Notice of Privacy

Last updated: January 1, 2026.

COMINVI, S.A. DE C.V. (hereinafter referred to as “CoMinVi”, or the “Controller”, indistinctly), with address for the purposes hereof located at Boulevard Paseo de los Insurgentes 3356, Colonia Cumbres del Campestre, Zip Code 37128, Edificio Puerta Bajío, Floor 7, in León, Guanajuato, Mexico, is responsible for the processing of your personal data, in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter referred to as the “Law”) and its Regulations, in connection with the operations it carries out in Mexico by itself and/or through its subsidiaries. The authority that currently exercises functions regarding personal data protection in Mexico is the Ministry of Anti-Corruption and Good Government (hereinafter referred to as “SABG”), pursuant to the legal framework in force in Mexico.

The personal data that CoMinVi will collect, whether directly or through various electronic media, by telephone, as well as when we obtain information through other sources permitted by the Law, may be shared with the affiliates and/or subsidiaries and/or parent company of CoMinVi and used by them to comply with the obligations derived from the purchase and sale of products and/or contracting of services or works provided by CoMinVi and/or its affiliates and/or subsidiaries and/or parent company of CoMinVi, as well as with the execution and process of selection and recruitment of personnel, including, without limitation, customer service, invoicing, sales or contracting follow-up, recruitment process follow-up and/or services on digital platforms and technical support, whether through its websites (owned or contracted from third parties), digital platforms and/or portals related to the operations of CoMinVi and/or the affiliates and/or subsidiaries and/or parent company of CoMinVi, administered by itself or through third parties, or otherwise, in person.

Additionally, we will use and share with the affiliates and/or subsidiaries and/or parent company of CoMinVi your personal data for purposes that are not strictly necessary for the aforementioned commercial relationship with CoMinVi and/or the affiliates and/or subsidiaries and/or parent company of CoMinVi, including, by way of illustration but not limitation:

Promotion, marketing, advertising, and commercial prospecting of its own products and services or related third-party products and services.
Preparation and sending of satisfaction surveys, market studies, and consumer analysis.
Invitation to participate in events, conferences, courses, training sessions, fairs, or promotional activities organized by CoMinVi and/or the affiliates and/or subsidiaries and/or parent company of CoMinVi, and/or its distributors and/or integrators.
Sending electronic bulletins, newsletters, catalogs, invitations, or communications regarding news, launches, and updates of products and services.
Loyalty programs, benefits, discounts, rewards, contests, and commercial dynamics.
Evaluation of the quality of our products and services, and follow-up thereon for improvement purposes.
Segmentation and preparation of profiles regarding consumption, purchasing habits, preferences, interests, and behavior in the use of our products, services, or website.
Generation of statistics, metrics, and reports for internal commercial planning purposes.
Transfer of contact information to the affiliates and/or subsidiaries and/or parent company of CoMinVi, business partners, distributors and/or integrators and/or strategic allies, for marketing or joint promotion purposes.

In the event there are additional or different purposes from those established in this document, CoMinVi will inform you of changes in the aforementioned purposes. If you do not want your personal data to be processed for any or all of these secondary purposes, you may state so at any time by sending an email to: info@cominvi.com, indicating in the subject line: “I do not consent to the use of my data for secondary purposes”.

For the aforementioned purposes, we may collect, among others, the following personal data: a) identification data such as full name, date of birth, gender, marital status, nationality, and age, among others; b) corporate identification personal data, such as articles of incorporation, RFC, CURP, financial statements, tax address, among others; c) contact personal data, such as telephone number, email address, home address, among others; d) academic personal data such as school certificates and/or degrees, language certificate, level of education, professional license number, and educational background, among others; e) employment personal data such as business email address, personnel development, workplace address, position, company, work telephone number, among others.

CoMinVi does not collect sensitive personal data. If it is necessary to collect such sensitive personal data, we will request your express consent in accordance with the Law.

The personal data collected will be stored for the time necessary for the established purposes and/or as provided by the applicable legislation. We undertake that the aforementioned data will be processed under the strictest security measures that guarantee its confidentiality.

With respect to the personal data provided, the data subject has the right to access, rectify, and cancel such data, as well as to object to the processing thereof or revoke the consent granted to us for such purpose (“ARCO Rights”). Therefore, the Data Subject, pursuant to the applicable legislation, shall have the right to:

