PRIVACY NOTICE FOR PERSONAL DATA PROTECTION

In accordance with Articles 15 and 16 of the Federal Law on the Protection of Personal Data Held by Private Parties, we inform you that Pragma, with an address at Calle Prolongación Tecnológico Norte, 950 B, Corporativo Blanco San Pablo, Querétaro, CP 76159, is responsible for collecting your personal data provided directly or when you use our online services, for the use given to them, and for their protection. Your personal information will be used to provide you with the services, information, or documents you have requested, to inform you about changes to them, and to evaluate the quality of the service we provide.

Form and Means of Contact

As mentioned in the General section, you can contact us by writing a document and sending it via email to the following address: hola@pragmamexico.net or by postal mail to the following address: Calle Prolongación Tecnológico Norte, 950 B, Corporativo Blanco San Pablo, Querétaro, CP 76159, or by calling the phone number: +52 1 442 200 7205.

Data Collected and Means of Obtaining Personal Data

We collect information about the applications, browsers, and devices you use to access our app services. This allows us to offer you features like automatic updates.

The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information (such as carrier name and phone number), and application version number. We also collect information about the interaction of your applications, browsers, and devices with our services, such as IP address, crash reports, system activity, and the date, time, and referral URL of your request.

The personal data we collect from you, for the purposes described in this privacy notice, are collected personally, when you provide them directly to us; via our Internet Portal www.pragmaamericas.com when you enter your data or use our online services, and when we obtain information through other sources permitted by law.

The personal data we collect directly and via the internet when you provide it to us through various means, such as when you provide it to enter our loyalty programs, participate in promotions, offers, or when you contract any product or service with us.

The data collected includes personal identification data, including name and surname, company you work for, position, phone number, email address, and physical address, among others; as well as device configuration data and application usage data, which will be sent to our servers.

For What Purposes Do We Use Your Information?

Personal data is collected for primary purposes (purposes that originate and are necessary) and secondary purposes (different purposes that are of great importance and utility).

The personal data you have provided will be used for the following primary and secondary activities: (i) to identify you; (ii) to contact you; (iii) to follow up, update and confirm regarding products and services; (iv) to evaluate the quality of the service provided; (v) to provide the good and/or service you request; (vi) to validate geofencing and real-time positioning; (vii) to respond to your comments or information requests; (viii) to keep a record of the user and the device they use and to provide support if needed.

The personal identification and contact data that you provide to us through various means will be used for tracking, updating, and confirming regarding products and services; for promotional and contracting purposes; for financial purposes, to fulfill obligations contracted with our clients, to evaluate the quality of the service; and to conduct studies on consumption habits and preferences.

Device configuration and application usage data will be used to provide relevant features to the user: enabling notifications of nearby points of sale (PDV), geofencing validations, and real-time positioning.

Pragma will process the following categories of personal data:

• Identification and contact data.
• Device configuration data: information that allows us to receive through the configuration you enable on your device, such as access to GPS location, camera, and/or photos.
• Application usage data: when you use our Applications, we may collect information about your device that may include, if required, information about the geographic location of the device, whether in the foreground or background; information generated through the use of other services such as GPS and Wi-Fi signals, and information regarding the technical and operational characteristics of the same.

Limitations on the Use of Data

You can unsubscribe from receiving promotions, offers, and services by phone, email, and postal mail by sending a written letter in Spanish indicating your request and the necessary data such as Full Name (first name(s) and surname(s)), a simple copy of your official identification or a digitalized version (scan) in electronic means, customer number (if you have one), phone number, and physical or electronic address to the address for notifications related to the case at the following address: Calle Prolongación Tecnológico Norte, 950 B, Corporativo Blanco San Pablo, Querétaro, CP 76159, or to the email address: hola@pragmamexico.net.

Exercise of ARCO Rights

You have the right to access the personal data we hold, to the details of their treatment, to rectify them if they are inaccurate or incomplete, to cancel them when you consider they are not necessary for any of the purposes stated in this Privacy Notice, are used for non-consented purposes, and finally to object to the treatment of such data for specific purposes, which you must clearly express.

Mechanisms for Exercising ARCO Rights

The Rights described above are exercised through the presentation of the respective request, which must be presented in writing and in Spanish, free of charge, to Pragma, unless there is a different agreement. For more information, contact +52 1 442 200 7205, addressed to the Administration Manager; or send it by postal mail, after paying the corresponding postage, to the aforementioned address, addressed to the same person.

For more information, please contact the Administration Management at +52 1 442 200 7205.

The deadline for responding to your request will be a maximum of twenty days from the date of receipt of your request for access, rectification, cancellation, or opposition.

We inform you that the Federal Institute for Access to Information and Data Protection is responsible for overseeing your ARCO rights and regulating and verifying compliance with the Law.

Right to Revoke Your Consent for Data Processing

At any time, you can revoke the consent you have given us for the processing of your personal data so that we stop using it. For this purpose, you must submit your request as described in this same notice under “Form and Means of Contact”.

Your request must indicate Full Name (first name(s) and surname(s)), a simple copy of your official identification or, in electronic means, a digitalized version (scan), indication of the email address or physical address you designate for notifications, and a contact phone number.

Within a maximum period of twenty days from the date of receipt of your revocation request, we will respond regarding its validity, via email sent to the address you have indicated in the request or by sending a letter to the physical address you have indicated for these purposes (the twenty days will be considered fulfilled upon delivering the document to the postal service).

Data Transfer, National and International

Your personal data will not be transferred to third parties without your consent, except for Pragma in accordance with Article 37 of the Law, including other exceptions provided for in said legal provision.

Modifications to This Privacy Notice

We reserve the right to make modifications or updates to this privacy notice at any time.

The modifications made will be made available to the public through some or all of the following means: visible announcements at our establishments, via our website, via email to the most recent address we have of you, through publications in national circulation newspapers, magazines, posters, sound recordings, or personally by our staff when you visit any of our facilities.

Information on the Internet

We inform you that when you access our Internet Portal, we receive information regarding your cookies (defined below in the Definitions section) and web beacons (defined below in the Definitions section) to obtain information such as your browser type and operating system, the Internet pages you have recently visited, the links you have recently followed, the IP address of your computer, and the site you closed before entering our Internet portal.

Definitions

For the purposes of this Privacy Notice, the following shall be understood:

I.- Cookies: Text files that are automatically downloaded and stored on the user’s computer’s hard drive when browsing a specific Internet page or portal, which allow the Internet server to store certain data, including preferred viewing pages on the Internet, some keys, and passwords.

II.- *Days: According to Article 3, section VII of the Federal Law on the Protection of Personal Data Held by Private Parties, the stipulated deadlines and times in days are counted as business days.

III.- ARCO Rights: The Rights of Access, Rectification, Cancellation, and Opposition, enshrined in the Law, which form the acronym ARCO.

IV.- Law: Refers to the Federal Law on the Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation on July 5, 2010.

V.- Web beacons: Images embedded in Internet pages or portals as well as in emails, which can store information such as the user’s IP address, interaction time on websites, among others.

Implied Consent, in Terms of Article 8 of the Law in Mexico

As established earlier, if you wish to express OBJECTION to your personal data being processed as stated in this privacy notice, you must send your objection in writing to the following address: Calle Prolongación Tecnológico Norte, 950 B, Corporativo Blanco San Pablo, Querétaro, CP 76159.