Important Legal Notice for Users
SERVICES WHO'S WHO, PUBLIC LIMITED COMPANY WITH VARIABLE CAPITAL (hereinafter referred to interchangeably as “SQQ”), with address at Bosque de Duraznos No. 61, 8th Floor, Office A-2, Colonia Bosques de las Lomas, Miguel Hidalgo, Mexico City, Postal Code 11700, is committed to the confidentiality and security of the personal data it collects from its clients and users of its services in general. SQQ undertakes to ensure the confidentiality/privacy and security of the information entrusted to it and collected through its commercial activities, particularly through its online services that you use. Failure to object to this Notice, or simply continuing to request services once this Notice is published and made available, implies, except for the exceptions provided herein, your express and written acceptance of its terms and your express submission to administrative authorities and competent courts in Mexico City for any dispute or claim arising from this Notice. Therefore, we recommend reading the following regulations to understand how your personal information is processed when using our services. These confidentiality and privacy regulations may change in the future, so it is recommended to review them periodically.
SQQ is committed to carrying out the proper processing (collection, storage, cancellation, modification, and/or deletion) of the personal data you have provided through voice, written, forms, digital, IT systems, and/or any other data collection method. Such data will be used for one or more of the purposes specified below, following responsible, informed management in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), its regulations (hereinafter “RLFPDPPP”), and other applicable regulations. We protect your information using both physical and electronic security measures during storage and continuously reviewing our information protection processes. For this reason, we share with you our privacy policy and how we safeguard the integrity, privacy, and protection of your personal data, in compliance with the LFPDPPP and its regulations. As the owner of personal data, this privacy notice is available at all times on our website: https://quienesquien.mx/terminos-ycondiciones.html, and you can access the content of the LFPDPPP and its regulations through the portal provided by the Federal Government via the Ministry of the Interior at www.ordenjuridico.gob.mx.
You may revoke this consent at any time, as well as exercise any of the “ARCO” rights (access, rectification, cancellation, or objection) by contacting us, provided the conditions established by the LFPDPPP are met.
All of the above is carried out to ensure that you have full control and decision-making over your personal data. Therefore, we recommend reading the following information carefully.
SQQ informs you that it collects or will collect from you the personal data necessary for the proper contracting of its products and services, as well as for the execution of other actions that the Responsible Party may perform according to the Law and its corporate bylaws. Such personal data may have been or may be obtained directly from you or through any electronic, optical, audio, visual, or other technological means. Additionally, we may obtain personal data for which you are the owner through third parties and other sources permitted by law, such as credit information companies. The data will be collected from the documents you provide, from the information recorded in the service request(s) submitted to SQQ as indicated in this privacy notice, as well as from complementary services used to provide the requested service, formalize the contracting, and maintain the commercial relationship that arises.
In addition to this general privacy notice, SQQ has established relevant notices at each appropriate time prior to the collection of information. You may access this privacy notice at any time, and any substantial or total changes made will be communicated through our websites: www.quienesquien.mx and/or https://tienda.quienesquien.mx/pages/aviso-de-privacidad.
SERVICES WHO'S WHO, SA DE CV., a commercial company established under Mexican law, with address at Bosque de Duraznos No. 61, 8th Floor, Office A-2, Colonia Bosques de las Lomas, Miguel Hidalgo, Mexico City, Postal Code 11700, is, for the purposes of this privacy notice, the “Responsible Party” in relation to you as the owner of your personal data.
Phone: (55) 5596 3030
E-mail: privacidad@quienesquien.com.mx
SQQ is dedicated to providing directory compilation services and making its database available for consultations restricted to contractual relationships, as well as carrying out all activities related to the promotion and sale of directories, related works, intermediating in the delivery of courses, training, and other services related to Compliance, prevention, and identification of operations involving illicit resources, and related activities. The primary purpose for which SQQ processes your personal data is to provide you with the services derived from any service contract you enter into with SQQ; any service related to the use of applications, software, websites, and/or any other services that you voluntarily decide to acquire (hereinafter collectively referred to as the “Services”).
You can browse our website without providing personal data; However, there are certain sections where you may voluntarily provide your information. Your data may be collected in different situations, for example, when you inquire about our products and services, when you submit a service request via email, or when you register to receive information of interest or our newsletter, as well as the information you provide to establish a legal relationship—for example, when you decide to contract our products or services or provide us with a service or supply a good. The personal data we may collect belong to the following categories:
Identification Data: Name, home address, date of birth, landline and/or mobile phone number, fax, email, image, marital status, gender, signature, electronic signature, CURP, among others.
Academic Data: Educational background, degree, professional license number, specialty, certificates, extracurricular activities, academic history.
Employment or Commercial Data: Occupation, position, area or department, business address, email, landline or mobile phone number and fax, work address, telephone, and email, employment or commercial references, personal references, performance history in or of the company, among others.
