Pursuant with the Federal Law on the Protection of Persona Data Held by Private Parties [Ley Federal de Protección de Datos Personales en Posesión de los Particulares] (hereinafter, the “Law”), the corporation denominated “CONSULTORES EN GESTIÓN POLÍTICA Y PLANIFICACIÓN AMBIENTAL” S.C., hereinafter “GPPA”, with legal address at Zona Hotelera, Manzana 27, Lote 1 02, UC 54, Office 401, Puerto Cancun, Diomeda, Cancun, Benito Juárez, Quintana Roo, Zip Code 77500, its subsidiary located in Avenida Insurgentes Sur 1793 office 302 col. Guadalupe Inn. Alvaro Obregon Zip Code 01020, and its internet site with address www.gppa.com.mx, is responsible for the use and protection of your Personal Data, and we hereby inform you of the following:

Your data will be collected and treated as per the principles of law, informed consent, information, quality, finality, loyalty, proportionality, and responsibility, in accordance to the aforementioned Law.

For what purposes are your Personal Data used?

Personal Data we collect from you are to be used with the following purposes, which are necessary for the performance of our services:

PRIMARY OBJECTIVES:

1. To provide requested professional consultancy and advice services, both domestically and internationally, for the private and public sectors, aligned with execution of the social object of GPPA.
2. In relation to the business lines of aerial photography, Lidar, thematic environmental cartography, diagnosis and restoration, environmental statements, Evidentiary Technical Studies.
3. Environmental training and education, feasibility studies, legal and environmental project management system, environmental supervision and monitoring, nutrients assimilation and water treatments, environmental zoning and characterization studies.
4. Quality studies, natural hazards studies, environmental impact studies, land use permit change studies, urban development programs preparation, environmental management programs preparation, construction and operative processes environmental supervision, diagnosis and environmental quality studies.
5. Contracting and sub-contracting local and international professionals, academicians, experts and consultants for the purpose of coordinating their efforts and resources for the provision of the services related to the social object of GPPA.
6. To sign contracts and in order to provide services and fulfill our contracted obligations in the industrial and business sectors of hydrocarbons, electric power, alternative energy sources, manufacturing, infrastructure development, highways, ports, railways, telecommunications, construction, real estate, tourism.
7. Teaching courses and conferences to individuals, companies, and private and public institutions focused on issues germane to the social object of the corporation.
8. Creation, edition, promotion, and sale of books, magazines, or newsletters aimed at promoting and advertising progress, works, reports, discoveries, methodologies, and case studies in relation to the social object of GPPA.
9. To contact and to identify You.
10. To carry out all internal tasks related to the commercial relationship, including credit and payment issues.
11. To manage collections and invoicing for our products and services.
12. To contact you over the telephone, electronic mail, ordinary mail, and any other means for information and promotional purposes of the Company.
13. To prepare and enter into Purchase and Sale, Consignment, Distribution, Supply, Service, or any other Contracts for which a commercial relationship is required with our clients.
14. To fulfill obligations contracted with our clients.
15. PTo fulfill all legal provisions and obligations resulting from the juridical relationship existing between GPPA and its Clients.

SECONDARY OBJECTIVES:

Additional, we will use your personal data for the following objectives, which are not necessary for the requested services, but which facilitate and enable us to offer a better service to you:

1. Development of our services.
2. Publications, manuals, and training courses, update courses, environmental certifications, climate change.
3. To inform you of changes to our services.
4. To evaluate the quality of our services.
5. For the promotion and marketing of our services and products.
6. For internal statistical purposes.
7. For statistical and internal analysis purposes.
8. For courier purposes.
9. For the purpose of mailing documents.

Should you not wish your Personal Data to be treated for these additional purposes, you can let us know at any time from this moment forward.

