Privacy & Data Protection policy

INTEGRAL PRIVACY NOTICE

In compliance with the Ley Federal de Protección de Datos Personales en Posesión de Particulares (hereinafter "LFPDPPP") "Grupo Ordas Howden, Agente De Seguros Y de Fianzas", Sociedad Anónima Promotora De Inversión De Capital Variable, (hereinafter "Howden"), with domicile at Lago Zúrich No. 245, Piso 16, Col. 245, Piso 16, Col. Ampliación Granada, Alcaldia Miguel Hidalgo, C.P. 11529, Mexico City and internet portal www.howdengroup.com, is responsible for the use and protection of your personal data, and in this regard we inform you of the following:

I. I. For what purposes will we use your personal data?

The personal data we collect from you, we will use them for the following purposes that are necessary to:

(a) To provide the services and/or products that Howden offers, as well as to carry out periodic evaluations of the same, to improve their quality.

b) To comply with the obligations contracted with customers.

c) To prepare and collect the insurance policy(ies).

d) Prepare and deliver the corresponding tax receipt.

e) Carry out the renewal of the respective policies.

f) Support and follow up in the event of a claim.

g) Inform about any change with respect to the policy(ies).

In addition, we will use your personal information for the following secondary purposes that are not necessary for the requested service, but that allow and facilitate us to provide you with a better service:

h) To inform about new services and/or products, which are related to the one contracted with the client.

i) Recruit and hire personnel directly or indirectly by Howden.

j)  Identify the public that enters Howden's facilities (customers, visitors and/or suppliers), for security and surveillance, as well as statistical purposes.

k) To attend and resolve clarifications and/or complaints, as well as for statistical purposes

l) Train Howden's personnel, as well as make internal communications, printed or digital, to encourage their performance.

m) To carry out any type of activities related to marketing or advertising.

In case you do not want your personal data to be processed for the secondary purposes referred to, you can communicate it to the following email: [email protected];

The refusal to use your personal data for these purposes may not be a reason for us to deny you the services and products you request or contract with us.

II. What personal data will we use for these purposes?

To carry out the purposes described in this Privacy Notice, we will use the following personal data:

a) Identification data

b) Contact data

c) Employment data

d) Personal and/or financial data

Likewise, we will use personal data considered as sensitive which require special protection, for example: information regarding present, past or future physical health, which will be used only to fulfill the purposes described in paragraph I of this document and will be treated and safeguarded with a high standard of security and strict confidentiality.

To limit the transfers indicated above, you can do so by sending an e-mail to: [email protected]

III. With whom do we share your personal information and for what purposes?

We inform you that your personal information may be transferred and processed inside and outside the country, by persons other than Howden. In that sense, your information may be shared with our business partners: Insurance Companies, Bonding Companies and Specialized Companies, in order to manage the services, we provide.

IV. How can you access, rectify, or cancel your personal data, or oppose to its use?

You have the right to know what personal information we have, what we use it for and the conditions of the use we make of it (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); to have it removed from our records or databases when you consider that it is not being used properly (Cancellation); as well as to oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

To exercise any of the ARCO rights, you must submit the respective request through the following means:

a) Customer Data Protection Department: e-mail:  [email protected];

b) Contact Center Data Protection Department, e-mail: [email protected];

c) Trademark Data Protection Department, e-mail: [email protected]; o

d)  Visit our website at the following address: www.howdengroup.com

To learn about the procedure, deadlines, requirements and to request the exercise of ARCO rights, it is necessary to send an e-mail to the Customer Data Protection Department at the following e-mail address: [email protected]

V. How can you limit the use or disclosure of your personal information?

For you to limit the use and disclosure of your personal information, we offer you the following means:

a) Your registration in the Public Registry of Users who Do Not Want Advertising Information of Financial Products and Services (REUS), which oversees the National Commission for the Protection and Defense of Users of Financial Services (hereinafter "Condusef"). For more information about this registry, you may consult the Condusef's web page or contact it directly.

b) For further information, please send an e-mail to the following address: [email protected]

VI. The use of tracking technologies on our website 

We inform you that on our website we use cookies, web beacons or other technologies, through which it is possible to monitor your behavior as an Internet user, as well as to provide you with a better service and experience when browsing our website, as well as to offer you new products and services based on your preferences.

The personal data we collect through these tracking technologies are the following: browsing hours, time spent browsing our website, sections consulted, and Internet pages accessed prior to ours.

Likewise, we inform you that your personal data obtained through these technologies will be shared with other persons, companies, financial entities, organizations, or authorities other than us, for the conservation of your information in servers and the realization of the collection of Howden's services by credit and/or debit card.

VII. ¿How you can learn about changes to this Privacy Notice? 

This Privacy Notice may be modified, changed, or updated as a result of new legal requirements; our own needs for the products or services we offer; our privacy practices; changes in our business model, or for other reasons.

Howden is committed to keep you informed about changes to this Privacy Notice, through: www.howdengroup.com

VIII. Date of last update: October 24, 2022.

If you consider that your right to the protection of your personal data has been violated by any conduct or omission of Grupo Ordas Howden, Agente De Seguros Y de Fianzas, Sociedad Anónima Promotora De Inversión De Capital Variable, or presume any violation of the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, its Regulations and other applicable laws, you may file a complaint with the National Institute for Transparency, Access to Information and Protection of Personal Data (INAI). For further information, please visit its official website https://home.inai.org.mx/