Access Data to Our Platforms: Device location data, network and traffic data, and preference information.
Billing Data: Entity to be charged, tax address, RFC, email.
Financial and Asset Data: Exceptionally, when acquiring a service payable in installments, or if identified as a Politically Exposed Person, data may be collected your sources and amounts of income, movable and immovable assets, credit history, income and expenses, bank accounts, insurance, bonds, contracted services, personal references, among others.
Additionally, you are informed that for the processing of your financial and/or asset data, your express consent will be collected, and for sensitive data, explicit written consent will be required. Once personal data from third parties—for example, authorized persons, users, beneficiaries, references, guarantors, clients, suppliers, and other legal entities related to products and/or services—are provided by you to the Responsible Party for the purposes identified, you must inform these third parties about the data processing and the content of this privacy notice.
In cases where SQQ has a basis for legitimacy, it may obtain information related to you from the following sources:
Affiliated Companies: Personal data communications from affiliated companies (for the purposes of this Privacy Notice, an affiliate means any other company that, directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under the common control of the specified company), subsidiaries, and/or entities controlled or controlling SQQ (“Group Companies”).
Third Parties: When third parties with whom SQQ has commercial agreements provide information related to you, including credit information agencies.
Public Sources: When information is obtained from public sources.
The collection of information through the above-mentioned sources helps improve the services we provide to you, as well as to comply with the primary and secondary purposes outlined in this Privacy Notice.
SQQ may process personal identification and contact data of third parties when you provide this information so that such third parties act as authorized users to access our digital platform or complete services in writing, or when you provide it so they may be contacted as personal references for collection purposes and/or to conduct periodic investigations and monitoring of their credit history, as well as to validate the information provided by you. By providing this information, you acknowledge that these third parties have been informed about the use of their data and that you have obtained their prior consent for SQQ to process it for the purposes stated above.
SQQ is committed to the privacy of minors and incapable persons; Therefore, we do not intentionally collect or process personal data of minors or incapable persons without the express consent of their parents, guardians, or legal representatives. If you are a parent, guardian, or legal representative of a minor or incapable person and you become aware that such personal data has been provided to us without consent, you may request its deletion by contacting the following email address: privacidad@quienesquien.com.mx
In cases where you decide to contract our products or services, or you are an employee, officer, manager, representative, or proxy of an individual or legal entity that has contracted the “Services” and designates you as an Authorized User, all personal and confidential information that is necessary for the proper handling of your assignments and restricted access, according to the assigned user level, will be collected.
Consequently, when a legal relationship is created under the service contract and/or purchase-sale agreement, the collection of your personal data falls under the exceptions provided in Article 10 of the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), meaning that your prior consent is not required for the processing of the data. However, in accordance with its code of ethics, SQQ voluntarily provides this Privacy Notice.
SQQ informs you that the data we hold, collect, or will collect from you will be used for the following necessary purposes for contracting the requested product and/or service:
To complete the contracting of our products and services, including activations, renewals, and cancellations.
To enroll or register you in compliance and AML training courses offered by third parties that have a relationship with SQQ for promotion purposes.
Contact information as your client's representative to monitor rights and obligations derived from our contract.
Storage for customer service and technical support.
Processing and management of refunds, billing, discounts, promotion notifications, pre-sales, access to the internet domain.
Activation and/or renewal of keys and/or licenses for our digital products.
To verify and confirm your identity, as well as the authenticity of the information you provide, including that of your authorized third parties, spouses, beneficiaries, references, guarantors, co-obligors, endorsers, or sellers, as applicable.
Visit our facilities:
To control access and maintain security within our facilities.
Contact us:
To answer your questions, inquiries, or comments.
Service contracting management, client registration, administrative file formation, and related service documentation.
To establish a legal relationship.
Proper integration of files, requests, purchase orders, and other processes necessary for proper marketing of our products and services.
To grant, validate, or claim assistance or complementary services that may be established for the benefit of the data subject.
Provision of the requested product or service through our commercial partners.
To comply with legal requirements requested by competent authorities.
Notify condition changes and maintain the commercial relationship.
Complementary activities necessary to fulfill the above purposes.
Collection activities derived from the breach of contractual obligations for the contracted services or products, including in-person visits or telephone calls.
Monitoring claims between SQQ and clients, reports of involvement in illegal acts, accidents, or where the law allows client information exchange with government entities (public prosecutor, etc.).
Consultations, investigations, and reviews related to complaints or claims.
Contact information as your client's representative to monitor rights and obligations derived from our service contract.
Necessary data for product delivery, invoicing, and notifications related to our relationship with the customer.
Transmission of information to our providers, only as required to fulfill obligations to our clients or authorities.
When you send your CV:
To contact you and consider you for recruitment and selection processes.
