Notice of Privacy

Identity and address of the Responsible
The person responsible for the processing of the personal data that you provide is RPM NEXO SA de CV with address located AV. REVOLUCIÓN No. Ext. 2703-1, Col. LADRILLERA, CP.64830, MONTERREY, NUEVO LEÓN, Mexico. .

Personal data and sensitive personal data processed by RPM NEXO SA de CV

To comply with the processing purposes indicated in this Privacy Notice, it is necessary for RPM NEXO SA de CV to process the following categories of personal data.

• Identification data, including your personal image;
  • Authentication Data;
  • Contact information;
  • Location Data;
  • Asset and financial data;
  • Tax Data;

You acknowledge having the consent of third parties for the processing of your personal data, when you contract for them to receive our products and services.

Likewise, we inform you that to comply with the purposes indicated in this Notice, RPM NEXO SA de CV will not collect or process sensitive personal data.

Primary purposes
RPM NEXO SA de CV may process your personal data to fulfill the following primary purposes:

• Identify and register you as a user and/or buyer of our products and/or services.
• To process the request(s) for products and services that RPM NEXO SA de CV provides or could provide you.
• Deliver the products you request to RPM NEXO SA de CV and/or a third party with whom we have entered into commercial and/or collaboration agreements.
• For the evaluation, improvement, administration, procurement and granting of the products and services that we offer (including the design and development of new products and services) and carry out all the necessary activities to comply with the legal obligations contracted with you.
• Validate the veracity and quality of the information provided by you or that which can be obtained from other lawful sources to which RPM NEXO SA de CV may have access, including the verification of your data before government agencies or third parties with whom we have entered into agreements. of colaboration.
• Comply with and monitor the institutional procedures and activities provided for in applicable internal guides, procedures, regulations, standards, codes or policies.
• If applicable, to manage and administer electronic access to the systems and technological infrastructure that is used for you to receive our products and services.
• Make your opinions known to third parties in relation to our products and services.
• Manage payments, discounts when applicable, refunds and billing for products and services provided to you, including collection activities.
• In cases where applicable, to keep a record of your credit history and behavior.
• In cases where required, to send to the credit bureau database in the event that you fail to comply with the payment obligation derived from the legal relationship with RPM NEXO SA de CV, in which case, the use of your information It will be governed in accordance with the provisions of the Law to Regulate Credit Information Companies.
• Keep a historical and statistical record of the products and services purchased by you as well as to personalize our offer of products and services according to your interests.
• Address questions, complaints and requests for information in relation to the products and services we offer.
• Comply with obligations provided for in the applicable regulations.

We inform you that you cannot object to RPM NEXO SA de CV ceasing the processing of your data for the primary and necessary purposes mentioned above, given that the processing is necessary to comply with obligations arising from the relationship between you and the RPM NEXO SA de CV

Secondary purposes
Additionally, RPM NEXO SA de CV will use your personal information for the following purposes that are not necessary for the service you request from us, but that allow and facilitate us to provide you with better service:

• Send advertising and marketing communications, publicity and commercial prospecting of own and/or third-party products and services, through various means of communication channels, both physical and electronic.
• For the application of surveys and evaluations to improve the quality of the products and services we offer.

If you do not want RPM NEXO SA de CV to process your personal data for any of the purposes described in this section, please send an email to hola@club16.mx . You may change your option at any time, following the procedure, requirements and deadlines for the exercise of your ARCO Rights and/or revocation of consent on our website: https://www.club16.mx .

It is important that you keep in mind that, if you grant your consent, it will continue to be valid even when the legal relationship between you and RPM NEXO SA de CV has ended, which means that RPM NEXO SA de CV may continue to process your necessary personal data. to fulfill these secondary purposes.

