In compliance with the Federal Law on the Protection of Personal Data in the Possession of Private Parties, its Regulations, as well as the guidelines of the Privacy Notice published in the Official Journal of the Federation on January 17, 2013, we bring to your attention the following Privacy Notice (hereafter the “Notice”).
The current privacy notice is included on the web site: www.inmersys.com. The company liable for handling and processing Personal Data in this Privacy Notice is SISTEMAS INMERSIVOS DIGITALES S. DE R.L. DE C.V. (hereafter “INMERSYS”), located at REAL DE SAN LUCAS #42, COLONIA BARRIO SAN LUCAS, DELEGACIÓN COYOACAN, C.P. 04030, CIUDAD DE MÉXICO. Efirstname.lastname@example.org.
INMERSYS may request, obtain, store, and/or use Personal Data for the following purposes:
• To maintain customer relationships with users, clients, professionals, or any other person or party interested in the services offered by INMERSYS.
• For statistical and marketing control of the use of products and /or services provided by INMERSYS.
• To develop adequate quality control and obtain contact level measurements with our clients through quality assessment surveys and market analyses.
• Sending information, magazines, news, communications and advertisement to clients, members, or users who provide their information and who are interested in receiving the information mentioned on this section.
• To respond to information, product, and service requests as well as complaints, questions or comments.
• To create data bases for product and/or service research and development purposes.
III. METHODS TO OBTAIN PERSONAL DATA.
• Directly: INMERSYS may obtain their clients´ or prospective clients´ personal information during a service promotional interview. The Notice will be printed and made available to the individuals whose personal data has been gathered.
• Directly from the Data Subject (hereafter “Data Subject or Holder): Through the means that INMERSYS employs such as: electronics, auditory, visual, or through any other technology, including the Internet.
• Indirectly: INMERSYS may gather Personal Data through third parties. In which case, INMERSYS will notify the Holder about the processing and purpose of their Personal Data and will make the privacy notice available prior to the handling of the Holder´s personal data.
IV. CONSENT FOR PERSONAL DATA PROCESSING.
The processing of Personal Data is always subject to the individual´s unambiguous consent; whether it be expressed orally, in writing, through electronic means, by any other type of technology, by irrefutable signs, or tacitly. Tacitly meaning that the individual concerned does not manifest any opposition after he or she is presented with the Privacy Notice, even after providing their personal data. It is clear that once the advertiser, subscriber, user, client, and/or member has provided INMERSYS with Personal Data, they expressly recognize and accept this Notice.
In both cases, whether it be explicit or tacit consent, the Holder of the Personal Data has a period of 5 days to express disapproval to the processing of said Personal Data. Assuming that no opposition is expressed, consent will be recognized.
Consent for the processing of Personal Data will not be necessary when: I. It is stated under a law; II. The data appear in sources accessible to the general public. III. Personal Data has previously gone through a process of dissociation, in which the data has been made anonymous; IV. It has the purpose of fulfilling any kind of legal obligation between the Holder and INMERSYS; V. There is an emergency situation that can potentially harm an individual, their assets, or estate. VI. It is determined by a competent authority.
V. REQUIRED PERSONAL DATA
The type of Personal Data that INMERSYS can gather are: name, last name, address, phone numbers, e-mails, Federal Taxpayer Registry passwords, family member names, as well as all the information that the user, client and/or member provides throughout the established contractual relationship and, hence, is not considered sensitive information.
VI. STORAGE OF PERSONAL DATA
INMERYS stores personal data during the period required to perform the service for which they were collected and the purposes for which they were requested.
VII. PROTECTION OF DATA
In accordance with the regulations on the subject of Personal Data in the Possession of Private Parties, INMERSYS has adopted the legally required Personal Data protection security measures; in addition, personal data owners are informed that INMERSYS has the means and additional technical measures to avoid the loss, improper use, alteration, unauthorized access, and/or theft of the Personal Data provided.