When you register as a user:
To grant access to your profile and site features developed exclusively for users.
To customize your account functions.
Your personal data may also be used for purposes compatible with those described above or considered analogous.
In addition, we will use your personal data for the following secondary purposes that are not necessary for the requested service but allow us to provide better attention:
Transmission of information to our providers and collaborators for the acquisition of Services, when third-party intervention is required, as well as to various entities of the Mexican Financial System and any other subject required to detect relevant financial operations, politically exposed persons, and others, according to applicable regulations for the prevention and combat of operations with illicit funds.
To maintain communication with authorities and inform about SQQ activities, procedures, and services.
For statistical purposes.
Conducting telephone calls to update information and renewals for the management and monitoring of our assets, products, and services.
Storage of data for future contracts and/or billing.
Storage for customer service and maintaining contact with you.
For the design of special products.
To maintain communication and inform about SQQ activities, products, and services.
To perform consultations, investigations, and reviews regarding complaints or claims.
To create and maintain an identity and collaboration link with SQQ clients.
To contact you regarding any issue related to the Services or this Privacy Notice.
Marketing, advertising, commercial prospecting, and customer profiling for the development and offering of new products, conducting surveys, and implementing analytical and statistical processes related to the operations and services described, related to SQQ's necessary purposes. Your consent is requested to notify you about promotions, discounts, and other advertising. You may revoke this consent at any time by submitting a request to the Data Privacy Committee.
The processing of personal data will be necessary, adequate, and relevant in relation to the purposes described in this Privacy Notice and any other purposes that are compatible or complementary with the services provided by SQQ. Opposition to the use of your personal data for these secondary purposes will not be grounds for denying the services or products you request or contract with us.
SQQ is committed to implementing the necessary physical, administrative, and technical measures to protect your personal information against damage, loss, alteration, destruction, or unauthorized use, access, or processing.
Furthermore, SQQ and all its employees, officers, and, in general, users who have access to personal data in the exercise of their functions or who participate in any phase of data processing commit to maintaining confidentiality regarding your personal information, even after the relationship with you or with SQQ has ended.
We guarantee that all service contracts with third parties involving the processing of your personal information on behalf of and for SQQ will include a clause ensuring that they provide the level of personal data protection required by the LFPDPPP and other applicable regulations. In any case, all access will be carried out in compliance with the LFPDPPP and other applicable regulations.
We inform you that your personal data may be transferred to third parties inside and outside the country when:
a) The transfer is provided for in a law or treaty to which Mexico is a party.
b) It is made to parent, subsidiary, or affiliated companies under the common control of the Responsible Party, or to a parent company or any company within the same group of the Responsible Party that operates under the same internal processes and policies.
c) It is necessary by virtue of a contract entered into or to be entered into the interest of the data subject, by the Responsible Party and a third party.
d) It is necessary for the maintenance or fulfillment of a legal relationship between the Responsible Party and the data subject.
e) It is legally required to safeguard a public interest, or for law enforcement or judicial purposes.
Thus, in order to provide the SQQ products requested by the user, SQQ may, in some cases and if necessary, share your personal information with subsidiaries and affiliates and/or with service providers who are SQQ partners. In all cases, SQQ will require these third parties to take the necessary organizational and technical measures to protect your personnel and traffic information and comply with the applicable legislation. Examples of companies with which SQQ may share your personal information include:
Distributors or agents of SQQ Services
Billing companies (automatic billing platforms)
Payment processing companies, such as Openpay or PayPal
Auditors
Companies subcontracted for Customer Service or Call Handling
Credit reference or anti-fraud agencies
Banks and financial service companies
Marketing and Public Relations companies, including email service providers such as Shopify
Analytics, Datacenter, and Hosting service providers
Online software providers
Additionally, transfers may be made to third parties such as the National Electoral Institute (INE) to validate your identity under applicable regulations to prevent identity theft. Occasionally, your personal data may be shared with related parties of SQQ, companies, investors (individuals or legal entities), or other institutions, for example, credit information companies, as indicated in this privacy notice, both within and outside Mexico. In any case, we will communicate this privacy notice to the recipients of your personal data so that its terms are respected.
Cookies are small pieces of information sent by the website to your browser. Cookies are stored on your computer's hard drive and are used to determine your preferences when you connect to the services on our sites, as well as to track certain behaviors or activities carried out by you within our sites.
In some sections of our site, it is required that the client has cookies enabled because some functionalities depend on them to operate. Cookies allow us to:
a) Recognize you when you enter our sites and offer you a personalized experience.
b) Know the personal configuration of the site specified by you; For example, cookies allow us to detect the bandwidth you selected when accessing the homepage, so we know what type of information is advisable to download.
c) Calculate the size of our audience and measure certain traffic parameters, as each browser accessing our sites receives a cookie used to determine frequency of use and sections visited, reflecting your habits and preferences, information useful for improving content, headlines, and promotions for users.