Transfers
Based on the provisions of article 37 of the LFPDPPP, RPM NEXO SA de CV may transfer your personal data without requiring your consent in the following cases:

• To holding companies, subsidiaries or affiliates under the common control of the controller, or to a parent company or any company in the same group of the controller that operates under the same internal processes and policies;
• Competent authorities in the cases provided for by the applicable regulations, in the event that we receive a mandatory requirement. When necessary for the maintenance or fulfillment of the legal relationship between you and RPM NEXO SA de CV with the purpose of complying with the purposes reported in this Privacy Notice.

If you do not want RPM NEXO SA de CV to transfer your personal data for those transfers for which your consent is necessary, we ask you to send an email following the procedure, requirements and deadlines for the exercise of your ARCO rights and/or revocation of the consent of our website:

https://www.club16.mx

ARCO rights and/or revocation of consent
You or your legal representative may exercise any of the rights of access, rectification, cancellation or opposition (hereinafter “arch rights”), as well as revoke your consent for the processing of your personal data through email and following the procedure , requirements and deadlines for the exercise of your ARCO rights and/or revocation of consent on our website:
https://www.club16.mx.

It is important that you keep in mind that your request will be attended to within the deadlines provided by the applicable regulations and not in all cases we will be able to respond to your request or conclude the use immediately, since it is possible that due to some legal obligation we may need to continue processing your personal information.

Options and means to limit the use or disclosure of your Personal Data
You may limit the use or disclosure of your personal data in events or activities carried out through digital tools and platforms, by not activating the camera, by not using your personal image in the account with which you connect and/or not registering with your profile (it will depend on the platform used to carry out the event or activity).

In email communications, subscribing to our exclusion list (unsubscribe list), when this is available in the communication itself.

In other cases, you may limit the use or disclosure of your personal data by sending your request to hola@club16.mx

The requirements to prove your identity, as well as the procedure to respond to your request, will be governed by the same criteria indicated on our website:

https://www.club16.mx.

If appropriate, you will be registered on the exclusion list of RPM NEXO SA de CV.

Use of Cookies
RPM NEXO SA de CV uses various technologies to improve the efficiency of the Platform, including your experience when you browse the site. Cookies are small amounts of information that are stored in the browser used by each user so that the server remembers certain information that it can later use. This information allows us to identify and save your personal preferences to provide you with a better browsing experience.

We remind you that you can deactivate, disable or adjust the use of cookies and other technologies by following the procedures of the internet browser you use.

• Select the “settings” or tools option according to your browser
  • Select the option disable cookies
  • This process will not only disable cookies on our Platform, but also those of your entire browser.

The personal data that can be obtained through the use of these technologies are the following: Identifiers, username and passwords for a session; region in which it is located; browser type; type of operating system; date and time of the start and end of a session; visited web pages; searches performed and advertising reviewed. These technologies may be disabled by following the procedures of the internet browser you use.

Personal Data Department of RPM NEXO SA de CV

It is important to inform you that RPM NEXO SA de CV has a Personal Data Department which, as part of its functions, is responsible for resolving any questions you may have related to the use of your information. Likewise, the Personal Data Department will follow up on any complaint or claim that you may have related to the processing of your personal information.

You can contact the Personal Data Department of RPM NEXO SA de CV by sending an email to the following email address: hola@club16.mx

INAI
If you consider it necessary, we inform you that you have the right to go to the National Institute of Transparency Access to Information and Protection of Personal Data (INAI) to assert any disagreement related to the processing of your personal data by RPM NEXO. Anonymous Society of Variable Capital.

Changes to the Privacy Notice
RPM NEXO SA de CV reserves the right, under its sole discretion, to change, modify, add or delete parts of this Privacy Notice at any time. Derived from legislative developments, internal policies or new requirements for the provision or offering of our services, this Privacy Notice will be subject to modifications or updates. In such case, RPM NEXO SA de CV will inform you of the changes by means of a statement on the official website: club16.mx/ and will indicate the date of the last version of the notice. We recommend that you periodically review this page in order to inform yourself if there are any changes to this page.