Should you not agree with the treatment of your Personal Data for the primary objectives, abstain from providing that information. Should you not agree with the treatment of the secondary objectives, you may let us know of your refusal in writing, addressing your communication to the legal address of the corporation as mentioned above in this Privacy Notice, as indicated below, in exercise of your ARCO [Spanish initials for Access, Correction, Cancellation, and Refusal] rights, as Holder of the data, or by emailing the following address: privacidad@gppa.com.mx

The duration of our handling of the Holders’ Personal Data shall depend on the relationship they may have with GPPA, as well as on the obligations demanded by the current legislation, competent authorities, and internal policies at GPPA.

Should you not wish to state your refusal to have your Personal Data treated for the primary and secondary objectives, your permission shall be understood as granted.

Your refusal for our treatment of your Personal Data for the secondary objectives shall not be cause for our refusal of any services or products you may request or hire from us.

What Personal Data Is Used for these Purposes?

In order to carry out the objectives described in this Privacy Notice, we shall require the use of the following Personal Data:

-- Identification data, such as Full name (official photo ID), place and date of birth, age, photograph, Landline number or mobile phone number (private), Fax number (private), address (private and fiscal address), an image of the Data Holder entering the facilities of GPPA (obtained by means of closed circuit and surveillance cameras), electronic mail address, marital status, Federal Taxpayers Number (RFC, in Spanish), Unique Key of Population Registry (CURP, in Spanish).

-- Work-related data, such as Occupation or professional activity, landline number of work-related mobile phone number, work electronic mail address, work fax number.

-- Invoicing Data, bank reference, fiscal address, RFC.

At "GPPA" we do not collect or manage sensitive Personal Data, understanding these as: those personal data which affect the intimate sphere of the Holders, or whose use might give rise to discrimination or might entail a serious risk for the Holder. Particularly, sensitive data are understood as those which might reveal personal aspects, such as racial or ethnic origins, current and future health status, genetic information, religious, philosophical, or moral beliefs, union affiliations, political opinions, sexual preferences.

I consent and authorize that my Sensitive Personal Data provided to the party responsible for their treatment, be transmitted and treated in accordance to the provisions of this Privacy Notice.

I do not consent or authorize that my Sensitive Personal Data be transmitted or treated as per the provisions of this Privacy Notice.

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

We hereby inform you that your Personal Data are shared, within the country and abroad, with the following persons, companies, organizations, and authorities, other than ours, for the following purposes:

Recipient of Personal Data	Country (optional)	Purpose
Local, state, and federal authorities, as well as various Public Entities, and those indicated by the Law.	México.	The fulfillment of the obligations indicated by the Law.
Experts in subjects related to each project generated by the client.	Mexico and abroad, as necessary to satisfy contracted obligations.	Supporting the various technical issues related to the projects.
Bank.	México.	Personnel payments (employees).
Client’s bank.	México.	If applicable, to collect on our Services by means of Debit or Credit Cards.

I consent and authorize that my Sensitive Personal Data be transmitted and treated in accordance to the provisions of this Privacy Notice.

I do not consent or authorize that my Sensitive Personal Data be transmitted or treated as per the provisions of this Privacy Notice.

If you do not state your refusal for said data transmissions, your permission shall be understood as granted.

What are the rights of the Personal Data Holder?

In accordance to the provisions of the Federal Law on the Protection of Persona Data Held by Private Parties, from January 6 of 2012, you may, as Personal Data Holder, exercise the rights of access, correction, cancellation, and refusal, which are known through the acronym – in Spanish - “ARCO Rights” (as long as legally appropriate). Likewise, you may revoke your granted consent, which was necessary for the management of your Personal Data, at any time, as well as to limit the use or transfer thereof. In all cases of a legally appropriate request, the delivery of the Personal Data shall be free, and you shall cover only justifiable courier costs, or the cost of the production of photocopies or any other format used, as established by the reference Law.

How can you access, correct, cancel your Personal Data, or refuse to consent to their use?

