding legal representation are not accompanied, St James International, within fifteen business days following receipt of your request, it will require the correction of the deficiencies in order to process it. In these cases, you will have ten business days to respond to the correction request, counting from the day after you received this request. The corresponding request will be considered not submitted if you do not respond within said period.

 

You may obtain the information or personal data requested through simple copies, electronic documents in conventional formats (Word, PDF, etc.), or through any other legitimate means that guarantees and certifies the effective exercise of the requested right.

 

Alternatively, you may direct your request to the Personal Data Department of St James International to the email address admin@stjamesinternational.com to receive guidance in this regard, complying in any case with all the requirements listed above, establishing as the Subject of the communication “ARCO Rights and/or Revocation of consent”, with the understanding that the deadlines for the procedure will be the same as those aforementioned.

 

If after the term established by the Federal Law on Protection of Personal Data Held by Private Parties and the Regulations of the Federal Law on Protection of Personal Data Held by Private Parties St James International does not respond to your request, you may initiate the procedure for the protection of ARCO Rights before the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI), whose address is located at Insurgentes Sur No. 3211, Col. Insurgentes Cuicuilco, Mayor's Office of Coyoacán, CP 04530, in Mexico City, the above in accordance with the requirements that are informed by said Institute in due course.

 

For St James International It is important to keep your personal data updated, as well as guarantee its veracity, validity, and accuracy; therefore, we would appreciate it if you notified us at all times of any changes in them.

 

F. Revocation of consent.

 

You may revoke your consent for the processing of your Personal Data at any time by email to our Personal Data Department, clearly establishing the Personal Data, the purpose and the activity that you do not authorize us to carry out; as long as they are in our databases or files, or are within our reasonable access.

 

The procedure for revoking consent, if applicable, will be the same as that established in the immediately preceding section for the exercise of ARCO Rights.

 

G. Limitations on the use and disclosure of your personal data

 

You may limit the use or disclosure of your Personal Data by directing the corresponding request to our Personal Data Department. The requirements to prove your identity, as well as the procedure to respond to your request, will be the same as those indicated in section E of this Privacy Notice (Exercise of ARCO Rights).

 

St James International has means and procedures to ensure the inclusion of some of your data in its own exclusion lists when you expressly request its inclusion in them. St James International will grant the registered owners the corresponding proof of registration.

 

H. Modifications or updates to this Privacy Notice

 

St James International may modify, update, extend or otherwise change the content and scope of this Privacy Notice, at any time and under its sole discretion. In such cases, St James International will communicate such changes through the following web address: http://www.stjamesinternational.com in the section called “Privacy Notices”.

 

 

St James International will be obliged to make a new Privacy Notice available to you, when St James International, in its capacity as Controller:

 

1. Change your identity;

2. Requires collecting Sensitive Personal, Wealth or Financial Data additional to those reported in this Privacy Notice, when the same is not obtained personally or directly from the owner and the consent of the owner is required.

3. Change the purposes that gave rise to or are necessary for the legal relationship between St James International and the owner; or new ones are incorporated that require the consent of the same, or

4. Modify the transfer conditions or transfers not initially planned are going to be made, and the consent of the owner is necessary.

 

For your security and information, we strongly suggest that you periodically review the content of this Privacy Notice, or that you send us any request for information or clarifications to our email account: admin@stjamesinternational.com

 

This Privacy Notice complies with the requirements established by the Federal Law on the Protection of Personal Data Held by Private Parties, the Federal Regulations on the Protection of Personal Data Held by Private Parties, the Guidelines of the Privacy Notice and other applicable legal provisions.

 

Last update date of this Privacy Notice: 08/11/2023.

 

• I express my consent to the processing of Personal Data provided to St James International to carry out the Primary Purposes or Necessary Purposes provided for in this Privacy Notice, recognizing in this act that there is no opposition on my part to the Personal Data being transferred to the third parties indicated therein.

• I express my consent for the Personal Data provided to St James International to be used to carry out the Secondary Purposes or Non-Necessary Purposes provided for in this Privacy Notice, recognizing in this act that there is no opposition on my part to the Personal Data are transferred to the third parties indicated therein.

• I express my consent for the Personal Data provided to St James International to be used to be contacted personally, by telephone or by email for marketing, advertising or commercial prospecting purposes solely and exclusively by St James International and/or or its affiliated parents and/or subsidiaries, recognizing in this act that there is no opposition on my part to the Personal Data being transferred to the third parties indicated therein.