Cookies also help us track certain activities, for example, in online surveys we can use cookies to detect if the user has already completed the survey and prevent it from being displayed again.
The “Help” button found in most browsers will tell you how to refuse new cookies, how to make the browser notify you when a new cookie is received, or how to disable all cookies. However, cookies allow you to take advantage of the most beneficial features we offer, so we recommend keeping them enabled.
SQQ assumes no obligation to keep confidential any other information provided by the user, including information submitted through newsletters and online chats, as well as information obtained through cookies as described, except for information classified as Sensitive or Patrimonial Data under the LFPDPPP.
In accordance with the provisions of the LFPDPPP, you or, if applicable, your duly accredited legal representative, may exercise your rights of Access, Rectification, Cancellation, and Opposition (ARCO) regarding the processing of your personal data by contacting the Data Privacy Officer (Committee). Your rights consist of the following:
I) Access – Access: – You have the right to know at any time your personal data held by SQQ, as well as to review the corresponding Privacy Notice.
II) Rectification: – If any of your data is inaccurate or incomplete, you may request its modification by providing the documentation that supports such correction.
III) Cancellation – Cancellation: – You may request the cancellation of your personal data when you deem it appropriate; If such request is accepted, your personal information will enter a blocking period and subsequently be deleted. Once in this period, your information can no longer be processed by SQQ.
IV) Opposition – Opposition: – You may object at any time and for legitimate reasons to the processing of your personal data. If your request is accepted, SQQ may no longer process your data.
To facilitate the exercise of these rights, you may request assistance from the Data Privacy Committee at the following address:
Data Privacy Committee Contact:
Bosque de Duraznos No. 61, Floor 8, Apt. A-2, Colonia Bosques de las Lomas, Alcaldía Miguel Hidalgo, Mexico City, Postal Code 11700
E-mail: privacidad@quienesquien.com.mx
You may revoke your consent or instruct SQQ to limit the use or disclosure of your personal data through a duly signed written notice, in which you state the reasons for the revocation or the limitations you wish to establish. Such limitations will be applied within thirty (30) calendar days following their receipt, provided they do not violate any law or alter the legal relationship you have with SQQ.
It is possible that we may modify this Privacy Notice. SQQ may update this notice and its practices regarding the handling of your personal information. Any substantial modification that affects you will be communicated through our website and/or the email address you have provided to us.
The procedure for modifications to the privacy terms will begin with a notification from SQQ, either through publication of the notice on the website and/or by sending an email to the email address you provided, fifteen (15) calendar days prior to the effective date of the modification.
If you do not agree with the proposed modifications, you may request from SQQ, within ten (10) calendar days following the notification, the limitation of use or disclosure of your personal data under the new terms and conditions, or exercise any of your ARCO rights. Once the period has elapsed without any communication from you, your consent to the new Privacy Notice will be deemed granted.
The Data Privacy Committee will provide the necessary assistance for exercising your ARCO rights and will also ensure the protection of your personal data within the organization.
Responsible: Erika Janeth Zamora Vélez
Bosque de Duraznos No. 61, Floor 8, Office A-2, Colonia Bosques de las Lomas, Alcaldía Miguel Hidalgo, Mexico City, Postal Code 11700.
Phone: (55) 5596 3030
E-mail: privacidad@quienesquien.com.mx
Office hours: 8:00 am to 2:00 pm, Monday to Friday, according to the banking calendar.
Having read and understood this privacy notice, you are deemed to authorize the responsible party who collects your personal data to process it under the terms and conditions established herein. Opposing, canceling, or revoking consent for the processing of your personal data may result in the impossibility of establishing or continuing the legal relationship with SQQ.
Contact: 55 5596-3030 | ventas@quienesquien.com.mx
SERVICIOS QUIEN ES QUIEN, SA DE CV (hereinafter referred to interchangeably as “QUIEN ES QUIEN”) is committed to handling the personal data it collects from the staff of consulates and foreign embassies accredited to the government of the United Mexican States in a responsible manner and in accordance with the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter referred to as “LFPDPPP”), its Regulations (hereinafter “RLFPDPPP”), and other applicable regulations.
The personal data necessary for the proper compilation of directories will be collected orally, in writing, by submitting documents, or through any other technological means, by SERVICIOS QUIEN ES QUIEN, SA DE CV, with address at Bosque de Duraznos No. 61, Floor 8, Suite A-2, Colonia Bosques de las Lomas, Delegación Miguel Hidalgo, Mexico City, Postal Code 11700, for the purpose of properly compiling directories and/or databases, to constitute support products required by authorities, entities of the Mexican Financial System, and other obligated parties, for the prevention and fight against money laundering, and in general, for the provision of its support services, information compilation, marketing, promotion, annexes, and related activities, as well as activities derived from attending your requests and/or providing services to individuals whose data is included in our products and our clients, or for conducting promotions, discounts, pre-sales, and offers in general, related to any of our previously indicated services, as well as carrying out socio-demographic and socio-economic studies, or any other studies deemed relevant at any time for continuous improvement of the products and services provided by QUIEN ES QUIEN.