You are entitled to know which of your Personal Data we have in storage, what we use them for, and what conditions we use them in (Access). Likewise, you are entitled to request corrections to your personal information, in case it is no longer up to date, it is inaccurate or incomplete (Correction); to have it deleted from our registries or databases, when you consider it is not being used according to the principles, duties, and obligations established by the Law (Cancellation); as well as to oppose to the use of your Personal Data for specific purposes (Refusal). These are the rights known as ARCO.

To do so, it is necessary for you to send a request in writing to “GPPA”, at the social address located in: Zona Hotelera Mz. 27 Lt. 1 02, Uc 54 Office 401, Puerto Cancún, Diomeda, Zip Code 77500, Cancun, Quintana Roo, or via email to privacidad@gppa.com.mx  whose reception we ask you to confirm over the telephone. Should you require any help or assistance from us, we ask that you kindly contact the following telephone numbers (998) 688 22 40 and (998) 688 08 75 from Monday to Friday, from 09:00 am to 14:00 pm and from 15:00 pm to 19:00 pm.

How can you revoke your consent for the use of your Personal Data?

You may revoke the consent you may have granted us for the management of your Personal Data. However, it is important that you consider that we may not respond to your request, or discontinue the use of the information immediately in all cases, since it may be possible that, due to legal obligations, we may require to continue to manage your Personal Data. Likewise, you must consider that, for certain purposes, revoking your consent will imply that we can no longer continue to render the services you requested, or be forced to terminate your relationship with us.

In order to revoke your consent, you must send a request in writing to “GPPA”, at the social address located in: Zona Hotelera Mz. 27 Lt. 1 02, Uc 54 Office 401, Puerto Cancún, Diomeda, Zip Code 77500, Cancun, Quintana Roo, or via email to privacidad@gppa.com.mx  whose reception we ask you to confirm over the telephone. Should you require any help or assistance from us, we ask that you kindly contact the following telephone numbers (998) 688 22 40 and (998) 688 08 75 from Monday to Friday, from 09:00 am to 14:00 pm and from 15:00 pm to 19:00 pm.

You may revoke your consent at any time, without retroactive affects. In order to begin the process of revocation, you must indicate, precisely and in writing, which consent it is that you wish to revoke, and send it to the address indicated above, or to the electronic mail address: privacidad@gppa.com.mx . All written, and/or electronic requests for access, correction, cancellation or refusal must contain, and be accompanied by, the following:

1. The name and address of the Data Holder, or some other means for us to communicate our response to your request.
2. The documents that certify the identity or, if applicable, the legal representation of the Data Holder.
3. A clear and precise description of the Personal Data on which you seek to exercise any of the aforementioned rights, and
4. Any other element or document that will enable us to locate your Personal Data.
5. In case of requests for corrections, the Data Holder shall indicate the corrections to be made and provide the documentation necessary to support the request.

“GPPA”, will inform the Data Holder, within twenty working days from the date of the reception of the request for access, correction, cancellation or refusal, of its decision so that, should it be legally appropriate, it shall be effectively adopted within fifteen days from the date of the response. In the case of requests for Personal Data access, the delivery shall be legally appropriate once the identify of the applicant or his/her legal representative has been ascertained, as appropriate. The above-mentioned periods of time may be extended only once, for a similar period, when required by the circumstances applicable to each case.

The obligations to grant access to the data shall be deemed as fulfilled when the Personal Data are made available to the Data Holder, or when “GPPA” issue the data in simple copies, electronic documents, or through other means, to the Data Holder.

In case the Data Holder requests access to the data from a person he or she presumes to be responsible for their management, who turns out not to be, letting the Data Holder know through any printed (Letter of Non Compliance) or electronic (e-mail, optical media, etc.) means, shall be sufficient to deem the request as fulfilled.

“GPPA” may deny access to the Personal Data, or to its correction or cancellation, or may refuse to acknowledge the refusal to consent to their use, in the following cases:

1. When the applicant is not the Data Holder, or when his or her legal representative is not properly authorized to do so.
2. When the applicant’s Personal Data cannot be found in our databases.
3. When breaching the rights of any third party.
4. When legal impediments arise, or when there arises a decision by a competent authority restricting the access to the Personal Data, or denies the right to correct, cancel or refuse said data.
5. When corrections, cancellation or refusals have been previously made.