However, since security measures may be susceptible to violations beyond INMERSYS´ control; the company, without being held accountable, undertakes to inform the Holder about any breaches in their security measures, in order for the holder to take the necessary measures to defend their rights.
INMERSYS´ collection of data is in good will, hence, it is assumed that the data is true, accurate, complete, and identifies the Holder who provides them. Therefore, it is the Holder´s responsibility to ensure that the information provided to INMERSYS fulfills said characteristics and are updated as necessary. Furthermore, INMERSYS reserves the right to exercise the corresponding actions in case of falsehood in the information provided.
VIII. TRANFER OF PERSONAL DATA
INMERSYS may transfer Personal Data in order to maintain a relationship with the Holder about the products, services, and market research that the company performs; for statistical and marketing control purposes of the use of INMERSYS products; to develop appropriate quality control and measurement of the contact levels with our clients through quality surveys and market research; and in order to create databases for research and developmental purposes of products and/or services; and/or to schedule follow-up visits and/or to promote products.
Based on articles 36 and 37 of the Federal Law on the Protection of Personal Data in the Possession of Private Parties, Personal Data can be legally transferred, for purposes established in this Privacy Notice, to:
a) Customer service and research related to our products and/or services; and
b) Third parties such as marketing agencies that collaborate with INMERSYS in order to offer their products and services in the terms established by the applicable Personal Data regulation.
Personal data transfer is limited to the facts and procedures that INMERSYS requires in order to fulfill its contractual obligations, whether regulatory and/or commercial, in the ordinary course of its business. If the user or member does not express opposition to his or her personal data being transferred, it will be assumed that consent has been granted.
IX. ARCO RIGHTS
“Access, Rectification, Cancelation, and Opposition Rights.” Personal Data Holders who have provided INMERSYS with their information may, at any time, exercise their right to Access, cancelation, rectification, and opposition (ARCO rights).
In order to assert their ARCO rights, the Personal Data Holder must apply with the following requirements:
(i) name and address or email of the Holder in order to reply to his or her application; (ii) documents establishing the Holder´s identity, and when applicable, the legal representation of the party acting on behalf of the holder; (iii) clear and precise description of the Holder´s Personal Data who seeks to exercise any of the aforementioned rights; (iv) any other element or document that facilitates the location of the Holder´s Personal Data; (v) clearly specify whether the application is for access, rectification, cancelation, or opposition; (vi) the reason for the application; and (viii) in case of rectification, the specified changes to be made.
The application should be forwarded to INMERSYS by any of the following means:
• Via e-mail, through email@example.com.
• Postal mail.
• Physically, at the INMERSYS offices
Once the application is received, INMERSYS will adopt the following procedures:
INMERSYS will notify the Holder about the determination made no later tan 20 (twenty) calendar days following the date in which the application was received. Provided that the application holds eligible, it will be resolved within the next 15 (fifteen) calendar days following the date in which eligibility is established.
INMERSYS may extend the time-limits previously mentioned whenever the specificities of each case warrant the aforementioned extensions. The Holder will be notified by the same means in which the application was submitted. INMERSYS may deny access, rectification, cancelation or opposition in the following cases:
I. When the applicant is not the Data Subject, or the legal representative is not appropriately qualified.
II. When the applicant´s personal data is not found in INMERSYS´ database.
III. Where fulfillment of a request could cause a violation of the legal rights of an independent third party.
IV. Where there is a legal impediment, a decision made by a competent authority that restricts access to personal data or that denies rectification, cancelation or opposition thereof;
V. Where rectification, cancelation, or opposition has been previously granted.
X. PRIVACY UPDATE.
INMERSYS reserves the right to modify this Privacy Notice in order to adapt it to new legal and legislative dispositions, as well as, to changing market practices. Any modifications applied to this Notice will be available on www.inmersys.com. Changes could be individually specified or the website could simply display the latest updated and modified version of this Notice.
Our products and/or services may contain links to other websites, applications that use INMERSYS´ technological platforms, and services offered by other companies with their own policies and privacy notices, which we encourage to review.