Comprehensive Privacy Notice

General Public
Comply, S.C. (hereinafter referred to as "Comply") with address at Av. Revolución 1267 Piso 19, Los Alpes, Álvaro Obregón, CP 01010, CDMX, is the entity "Responsible" for the use, access, collection, storage and transfer of your personal data (in general for the "Processing" of these).
The purpose of our Privacy Notice is to communicate to our customers, suppliers and users of our website regarding the type of personal data we collect, for what purposes, when we share them, how we ensure their confidentiality and security, as well as the rights you have and the mechanisms to exercise them; all of the above based on the Federal Law on Protection of Personal Data Held by Private Parties, its Regulations and the Privacy Notice Guidelines [Ley Federal de Protección de Datos Personales en Posesión de Particulares, su Reglamento y los Lineamientos del Aviso de Privacidad] (hereinafter "LDP").

Comply
will process the following personal data: a) contact: full name, telephone, e-mail, fax, address; b) identification: signature, official identification number, R.F.C., C.U.R.P., gender, date of birth, nationality. For administrative support, contact data of your staff will be requested; c) professional: personal and commercial references.
Comply will not process Sensitive Personal Data.
Financial or Patrimonial Personal Data: Bank account number, C.L.A.B.E., Bank, SWIFT/IBAN, tax withholdings.
In compliance with the current and applicable regulations regarding Money Laundering Prevention, a "Due Diligence" process may be carried out, through which the following information may be collected: validation of criminal records, negative news, etc.
(Collected from public media and legal sources).
Purposes of Use of your Personal Data. The personal data you share with us will be processed for the following primary purposes: (a) to carry out payment, billing and tax processes; (b) to enter your information to files, systems and digital platforms; (c) to prepare contracts, letters, invoices or related documents; (d) to consult and update personal data; (e) to validate your personal information; (f) to carry out, through third parties, pre-screening and/or "Due Diligence" processes; (g) to comply with the services contractually entrusted to us; (h) logistics and organization of events, congresses and forums of which you participate as an attendee or speaker.

The secondary purposes for which we will process your personal data, i.e. those not necessary are the following: a) to carry out quality or satisfaction surveys; b) to invite you to events organized by Comply or by third parties. You may refuse to allow Comply to process your personal data for any of the secondary purposes described here. In general, you may request that Comply limit or reserve the processing of your personal information at any time by sending an email to
informacion@complylatam.com. You may also unsubscribe from email lists by requesting it through the same email.
Cookies and Other Tracking Mechanisms. Cookies are small text files that are sent to your computer when you visit our website or use our applications. We do not use cookies to track individual visitors or to identify you, but rather to gain useful knowledge about how our website and applications are used so that we can continue to improve them for our users.
Personal data generated through cookies is collected in an anonymized or aggregated format, not allowing us to identify you.

Comply uses the following types of cookies:
• user interface customization cookies (i.e. cookies that memorize your preferences);
• authentication cookies (i.e. cookies that allow you to leave and return to our websites without having to re-authenticate);
• video player cookies (i.e. cookies that store the data necessary to play video or audio content and store your preferences);
• first-party analytics cookies (i.e., cookies that memorize the pages you visited and provide information about your interaction with those pages); and
• third-party analytics cookies (i.e., cookies from third-party vendors that track our website statistics and vice versa).

Please note that you can modify your browser to notify you when cookies are being sent to you. If you do not wish to receive cookies, you can also refuse cookies by activating the appropriate setting on your browser. Finally, you can also delete cookies that have already been set.

For more information on how to manage cookies on your device, please refer to your browser's Help function or visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers (external link).

Other Mechanisms:
We may also use other technologies on our websites to collect and process your personal data for the same purposes as described above, which include:
• Internet tags (such as action tags, single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs, which are technologies that allow us to track user visits); and
• Adobe Flash technology (including Flash local shared objects, unless you configure your settings differently).
Cookies en Comply Academy. Comply Academy utiliza Learn Worlds como plataforma de cursos en línea, su política de cookies es la siguiente: y, adicionalmente puede consultar la política de cookies en español en www.complyacademy.com/cookies En caso de diferencia la versión más actualizada es la de Learn Worlds.
Use of discussion forums: When using the discussion forums, please note that your name will be displayed in the posts you make.

Referrals and Transfers of Personal Data
. Comply may transfer, without requiring your prior consent, the personal data necessary in compliance with contractual obligations, competent authorities and in the cases provided for by law, including but not limited to: tax, labor, administrative, social security and health authorities; to national and foreign third parties contracted for compliance with the purposes described herein.

Personal and course data is held on LearnWorlds servers which are based in England, the countries in which the servers are located can be found at https://www.learnworlds.com/data-security/.

Applicable Information Security Measures.
Comply has implemented physical, technical and administrative security measures framed in policies, procedures and information security standards appropriate to the applicable risk and technological development, which are subject to audits, reviews and periodic risk analysis and whose objective is to preserve the integrity, confidentiality and availability of personal data under our custody, regardless of the medium or format where they are, their temporary or permanent location or the way in which they are treated.

Third parties contracted by Comply are obliged to comply with this Privacy Notice, as well as with the policies, procedures and standards of information security. Any contract or agreement entered into with third parties involving the processing of personal data, includes obligations of confidentiality, retention, integrity, availability and comprehensive protection of the same.

At Comply Academy we use the Learn Worlds platform. You can access the information security measures that are implemented in https://www.learnworlds.com/data-security/ document in English).

Period
. The period of time for which we will store your Personal Data will vary depending on the purpose for which we have collected and are processing your data. In most cases, we will keep the data for three (3) years after our last interaction with you. However, we may keep your data for a longer period of time if we are required by law to keep your data.

Exercise of "A.R.C.O." Rights. You may exercise your rights of Access, Rectification, Cancellation and Opposition (Acceso, Rectificación, Cancelación y Oposición, "A.R.C.O. Rights") with respect to your personal data at any time and in accordance with the LPD. The A.R.C.O. Rights may be exercised upon delivery of the suggested form, to be requested by e-mail: informacion@complylatam.com. If applicable, and after validation of your identity, a folio number will be issued as confirmation of formal receipt of your request. Comply will respond within a maximum of 20 business days, or may require additional information to fulfill your request. If the response is favorable, Comply will have a period of 15 business days after a response is given to make your request effective. Through the same email, you may limit the disclosure of your information and request additional relevant information.

Comply's Personal Data Protection and Privacy Office is located at Av. Revolución 1267 Piso 19, Los Alpes, Álvaro Obregón, CP 01010, CDMX. In case you disagree with the way Comply treats your personal data, you can go to the National Institute of Transparency, Access to Information and Protection of Personal Data (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales, “INAI") at: http://ifai.gob.mx or directly at: Insurgentes Sur No. 3211 Col. Insurgentes Cuicuilco, Delegación Coyoacán, C.P. 04530. TELINAI toll-free telephone line: 01800-835-4324.

Any change or modification to this Privacy Notice will be informed to you by the appropriate and available means, for example, by e-mail or directly on our website.

Last updated: July, 2021