The refusal mentioned above may be partial, in which case “GPPA” will comply with the access, correction, cancellation or refusal requested by the Holder.

In all of the cases above, “GPPA” shall inform of the reasons for their decision, and inform the Holder or his or her legal representative, within the period established for such purposes, through the same means of communications as the request, accompanied by pertinent evidence.

“GPPA” shall not be obligated to cancel the use of Personal Data when:

1. They refer to the parties in a Private, Social, or Administrative Contract, and they are necessary for the fulfillment thereof.
2. They must be stored and managed based on any legal provisions and mandates.
3. It might impede judicial or administrative acts related to fiscal obligations, the investigation and prosecution of crimes, or updates to administrative sanctions.
4. They are necessary to protect the lawful interests of the Holder.
5. They are necessary to carry out any acts in service of the public interest.
6. They are necessary to fulfill legally acquired obligations of the Holder.

Should the cancellation be legally appropriate, “GPPA” shall determine a blocking period for the sole purpose of establishing potential liabilities in relation to their management or treatment, until their validity has legally or contractually run its course; then “GPPA” shall inform the Holder or his or her legal representative of its response to the cancellation request, which will be issued within twenty working days; begin the blocking period within fifteen working days; and after the expiration of the blocking period, make the corresponding deletions.

The blocking period shall extend until the expiration of the data’s legal or contractual validity.

How can you limit the use or transmission of your Personal Data?

In order for you to limit the use and transmission of your personal data, we offer the following means:

• Your registration in the Public Registry to Avoid Publicity [Registro Público para Evitar Publicidad], of the Office of the Federal Prosecutor for the Consumer [Federal del Consumidor], so that your personal data may not be used to receive publicity or offers of goods or services from companies. For further information about this Registry, you may visit the PROFECO’s website or contact it directly.

Your inclusion on the Exclusion List titled “GPPA EXCLUSION LIST”, so that your Personal Data may not be managed or used for marketing, advertising or commercial lead generation purposes by us. For further information, call (998) 6 88 22 40 and (998) 6 88 08 75 from Monday to Friday, from 09:00 a.m. to 14:00 p.m. and from 15:00 p.m. to 19:00 p.m. or email this address privacidad@gppa.com.mx.

The use of Tracking technologies in our Internet Website

We may use cookies, web beacons and/or similar technological elements in our internet website in order to obtain information, such as: (a) your type of browser and operating system; (b) Internet pages you visit; (c) links you follow; (d) IP address; (e) sites you visited before visiting ours; (f) user identification; (g) highlighted information detection; and (h) measuring certain traffic parameters. The “help” button located in the toolbar of most browsers will tell you how to refuse our cookies, how to have your browser inform you when you receive a new cookie, and how to disable cookies.

There are several sites within the “GPPA” website which may connect to other websites which do not operate under the privacy policies of “GPPA”. When you connect to other websites, the privacy practices of “GPPA”, as well as this Notice, are no longer valid. We invite our users to review the privacy policy as well as the corresponding notice of each site before disclosing their personal information.

How can you be informed of changes made to this Privacy Notice?

This Privacy Policy may be modified, changed, updated as resulting from our legal requirements; our own needs related to the products and services we offer; our privacy practices; or changes to our business model.

We reserve the right to change this Privacy Notice at any time, at the sole discretion of its Administrators. The latest update to this Privacy Policy, as well as any changes to the Privacy Notice, may be consulted at our website http://www.gppa.com, or at our offices, without the need for us to inform you individually of these modifications.

Should the Data Holder provide his or her Personal Data, this will signify that he/she has read, understood, and accepted the terms established herein.

I consent and authorize that my Personal Data be treated in accordance to the provisions of this Privacy Notice.

Latest update: 28/10/2014.