In compliance with the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter the "Law"), its Regulations, and other applicable provisions, and in order for you to make an informed decision about the treatment we may give to your information, we provide this notice that offers information about the use of your personal data, identifying the entity responsible for your information; the purposes or actions that motivate the collection, use, and custody of your personal data; the third parties to whom your personal data will or may be transferred; the mechanisms for you to exercise your rights, among other information.

 

At ORLEGI, we use video surveillance systems to monitor certain areas, events, activities, or individuals through a visual surveillance system called closed-circuit television (CCTV), which has been placed in such a way that the location of the cameras, viewing angles, and areas under video surveillance are limited to the minimum perimeter necessary to fulfill the purposes of this Privacy Notice.

 

Without prejudice to its availability and communication through physical or electronic means, individuals recorded by our video surveillance system may consult this privacy notice through the following websites: https://abonos.clubsantos.mx/ and https://clubsantos.mx/.

 

 

Who is responsible for your personal data?

 

Orlegi Occidente, S.A.P.I. de C.V. (hereinafter and interchangeably the "Responsible Party" or "Orlegi") is responsible for your personal data. Orlegi designates as its address for receiving notifications, the location at Calzada Territorio Santos Modelo, Number 1, Conjunto de Todos Los Santos, Postal Code 27014, Torreón, Coahuila de Zaragoza, Mexico.

 

 

What data do we use and may request?

 

For the purposes established in this Privacy Notice, Orlegi may process the following categories of personal data:

·      Image, and

·     Date, time, and location of individuals.

 

 

Processing of sensitive personal data

 

Orlegi does not request sensitive personal data for the purposes listed in this Privacy Notice. As the data subject, you should refrain from providing this type of information.

 

 

What will we use your personal data for?

 

By accessing or leaving a video-monitored area within Orlegi's facilities, you accept and acknowledge that we may process your personal data for the following purposes:

 

 

Primary purposes:

 

1.     Surveillance and security of Orlegi's facilities and equipment.

2.    Safety of personnel, attendees, clients, suppliers, and visitors accessing Orlegi's facilities.

3.    Access control to Orlegi's facilities.

4.    Preserving the safety of individuals, property, and Orlegi's facilities against theft and intrusion, as well as any type of vandalism or criminal action that may compromise the safety of such individuals, property, and facilities.

5.    Providing access to or copies of sections or fragments of video recordings to competent authorities to comply with duly founded and motivated information requests.

6.    Retention of records for the time strictly necessary to fulfill the purposes listed above.

 

 

Secondary purposes: none.

 

With whom can we share your data?

Your personal data may be transferred within Mexico or abroad to the following categories of recipients and for the identified purposes:

·      Parent companies, shareholders, affiliates, subsidiaries, and/or any company within Orlegi's corporate group operating under the same internal processes and policies, for purposes of management, administration, and centralized safeguarding of video surveillance information.

·      Federal, state, and/or municipal administrations and authorities; commissions; institutes, regulatory entities; judicial or administrative authorities; and national and/or foreign government entities, to comply with informational, transparency, and fraud, crime, or other illicit activity prevention obligations, as well as to fulfill judicial or administrative requirements issued by competent authorities.

The Law establishes that the aforementioned data transfers do not require your consent to be carried out, but Orlegi is obligated to inform you about them. Any transfer of your personal data that does require your consent will be informed in advance through the communication and update of this Privacy Notice and prior to the execution of such data communication.

 

 

ARCO Rights

 

The Law regulates the ARCO Rights you have as the owner of personal data. These rights include:

·     Access: the right to know what data we have about you, as well as to know how we use or share it.

·     Rectification: the right to request at any time the correction of your data if, for any reason, it is incorrect, inaccurate, or incomplete in our databases.

·     Cancellation: the right to request that we delete your information, starting with its blocking and subsequent permanent deletion.

·     Opposition: the right to indicate a legitimate reason why we should stop using your personal data.

To exercise any of the ARCO Rights, you must submit a request addressed to our Personal Data Department via email at: datospersonales@orlegi.mx

 

 

The request must contain or be accompanied by:

1.    Your full name and address, or another means to communicate the response to your request,

2.   A copy of an identification document (or a power of attorney if someone exercises the right on your behalf),

3.   A description of the right you wish to exercise, as well as the information related to it, and

4.   Any other information you consider important to address your request or locate your personal data.

 

Orlegi will respond to your request within 20 (twenty) business days from the date it is sent and received. If the request is deemed valid, we will implement it within 15 (fifteen) business days from the date the response is communicated. If the information and/or documentation provided in your request are incomplete, incorrect, and/or insufficient, or if the necessary documents to prove your identity or legal representation are not included, we will request the correction and rectification of the deficiencies to process the request. You will have 10 (ten) business days to address the request and correct the deficiencies; otherwise, the request will be considered not submitted.

 

The use of electronic means to exercise ARCO Rights authorizes Orlegi to respond to the corresponding request through the same means unless you clearly and expressly indicate another means of contact in your request.

 

The right to cancellation is not absolute. Please note that Orlegi must retain information to comply with various legal obligations and may share your personal data with other entities or organizations. In such cases, the right to cancellation may need to be requested from the entity that received your personal data.

 

 

Do you want to revoke your consent?

 

In some cases, you may revoke your consent for the processing of your personal data; however, this revocation cannot have retroactive effects, meaning it cannot affect situations, procedures, or transfers carried out before the revocation of your consent, nor in cases where such revocation would result in non-compliance with general public order provisions that establish the obligation to maintain the processing of your personal data for a certain period.

You can send your request to revoke consent to the email address datospersonales@orlegi.mx, following the instructions applicable to the exercise of ARCO Rights.

 

 

Limitations on the use and disclosure of your personal data

 

You can limit the use or disclosure of your personal data by directing the corresponding request to our Personal Data Department, following the procedure and instructions applicable to the exercise of ARCO Rights.

Orlegi has means and procedures to ensure the inclusion of some of your data in its own exclusion lists to prevent your data from being disclosed. In such cases, we will provide the requesting data subjects with the corresponding registration certificate.

 

 

Changes to our Privacy Notice

 

Orlegi reserves the right to modify, update, extend, and/or otherwise change the content and scope of this Privacy Notice at any time and at its sole discretion; in such cases, we will publish these changes on the websites https://abonos.clubsantos.mx/ and https://clubsantos.mx/, in the Privacy Notices section. At any time, you can request a copy of the latest version of this Privacy Notice from our Personal Data Department via the following email address: datospersonales@orlegi.mx

 

The Privacy Notice governing the processing of your personal data will be the one published in our Privacy Notices section on the following websites: https://abonos.clubsantos.mx/ and https://clubsantos.mx/.

 

 

Questions or clarifications

 

If you have any questions or need clarifications about this Privacy Notice, you can contact our Personal Data Department via the following email address: datospersonales@orlegi.mx.

 

 

Last updated: May 24, 2024.