For QUIEN ES QUIEN, it is necessary to collect certain personal data to carry out activities intrinsic to its operations. QUIEN ES QUIEN has the legal and social obligation to comply with sufficient legal and security measures to protect the personal data it collects for the purposes mentioned in this Privacy Notice. In addition to this privacy notice summary, WHO IS WHO has made relevant notices available at each appropriate time prior to the collection of information. Our privacy policies and contact information are available at: www.quienesquien.com.mx/privacypolicies
All of the above is carried out so that you have full control and decision-making over your personal data. Therefore, we recommend that you carefully read our privacy policies available at the domain mentioned above.
It is understood that with this Privacy Notice, you consent that QUIEN ES QUIEN, in order to fulfill the purpose(s) previously described or others required legally or by the competent authorities, may communicate certain personal data collected from you to any supervising authority, as well as to its partners, associates, and providers.
At any time, you may revoke the consent you have granted for the processing of your personal data so that we stop using it. To do so, you must submit your request to the Data Privacy Committee, with an office located at Bosque de Duraznos No. 61, Floor 8, Suite A-2, Colonia Bosques de las Lomas, Delegación Miguel Hidalgo, Mexico City, Postal Code 11700. Telephone: (55) 5596 3030. Once the revocation request is submitted, the Committee shall, if applicable, place the data in a “Blocking” stage and subsequently destroy it, except where this would constitute a violation of the law and the data is strictly necessary for compliance with the purposes for which it was collected. In any case, the Committee must respond within ten business days following the submission of the revocation request.
Likewise, you are informed that as of January 6, 2012, you may exercise any of the “ARCO” rights (access, rectification, cancellation, or opposition) by contacting the Data Privacy Committee.
You may access this privacy notice at any time through our website; Likewise, any substantial or total change that may occur will be communicated to you through this medium: www.quienesquien.com.mx/privacypolicies/privacynologies
Acceptance by clicking the icon below means that you: (i) are 18 years of age or older; or (ii) are the parent/guardian/legal representative of minors; and that having read and understood this privacy notice, you expressly authorize the responsible party collecting the personal data to process it under the terms and conditions set forth herein.
SERVICIOS QUIEN ES QUIEN, SA DE CV, with address at Bosque de Duraznos No. 61, 8th Floor, dep. A-2, Colonia Bosques de las Lomas, Miguel Hidalgo, Mexico City, Postal Code 11700, Federal District, may keep stored in its Databases some personal data that were collected at the time for the proper integration of compilations and/or directories, to constitute the support products required by authorities, entities of the Mexican Financial System, and other obligated parties in the prevention and combat of money laundering; and currently keeps and processes them for the purpose of properly integrating the new editions of these directories, as well as for providing support services to their clients, conducting statistical studies, and any other type of study that at any time is deemed relevant for the continuous improvement of the products and services provided by QUIEN ES QUIEN. Therefore, in accordance with the applicable regulations on personal data held by private parties, the corresponding privacy notice is made available to you, as well as our current general Privacy Policies, which can be consulted on our website: www.quienesquien.com.mx/politicasdeprivacidad/avisodeprivacidad.
B) HYPERLINK ON THE WEBSITE
PRIVACY NOTICE FOR PREVIOUS EDITIONS OF WHO'S WHO DIRECTORIES
SERVICIOS QUIEN ES QUIEN, SA DE CV (hereinafter referred to interchangeably as “QUIEN ES QUIEN”), with address at Bosque de Duraznos No. 61, 8th Floor, dep. A-2, Colonia Bosques de las Lomas, Miguel Hidalgo, Mexico City, Postal Code 11700, Federal District, may keep stored in its Databases and process some personal data that were originally collected orally, in writing, through document delivery, and by any other technological means, essentially through research and compilation from public access sources, for the proper integration of compilations and/or directories, to constitute the support products required by authorities, entities of the Mexican Financial System, and other obligated parties in the prevention and combat of money laundering; and currently keeps and processes them to properly integrate new editions of these directories, as well as to provide support services to their clients, conduct statistical studies, marketing, and any other type of study deemed relevant for continuous improvement in the products and services provided by QUIEN ES QUIEN; and occasionally, for promotions, discounts, pre-sales, and offers in general, related to any of our services regarding the sale of directories.
