Privacy Notice for Clients

This privacy notice (“the Notice”) is issued in compliance with Article 15 of the Federal Law on Protection of Personal Data Held by Private Parties, hereinafter referred to as “the Law”, and its corresponding regulations under the Regulation of the Federal Law on Protection of Personal Data Held by Private Parties, hereinafter referred to as “the Regulation”, and is made available to users and third parties who provide personal data or information to SPIN MEXICO., hereinafter referred to as “SPIN”.

Responsible Party for the Protection of Your Personal Data

“SPIN”, with a notification address at Monclova 61, Roma Sur, Cuauhtémoc, CP 06760, Mexico City, Mexico, is responsible for the processing of your personal data.

Form and Means of Contact

To contact us, you must submit a request in Spanish addressed to the OFFICE OF PERSONAL DATA PROTECTION OF “SPIN” and send it by email to: administracion@spinmexico.com.mx

Personal Data We Collect and Means of Obtaining Personal Data

The personal data we collect from users to fulfill the purposes described in this “Notice” are obtained directly when provided to us through agreed-upon means with each intermediary and/or end user via our website, email, telephone calls to the reservation center, electronic messages, and when we obtain information through other sources of public access permitted by “the Law” and “the Regulation”.

The data we may collect include:

For individuals:

  • Full name, cellphone number, email address, address
  • Social media credentials or passwords (when you register as a user of our technological tools through social media or search engines)
  • Financial data such as Tax Identification Number (RFC), fiscal address, and payment information (consent is granted for processing this data as per Article 8 of “the Law”)

For legal entities:

  • Full name of the legal representative or attorney-in-fact, official identification, signature, email address, Unique Population Registry Code (CURP), date of birth, telephone number, address, and nationality
  • Financial or fiscal data of the company such as Tax Identification Number (RFC), fiscal address, and payment information (consent is granted for processing this data as per Article 8 of “the Law”)

“SPIN” does not store any debit card, credit card, or payment method information as part of the payment processing. “SPIN” transmits debit card, credit card, or payment method information directly to your bank or the payment platform being used.

Additionally, as permitted by “the Law”, we may obtain information from other sources such as telephone and service directories, physical or electronic, including name and surname, telephone number, email address, and address.

Personal Data of Third Parties and Minors

“SPIN” may collect and process personal identification and contact data of third parties, such as their full name, email address, and telephone number, when you or such third parties provide them for purposes related to products and/or services contracted on behalf of those third parties. By providing this information, you acknowledge having informed these third parties about the use of their personal data and having obtained their prior consent for “SPIN” to process it for the aforementioned purposes.

“SPIN” does not collect or process personal data of minors. Therefore, you acknowledge that at the time of providing your data, you are of legal age, have full legal capacity, and have read this privacy notice. In exceptional cases where personal data of minors or individuals with natural or legal incapacity established by law, such as name and age, are collected or processed, this will be done with the consent of the person exercising parental authority, guardianship, or legal representation, in accordance with applicable laws.

If “SPIN” identifies that personal data of minors or individuals with natural or legal incapacity has been provided without the consent of their parent or legal guardian, or that, due to human or technical error, personal data of minors or individuals with natural or legal incapacity has been collected, such personal data will be deleted from the databases containing them upon knowledge of the situation.

Sensitive Personal Data

“SPIN” does not collect or process any sensitive personal data of any kind.

Purposes of Processing Personal Data

Your personal data will be used for the following purposes:

Primary Purposes:

  • Identification and contact
  • Contracting, monitoring, updating, confirmation, and generation of history of contracted products and/or services
  • Creation, updating, customization, maintenance, and authentication of your user account
  • Addressing inquiries, complaints, comments, suggestions, clarifications, and following up on them
  • Security purposes: when acquiring a product or service, you may be recorded or photographed. Images from video recordings or photographs will be protected by “the Law” and “the Regulation” and will be retained in databases for a period of ten natural days, after which they will be formatted or deleted.
  • Credit validation and payment verification, and assessment of transaction fraud risks
  • Invoicing of contracted services or products
  • Compliance with legal and regulatory obligations, as well as requirements from government or judicial authorities, Federal, State or Municipal, and/or regulatory entities

Secondary Purposes:

  • Quality assessment of service through surveys, conducting studies on consumption habits and preferences
  • Participation in contests, draws, events, and promotions: If you participate in these activities, “SPIN” may collect your image through videos and/or photographs and publish them through various physical and electronic media, along with your personal data such as full name and surname, date of birth, email address, address, and telephone number, for documenting your participation or delivering the corresponding prize or incentive.
  • Informing and offering the range of products and services marketed by “SPIN” and communicating promotions
  • Marketing and commercial prospecting
  • Conducting mass data analysis techniques for profiling activities and better customer understanding

The provision of services and/or the creation of an account implies full and unconditional consent of users for the processing of their Personal Data in accordance with this Privacy Notice. If you wish to object to the processing of your personal data for the aforementioned secondary purposes, you must send an email to administracion@spinmexico.com.mx indicating which secondary purpose(s) you oppose and wish to opt-out from.

Limitations on Data Use

You may limit the use or disclosure of your personal data by sending a written request to administracion@spinmexico.com.mx, stating your intention to limit the use or disclosure of your personal data and providing necessary details such as: full name and surname, simple copy of your official identification, client number (if applicable), telephone number, and address or email address.

