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ALFA’s Privacy Policy

I.	Responsibility

In accordance with the the Federal Law on Protection of Personal Data Held by Private Parties (“Ley Federal de Protección de Datos Personales en Posesión de los Particulares”) (the “Federal Law”), Alfa Corporativo, S.A. de C.V. (“ALFA”), located in Ave. Gómez Morín 111 Sur, Colonia Carrizalejo, San Pedro Garza García, Nuevo León, México, C.P. 66254, is responsible for the treatment of your personal data.

II.	Personal Data

Personal Data is considered any information concerning an identified or identifiable natural person (“Personal Data”). The Personal Data that ALFA requires to a PROSPECTIVE EMPLOYEE that is providing information is:
•	Personal identification
•	Contact information
•	Employment information and background
•	Physical features (in case it is required)
•	Academic background
•	Property ownership
•	Personal ideological information (in case it is required)
•	Personal health information (in case it is required)

The Personal Data that ALFA requires an EMPLOYEE that is providing information is:
•	Personal identification
•	Contact information
•	Employment information
•	Physical features
•	Academic background
•	Property ownership
•	Personal ideological information
•	Personal health information

The Personal Data that ALFA requires to SUPPLIER that are providing information is:
•	Personal/Company’s Identification
•	Contact Information
•	Employment information
•	Property ownership

The Personal Data that ALFA to VISITOR that are providing information is:
•	Personal Identification

The Personal Data necessary to comply with the purposes expressed in this Privacy Policy may be collected, alternatively, in any of the following means: directly provided by the owner of the data, through electronic means and online services, such as ALFA’s web page or by e-mail, as well as any other source of information permitted by law.

III.	Purpose of the Data Treatment

The Personal Data that ALFA requires to a PROSPECTIVE EMPLOYEE that is providing information, shall be used for the following purposes:
•	Identification
•	Communication
•	Evaluation, promotion and professional development monitoring

The Personal Data that ALFA requires to an EMPLOYEE that is providing information, shall be used for the following purposes:
•	Identification
•	Communication
•	Evaluation, promotion and professional development monitoring
•	Prevention of labor risks

The Personal Data that ALFA requires to a SUPPLIER that is providing information, shall be used for the following purposes:
•	Identification
•	Evaluation
•	Communication
•	Compliance of the legal obligations related to the client-supplier relationship.
•	Grant access to our workplace
•	Prevention of labor risks

The Personal Data that ALFA requires to a VISITOR that is providing information, will be used for the following purposes:
•	Identification
•	Grant access to our workplace

ALFA, under no circumstances, shall use the Personal Data for any purpose other than the purpose specified herein, unless this Privacy Policy is modified, which shall be notified to the person providing the Personal Data at the time and through the mechanisms set forth in this Privacy Policy.

IV.	Means to limit the use or disclosure of the Personal Data

In the event that the person providing the Personal Data wishes to limit the use or disclosure of his/her Personal Data, he/she shall contact ALFA’s Contracts and Litigations Legal Department, located in the above mentioned address, which is responsible for processing such requests. Subsequently, ALFA’s Contracts and Litigations Legal Department shall inform the procedure established by ALFA, so that the person providing the Personal Data may limit the use or disclosure of the Personal Data at its convenience.

V.	Rights of access, rectification, cancellation and objection (“ARCO” rights) and consent withdrawal

The Personal Data right holders are entitled to access, rectify and cancel their Personal Data, the right to oppose the treatment thereof, as well as the right to withdraw a consent previously granted for the treatment of the information, or, to limit the use or disclosure of Personal Data by ALFA.
To review the procedure for exercising the aforementioned rights, the right holder of the Personal Data must personally turn to Alfa’s previously provided address, and submit a letter to the ALFA’s Contracts and Litigations Legal Department, which is responsible for processing these requests, in which the right holder must specify in such letter which right they wish to exercise and on what terms, the foregoing for purposes that the Legal Department can inform the right holder the procedure to be followed. For this type of letter to be accepted by the ALFA’s Contracts and Litigations Legal Department, it must contain the elements specified in Article 29 of the Federal Law.

VI.	Data Transfer

ALFA undertakes not to transfer Personal Data to any third party, except for the exceptions set forth in Article 37 of the Federal Law when relevant, in which case such transfers shall be carried out in accordance to the conditions specified therein.
The exceptions contained in Article 37 above mentioned, are as follows:
•	Cuando la transferencia esté prevista en una Ley o Tratado en los que México sea parte;
•	When the transfer is permitted under in any Law or a Treaty to which México is a party;
•	When the transfer is necessary for the prevention or medical diagnosis, the provision of health care, medical treatment or the management of health services;
•	When the transfer is performed to holding companies, subsidiaries or affiliates under common control of the holder of the information, or to a parent company or any company in the same group responsible for operating under the same processes and internal policies;
•	When the transfer is necessary by virtue of a contract concluded or to be concluded in the interest of the provider of the Personal Data, by the controller and a third party;
•	When the transfer is necessary or legally required to protect the public interest, or to the enforcement or administration of justice;
•	When the transfer is necessary for the establishment, exercise or protection of a right in judicial proceedings, and
•	When the transfer is necessary for the maintenance or enforcement of a legal relationship between the provider of the Personal Data and the person responsible of the Data.

VII.	Modifications to this Privacy Policy

ALFA reserves the right to modify, if deemed appropriate, this Privacy Policy, in order to adapt, update or improve it or to meet new legal provisions.
ALFA recommends the providers of Personal Data to regularly review the content of this Privacy Policy, same which will be published on the following website: www.alfa.com.mx

VIII.	Use of cookies and web beacons

Where applicable, we inform you that ALFA’s website may use cookies or web beacons on its website to simplify navigation. The cookies or web beacons used on the website do not provide any means of identification and cannot read data off your hard drive. The user can change the settings of the cookies by actualizing the necessary settings on the Internet browser it is using. For more information please consult the help section of the browser.

IX.	Consent

In terms of Article 10 of the Federal Law, ALFA does not require the consent of the right holders to treat their Personal Data in the following cases:
•	Permitted by law;
•	The data is contained in sources available to the public;
•	The Personal Data is subject to a prior dissociation procedure;
•	Has the purpose of fulfilling obligations arising from a legal relationship between the provider of the Personal Data and the person responsible of the Data;
•	The presence of an emergency situation that could potentially harm an individual in his person or property;
•	It is essential for health care, prevention, diagnosis, sanitary assistance, medical treatment or the management of health services, while the right holder is unable to give consent, in the terms set forth in the General Health Law (“Ley General de Salud”) and other applicable legal provisions and the data processing is performed by a person who is subject to professional secrecy or equivalent requirement or
•	Issuance of a judicial resolution by an authority of competent jurisdiction.

ALFA does not treat Personal Property and Financial Data except in the cases described in Article 8 of the Federal Law. Unless otherwise expressed, the person providing the Personal Data is consenting to the treatment of its Personal Data in the terms set forth in this Privacy Policy.
If ALFA requires to treat Sensitive Personal Data, the provider thereof grants its express and written consent for its treatment, in accordance with Article 9 of the Federal Law, through his handwritten signature, electronic signature or any mechanism of authentication as may be determined by ALFA, as appropriate.
This Privacy Policy is issued to the extent that the Federal Law is applicable to ALFA, however, please note that ALFA is within the exceptions set forth in Article 2 of the Federal Law.
I've read and accept the terms and conditions contained in the privacy policy and agree that my personal data is to be used with the purpose of a PROSPECTIVE EMPLOYEE and VISITOR
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