For QUIEN ES QUIEN, it is necessary to collect and store certain personal data to carry out activities intrinsic to its operations. QUIEN ES QUIEN has the legal and social obligation to comply with sufficient legal and security measures to protect the personal data collected for the purposes mentioned in this privacy notice. Our privacy policies and contact information are available at: www.quienesquien.com.mx
It may be the case that sensitive, patrimonial, or financial personal data are held; However, since these were originally obtained from public access sources or directly from the data subjects, the provisions of Articles 10 and 37 of the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) apply, including the compensatory dissemination measure. However, all of the above is provided so that you have full control and decision-making over your personal data.
If you do not express opposition to the processing of your personal data, your tacit consent for their processing will be understood in accordance with this Privacy Notice, consenting that QUIEN ES QUIEN, to fulfill the purposes previously described or others legally required or by the competent authorities, may communicate certain personal data of the relevant public or banking official to its partners, associates, and providers.
You are also informed that, since the data collected or previously collected by QUIEN ES QUIEN pertains to your role as a public official, diplomatic official, public figure, or representative of financial entities, if you maintain such professional status, it may not be applicable to oppose the processing of the data, as these were collected from public sources—either from directories made available by Mexican authorities under Article 7, Section III of the Federal Law on Transparency and Access to Public Government Information, or from registries compiled by Financial Authorities based on information provided by financial entities of which you are a part. Consequently, this falls under the provisions of Sections I and II of Article 10 of the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), meaning your consent is not required for their processing. However, in these cases, and according to the code of ethics, QUIEN ES QUIEN will attempt, as much as possible, to subject your data to a disassociation process.
Therefore, it is understood that QUIEN ES QUIEN is authorized to process the personal data. However, if you no longer hold the status of public official, diplomatic official, public figure, or representative of financial entities, you may at any time revoke the consent you have granted for the processing of your personal data so that we cease its use. To do so, you must submit your request to the Data Privacy Committee, with an office at Bosque de Duraznos No. 61, Floor 8, dep. A-2, Colonia Bosques de las Lomas, Miguel Hidalgo, Mexico City, Postal Code 11700, Federal District. Phone: (55) 5596 3030. Once the revocation is submitted and deemed applicable by the Committee, the data will be placed in a “Blocking” stage and subsequently destroyed, except where this would violate the law and the data is strictly necessary for the purposes for which it was collected. In any case, the Committee must respond within ten business days following the submission of the revocation.
Likewise, you are informed that since January 6, 2012, you may exercise any of the “ARCO” rights (access, rectification, cancellation, or opposition) by contacting the Data Privacy Committee.
You may access this privacy notice and our general Privacy Policies at any time through our website; Likewise, any substantial or complete changes will be communicated to you through these means.
It is hereby made known that “SERVICIOS QUIEN ES QUIEN”, SA DE CV (hereinafter referred to interchangeably as “SQQ”) collects, directly and/or indirectly from you, in your capacity as a public official, diplomatic official, public figure, official, or representative of financial entities, various personal data concerning yourself and, where applicable, your family members. In the first case, the data is collected from public access sources, either from directories made available by Mexican authorities to citizens in accordance with Article 7, Section III of the Federal Law on Transparency and Access to Government Public Information, or from registries or lists compiled by Financial Authorities based on information provided by financial entities of which you are part. Consequently, the personal data collected from you under your professional capacity falls under the provisions of Sections I and II of Article 10 of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter “LFPDPPP”), meaning that a Privacy Notice is not required prior to processing.
In addition, considering the nature of the products and services provided by SQQ, some of your data are collected solely for the purpose of transmitting them under contractual terms to entities of the Mexican Financial System and other obligated parties pursuant to the Federal Law for the Prevention and Identification of Operations with Illegally Sourced Funds, the Law on Credit Institutions, the General Law of Credit Organizations and Auxiliary Activities, the Law on Savings and Popular Credit, the Law to Regulate the Activities of Credit Cooperative Societies, and others applicable legislation and prudential regulations of various sectors of the Mexican Financial System for the prevention of operations with illegally sourced funds. Therefore, such data will necessarily be processed and transmitted to these entities without prior notice, in accordance with the provisions of the aforementioned laws and the Federal Law on Transparency and Access to Government Public Information.
However, in accordance with its code of ethics, SQQ has voluntarily prepared, especially for any data that could be considered non-essential or reserved for the aforementioned legal purposes, the following:
PRIVACY NOTICE
SQQ is committed to the confidentiality and security of personal data that is part of its Compilations and/or Directories, as well as personal data from its clients and general service users, and therefore gives the utmost importance to the confidentiality and proper protection of the entrusted personal information. In accordance with its code of ethics, SQQ is committed to handling your personal data responsibly and in compliance with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), its Regulations (RLFPDPPP), and other applicable regulations.
For SQQ, it is necessary to collect certain personal data from public access sources to carry out the intrinsic activities of its operations, which on occasion are confirmed via telephone or data messages directly with you, your staff, or the entity to which you belong. SQQ has the legal and social obligation to comply with sufficient legal and security measures to protect the personal data collected for the purposes described in this Privacy Notice.