In addition to the procedure mentioned above, you may unsubscribe from promotional, marketing, and/or advertising emails by clicking on the link provided at the bottom of each email.

ARCO Rights

You or your duly accredited legal representative may exercise, when applicable, the rights of access, rectification, cancellation, or opposition, hereinafter referred to as “ARCO Rights” as provided by “the Law”, through the mechanism described below; it is important to mention that exercising any of the “ARCO Rights” does not preclude the exercise of another right.

Mechanisms for Exercising ARCO Rights and Revoking Consent for the Processing of Your Personal Data

The exercise of “ARCO Rights” as well as the revocation of your consent for the processing of your personal data will be carried out by submitting the respective request in writing, which the data subject or their legal representative must present to the OFFICE OF PERSONAL DATA PROTECTION OF “SPIN” via email to administracion@spinmexico.com.mx

Your request must indicate full name and surname, simple, readable, and valid copy of your official identification, or in case of using electronic means, you must attach the digitized version of it (scan), email address or address designated for notifications, and a contact telephone number. If your request is submitted by your legal representative, you must additionally provide official documents accrediting such representation with your request.

If the information provided in your request is incorrect or insufficient to process it, or if the corresponding accreditation documents are not attached, you will be requested to provide the necessary elements or documents within five business days following receipt of your request. You will have a period of ten business days to comply with this request, counted from the day following the issuance of the requirement by the OFFICE OF PERSONAL DATA PROTECTION OF “SPIN”. Failure to respond to this requirement within the granted period will result in your request being considered as not submitted.

Once the requirements mentioned above have been met, within a maximum period of twenty business days from the date of receipt of your “ARCO Rights” request, as well as from the date of revocation of the processing of personal data, the OFFICE OF PERSONAL DATA PROTECTION OF “SPIN” will respond regarding the acceptance of your request, by email sent to your email address provided in the request itself, or by sending a notification to the address you indicated for such purposes (the twenty days shall be considered fulfilled upon delivery of the document to the postal service). If the request is accepted, it will be effective within fifteen business days following the date on which the response of acceptance is communicated.

Transfer of National and International Data

Your personal data will not be transferred nationally or internationally to third parties without your consent, except as provided in Article 37 of “the Law”:

  • When the transfer is made between controlling companies, subsidiaries, or affiliates under the common control of “SPIN”, or to a parent company or any company of the same group as “SPIN” operating under the same internal processes and policies.
  • When the transfer is necessary for medical prevention or diagnosis, the provision of health care, medical treatment, or the management of health services.
  • When the transfer is necessary under a contract already executed or to be executed in your interest, between “SPIN” and a third party.Principio del formulario

Updating of Privacy Notice

This Privacy Notice may be updated, modified, or rectified for legal or internal reasons. Any change in this Privacy Notice will be made available to the public through the website www.spinmexico.com.mx/privacy-notice.

 

Information on the Internet

We hereby inform you that we utilize electronic technologies (cookies and web beacons) on our website: www.spinmexico.com.mx. When you access our Internet Portal, we receive information such as your browser type and operating system, the Internet pages you have recently visited, the links you have recently followed, your computer’s IP address, and the site you exited before entering our website.

You can disable or adjust the use of these technologies by following the procedures of the internet browser you use to access our website.

Disclaimer of Responsibility for Our Website or Application

While browsing or using our website www.spinmexico.com.mx or applications, you may encounter hyperlinks, links, banners, buttons, owned by third parties that may request your personal data (“Third-Party Sites”). Personal data that you provide through these portals or websites will be subject to the Privacy Notices displayed and applicable to these portals and websites. Therefore, “SPIN” will not be responsible for the use, publication, disclosure, and/or dissemination of your personal data that you provide through the aforementioned Third-Party Sites. We recommend users to be cautious and responsible regarding the personal information they provide on such sites.

Data Retention

“SPIN” will retain your information for as long as necessary for the purpose for which it was collected, unless you request its deletion. In such cases, “SPIN” will retain your personal data as long as necessary to comply with applicable laws and to fulfill its responsibilities derived from the processing of your data.

Modifications to this Privacy Notice

“SPIN” reserves the right to make modifications or updates to this “Notice” at any time. Any modifications will be made available to users through our website www.spinmexico.com.mx or via email to the most recent address we have from you.

Definitions

For the purposes of this “Notice,” the following definitions apply:

  1. Cookies: Text files that are automatically downloaded and stored on the hard drive of the user’s computer when browsing a specific internet page or portal, allowing the internet server to store certain data, including information about preferences and browsing patterns.
  2. Days: As stipulated by Article 3, Section VII of the Federal Law on Protection of Personal Data Held by Private Parties, deadlines and times specified in days are counted in business days.
  • ARCO Rights: Rights of Access, Rectification, Cancellation, and Opposition, established by “THE LAW” (Federal Law on Protection of Personal Data Held by Private Parties).
  1. Law: Federal Law on Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation on July 5, 2010.
  2. Regulation: Regulation of the Federal Law on Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation on December 21, 2011.
  3. Transfer: Any communication of personal data within or outside Mexican territory, made to a person other than the data subject, the data controller, or the data processor.
  • Web beacons: An image used exclusively to quantify the number of visits or monitor user behavior.