Access his or her personal data held by the Controller, as well as know the information related to the conditions and general aspects of the processing thereof. The Personal Data shall be sent to You free of charge (except for shipping and reproduction costs) by means of physical copies, electronic documents, or by any other means indicated in this Privacy Notice. If you repeat your request within a period of less than twelve (12) months, the Controller may charge you a fee that may not exceed three (3) days of the Unit of Measurement and Update.
Request that the Controller rectify or correct your personal data when such data proves to be inaccurate, incomplete, or not updated.
Request the cancellation of your personal data from the files, records, case files, and systems of theController, so that such data is no longer in its possession and ceases to be processed by the latter. Once the Controller has received a cancellation request, your Personal Data shall be subject to a Blocking Period, after which such data shall be deleted. The Controller shall notify you when the cancellation process has concluded. The Controller shall not be obligated to cancel the Personal Data when: (i) such Personal Data refers to the parties to a contract and is necessary for its operation and performance; (ii) such Personal Data must be retained by the Controller by legal provision; (iii) the cancellation of the Personal Data may obstruct judicial or administrative proceedings related to tax obligations, investigation and prosecution of crimes, or the updating of administrative sanctions; (iv) such Personal Data is necessary to protect the legally protected interests of the Data Subject; (v) such Personal Data is necessary to protect the public interest; and (vi) such Personal Data is necessary to comply with a legal obligation acquired by You.
Object to the processing of your personal data or demand that such processing cease.

To exercise your ARCO Rights, send a request through any of the following channels:

By telephone: At number +52 477 104 3566
Electronically: By email to the following address: info@cominvi.com.
In person by prior appointment or by postal mail: At the address: Boulevard Paseo de los Insurgentes 3356, Colonia Cumbres del Campestre, Zip Code 37128, Edificio Puerta Bajío, Floor 7, León, Guanajuato, Mexico.

Such request must contain: Name of the data subject and contact information, a clear description of the right he or she wishes to exercise, and a copy of a valid official identification.

‍CoMinVi shall issue a response to your request within a term not exceeding 20 business days, counted from receipt of the request, by the same means through which such request was made.

Once the request to exercise ARCO Rights has been made, and if applicable, CoMinVi shall make it effective within a maximum term of 15 business days, counted from the date on which the response to the request was communicated.

The aforementioned periods may be extended only once for an equal period, provided that the circumstances of the case so justify.

On the other hand, we inform you that, as established in the second and third paragraphs hereof, your personal data collected may be transferred to third parties within and outside the country and processed by them for the authorized purposes. In this regard, your information may be shared with controlling companies, subsidiaries and/or affiliates under common control of the controller, or with the parent company or any company of the same group as the controller that operates under the same internal processes and policies; suppliers of goods and/or services of CoMinVi and/or its affiliates and/or subsidiaries and/or parent company, for the purposes authorized by virtue hereof, as well as for the provision of services and/or purchase and sale of CoMinVi’s own products and/or those of its affiliates and/or subsidiaries and/or parent company. The foregoing in accordance with Chapter V of the Law. CoMinVi guarantees that, in these transfers and processing of personal data, it shall cause such third parties to formalize the necessary legal acts by means of which they shall be subject to the uses and restrictions that you have authorized hereby, as well as to comply with the internal control mechanisms and measures and the applicable legal measures.

If the holder of the personal rights does not state his or her objection for his or her personal data to be transferred pursuant to the preceding paragraph, it shall be understood that he or she has granted consent therefor and has read, understood, and agreed to the terms set forth above.

In the event that the holder of the personal data does not consent to the transmission thereof under the terms of this privacy notice, he or she must inform us of such refusal by sending it to the following email address info@cominvi.com or by appearing at the address: Boulevard Paseo de los Insurgentes 3356, Colonia Cumbres del Campestre, Zip Code 37128, Edificio Puerta Bajío, Floor 7, León, Guanajuato, Mexico.

Our website uses technical cookies and server logging technologies (logs) for the purpose of remembering the user’s browsing preferences (such as language), ensuring the security of the infrastructure, and allowing the portal to operate efficiently and securely. Cookies are text files that are automatically downloaded and stored in the browser or device when visiting a website.

Through these automated technologies and server diagnostic tools, the following technical information is obtained:

Visitor’s IP address.
Date and time of the access request.
Content of the request (specific pages visited within our site).
Volume of data transferred and access status (HTTP status code).
Website or search engine from which the request originates (referrer).
Operating system, language type, and version of the browser used.

On the other hand, any personal data that the user voluntarily provides, such as his or her name, email address, or other contact information, as well as the content of his or her message, shall be collected solely and exclusively when the user initiates direct communication through the institutional email addresses or forms enabled on the site.

Cookies strictly necessary for the operation, security, and display of the website do not require your prior consent to be executed. In the event that secondary tracking technologies for consumer profiles, advanced analytics, or behavioral advertising are implemented in the future, an explicit mechanism shall be enabled on the portal so that you may accept or reject such tools.

If you do not agree with the use of technical cookies, you may prevent their installation through your browser settings, or delete them subsequently. Please note that, if you limit or block these technologies, some site functions may not be available.

This notice may be modified at any time. Any modification to this privacy notice shall be notified to you by email at the email address you provide to us for such purpose; or, in the event you do not receive such notification, you may consult any change to this notice by contacting our personal data area, or directly at the address stated above.