All of the above is carried out so that you have full control and decision-making over your personal data. Therefore, we recommend that you carefully read the following information.
1. Data Controller: “SERVICIOS QUIEN ES QUIEN”, SA DE CV, a commercial company established in accordance with Mexican law, with address at Bosque de Duraznos No. 61, 8th Floor, dep. A-2, Colonia Bosques de las Lomas, Miguel Hidalgo, Mexico City, Postal Code 11700.
Phone: (55) 5596 3030
E-mail: privacidad@quienesquien.com.mx
2. Source of Data Collection: SQQ informs you that the data it holds, collects, or will collect comes from public access sources such as websites, official government documents, social networks, registries managed by regulatory authorities, news articles, among others, and in some cases, directly from you via telephone, data messages, and any other technological or direct communication means.
3. Personal Data: As part of our compilation of directories of public officials, diplomatic officials, public figures, officials of financial entities, clients, and general users, we maintain certain personally identifiable information about you. That is, for the purposes described in this Privacy Notice, your data may be collected in various ways, such as when you provide it directly; when you visit our website or use our online services; and when we obtain information from other sources. Such information may include, without limitation:
a) Identification Data: full name of the data subject, full names of blood relatives up to the second degree in a direct line and up to the fourth degree in collateral lines, spouse, and for each of these, their address, work phone, email, RFC, CURP, place and date of birth, age, and nationality.
b) Professional Data: occupation, position, area or department, work address, phone and email, extracurricular activities, professional references, personal references, among others.
c) Financial Data: source and amount of income, movable and immovable property, bank accounts, personal references, among others. In such cases, SQQ always seeks to collect explicit consent in separate formats for the processing of this data, unless impossible.
4. Purposes of Data Processing: SQQ collects your data for the necessary purposes to accurately compile Directories and PEPs and AML/CFT Lists required by financial entities and obliged parties to comply with their obligations regarding the prevention and identification of operations with illegally sourced funds. The purposes for which your data is collected are related to your status as a public official, politically exposed person, diplomat, public figure, shareholder, official, or representative of Mexican financial entities. These purposes are as follows:
Necessary Purposes:
Compilation and/or Directory Integration.
Restricted access for consultation of our database by users authorized by our clients linked to SQQ via contract, including various entities within the Mexican Financial System and any other party obligated to detect relevant financial operations, KYC, identify politically exposed persons, and any other action in accordance with applicable regulations for the prevention, identification, and combat of operations with illegally sourced funds.
Secondary Purposes:
Transfer of information to competent authorities in accordance with applicable regulations for the prevention and combat of operations with illegally sourced funds.
Transmission of information to our clients, including entities within the Mexican Financial System, for credit and financial analysis.
Design of special products for the financial sector.
Maintaining communication with our authorities and informing about SQQ activities, procedures, and services.
Statistical purposes.
Conducting phone calls to update data and re-register in directories, or, where applicable, remove them.
Follow-up on disputes between SQQ and clients, reports of involvement in illicit acts, accidents, or where the law justifies sharing client information with government entities (public prosecutor, etc.).
Conduct inquiries, investigations, and reviews concerning your complaints or claims.
Create and maintain a collaboration link with public officials and financial officials.
Continue offering commercial and collaboration offers from SQQ.
Contact you regarding any matter related to the Services or this Privacy Notice.
5. Security and Confidentiality Measures: SQQ is committed to implementing the necessary physical, administrative, and technical security measures to protect your personal information against damage, loss, alteration, destruction, or unauthorized use, access, or processing. Likewise, SQQ and all its employees, officers, and users who have access to personal data in the exercise of their duties or intervene at any stage of the processing, commit to maintaining confidentiality regarding your personal information.
6. Data Transmission: We guarantee that all service contracts with third parties that involve the processing of your personal data on behalf of SQQ will include a clause ensuring that they provide the level of personal data protection provided by the LFPDPPP and other applicable regulations. In any case, all access will comply with the LFPDPPP and other applicable regulations.
SQQ is committed to ensuring that all legal protection principles regarding the transmission and transfer of your personal data are respected. Likewise, it commits to ensuring that our partners, associates, and providers also comply with this Privacy Notice. The information held by SQQ will not be processed for a period longer than necessary to fulfill the purposes indicated.
7. Opposition to Processing: If you do not express opposition to the processing of your personal data, your tacit consent to the processing of such data will be understood under this Privacy Notice, consenting that SQQ, to fulfill the aforementioned purpose(s) or any legally required purpose or by competent authorities, may communicate certain personal data of the official or former public or banking official in question to its partners, associates, and providers.
It is also hereby noted that, since the data collected by SQQ about you pertains to your status as a public official, diplomatic official, public figure, or official or representative of financial entities, if you retain such professional status, opposition to the processing of the data may not be applicable, as these were collected from public access sources, either from directories made available by Mexican authorities in accordance with Article 7, Section III of the Federal Law on Transparency and Access to Government Public Information, or from registries or lists compiled by Financial Authorities based on information provided by financial entities of which you are part. Consequently, they fall under the provisions of Sections I and II of Article 10 of the LFPDPPP, meaning that prior consent is not required. However, in these cases and in accordance with its code of ethics, SQQ will attempt, as much as possible, to submit your data to a dissociation process.
8. Limitation of Use: If you cease to hold the status of public official, diplomatic official, public figure, or official or representative of financial entities, you may at any time object to the processing of your data after that fact, or revoke the tacit consent previously granted for the processing of your personal data so that we stop using it. You may revoke your consent or instruct SQQ to limit the use or disclosure of your personal data by submitting a duly signed written notice, stating the reasons for the revocation or limitations you wish to establish. These limitations will be applied within thirty (30) calendar days following receipt for future editions of the Directories, provided they do not contravene any law. To do so, you must submit your request to the Data Privacy Committee, with an office located at Bosque de Duraznos No. 61, 8th Floor, Suite A-2, Colonia Bosques de las Lomas, Alcaldía Miguel Hidalgo, Mexico City, Postal Code 11700. Phone: (55) 5596 3030.
Once the revocation is submitted and the Committee determines its validity, the data will be placed in a “Blocked” stage and subsequently destroyed, unless doing so would violate the law and the data is strictly necessary to fulfill the purposes for which it was collected. In all cases, the Committee must respond within ten (10) business days following the submission of the revocation. Forms for these purposes will be available on the website www.quienesquien.mx, or in person at the office of the Data Privacy Committee mentioned above.
9. Exercise of ARCO Rights: In accordance with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), you or, if applicable, your duly accredited legal representative, may exercise your rights of Access, Rectification, Cancellation, and Opposition (ARCO) regarding the processing of your personal data by contacting the Data Privacy Committee. Your rights are as follows:
I) Access: Allows you to know at any time your personal data held by SQQ, as well as the corresponding Privacy Notice.
II) Rectification: If any of your data is inaccurate or incomplete, you may request its modification, attaching documentation that provides the correction.
III) Cancellation: You may request the deletion of your personal data; If approved, your information will enter a blocking period and will then be deleted. Once in this period, your information can no longer be processed by SQQ.
IV) Opposition: You may, at any time and for legitimate reasons, object to the processing of your personal data. If your request is approved, SQQ will no longer process the data.
To facilitate the exercise of these rights, you may request assistance from the Data Privacy Committee, located at Bosque de Duraznos No. 61, 8th Floor, Suite A-2, Colonia Bosques de las Lomas, Alcaldía Miguel Hidalgo, Mexico City, Postal Code 11700.
E-mail: privacidad@quienesquien.com.mx
10. Data Transfer: SQQ will allow access to its database or transfer personal data in a restricted manner exclusively to third parties that are part of its client portfolio, subject to a confidentiality clause guaranteeing the purposes indicated above, unless you explicitly object, provided such objection does not violate any law. Your acknowledgment of this Privacy Notice, without expressing opposition, will be understood as your consent to the data transfer referred to in this section.
11. Changes to the Privacy Notice: We may modify this privacy notice. SQQ may amend this notice and its practices regarding the handling of your personal information. Any substantial modification affecting you will be notified via the website and/or the email address you provided.
The procedure for modifications will begin with a notice published on the website and/or sent by email to the address you provided, fifteen (15) calendar days prior to the effective date of the modification. If you do not agree with the proposed changes, you may request that SQQ limit the use or disclosure of personal data under the new terms within ten (10) calendar days following the notification, or exercise any of your ARCO rights as outlined in section 9 above. After this period passes without communication from you, your consent to the new Privacy Notice will be deemed granted.
12. Data Privacy Committee: The Data Privacy Committee will provide the necessary assistance for exercising ARCO rights and will ensure the protection of your personal data within the organization.
Responsible Officer: Erika Janeth Zamora Vélez
Address: Bosque de Duraznos No. 61, 8th Floor, Suite A-2, Colonia Bosques de las Lomas, Alcaldía Miguel Hidalgo, Mexico City, Postal Code 11700.
Phone: (55) 5596 3030
E-mail: privacidad@quienesquien.com.mx
Office Hours: 8:00 am to 2:00 pm, Monday to Friday according to the banking calendar.
Having read and understood this privacy notice, you are deemed to authorize the responsible party collecting the personal data to process it under the terms and conditions set forth herein. Refusing, canceling, or revoking consent for the processing of personal data may result in the inability to establish or continue a legal relationship with SQQ.
