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Privacy Policy

1. IDENTIFICATION OF THE PERSON RESPONSIBLE
ALXEDO SMART WATER, S.A. de C.V. together with its controlling companies, subsidiaries, affiliates, companies under common control or companies belonging to the same group (here in after ALXEDO), a company duly incorporated in accordance with the laws of the United States of Mexico, located at Avenida Homero 205, interior 901, Polanco V Secc, Miguel Hidalgo, C.P. 11560 Mexico City, Mexico, makes available this Privacy Notice, in terms of the Federal Law of Personal Data in Possession of Individuals. ALXEDO has a Privacy Department which can be contacted by e-mail at privacidad@alxedo.mx, or in person at the address indicated in the previous paragraph. In this regard, we inform you that your data will be treated and safeguarded based on the principles of legality, quality, consent, information, purpose, loyalty, proportionality, and responsibility, as enshrined in the Law. 

2. PERSONAL DATA COLLECTED
We inform you that the personal data that we may collect are the following:

1.    Identification data: such as full name, date of birth, sex, nationality, federal taxpayer registration number (R.F.C.), unique population registration number (C.U.R.P.), official identification, gender, place of birth, marital status, videotape images, photographs and signature; among others;
2.    Contact details: e-mail, landline, mobile phone, home and/or fiscal address, real-time location [1];
3.    Employment data: occupation or profession;
4.    Personal data of minors: name, date of birth, age, nationality. These may only be obtained from the person who proves that he/she has parental authority over the minor.
5.    Financial and wealth data: credit and/or debit card number(s), effective date of credit or debit cards, card verification code (CVV) information, rewards e-wallet number and information;
6.    Network and authentication data: username, logins, login number, location.
7.    Social media and application data: login credentials, email registered to sign into Google (Google Account) or Apple, name and profile picture, date of birth.
8.    Preference data: such as searches for restaurants or cafés within the mobile application, most visited places, time spent using the mobile application.
9.    Purifier-related data: Location of the purifier, time of purification, start time of device use, purification quantities, water quality data, amount of carbon emissions avoided, plastic waste avoided, and money saved, number of cartridges changed and types of cartridges. 

We inform you that, for the collection and use of your financial or property data, current location, as well as for the personal data of minors, we will request your consent prior to the processing of such data, in the ways and means that are convenient and applicable to ALXEDO in each specific process where the processing of such personal data is involved. 

[1] ALXEDO will not collect the exact location, only the area in which the purifier is located and when using the website or mobile application.

3. WAYS OF COLLECTING YOUR PERSONAL DATA 
ALXEDO may collect your personal data, in different ways, as follows:

●       In person: verbally at the time of going to the ALXEDO facilities;
●       Through the ALXEDO mobile application;
●      By electronic means: telephone calls, instant messaging or any other means of communication, by means of which they may refer to the privacy notice in accordance with the operator's instructions.
●      By means of the purifier purchased with ALXEDO, at the time of updating the data related to your consumption in ALXEDO's system;
●      On the website: when you request information, when a message is sent, or when you provide your card details to proceed with the payment when requesting the service;
●      In the web shop: when you use the web shop, purchase items in the web shop and register your personal user profile. 

4. PURPOSES OF PROCESSING 
Primary purposes: The personal data collected will be used for the following primary or necessary purposes in order to provide the services offered by ALXEDO:

●     Identification and contact with the user
●    Know the location or location of the user;
●    Creation of the account holder's account as an ALXEDO customer;
●    Manage the account holder's account as a client of ALXEDO;
●    Deliver products to your home;
●    To adequately offer the products and services contracted with ALXEDO.
●    To protect and provide security of the data provided;
●    Manage the purchase, withdrawal or cancellation of ALXEDO products;
●    Collection of products and/or services;
●    Processing, issuing and administering invoices;
●    Attend and follow up on your questions or comments;
●    Registration and maintenance of an up-to-date database;
●    Compliance with applicable legal and regulatory obligations;
●    Send replacement cartridges to your home.
 
Secondary purposes: In addition, your personal data will be used for purposes that are not necessary for the maintenance of the existing legal relationship between the owners and ALXEDO, however, they allow us to provide you with a better service, which are mentioned below:

●      Conduct internal studies and procedures;
●      Creation of reports and statistical databases;
●      Creation of preference and consumption profiles;
●      Conduct service quality and satisfaction surveys;
●      To carry out communication, advertising and commercial prospecting campaigns;
●      Offering personalised services based on their consumption habits or profiles;
●      Send via e-mail advertising and updates on ALXEDO products;
●      Sending invitations to participate in events;
●      Sales;
●      Offering of goods and services, as well as promotions and advertising events of ALXEDO. 

We inform you that if you do not wish ALXEDO to process your personal data for the secondary purposes previously identified, you have a period of 5 working days to express your refusal, which must be communicated to ALXEDO's Privacy Department in writing, accompanied by the document that proves your identity or personality, and which must be sent to the e-mail address:
privacidad@alxedo.mx 
Likewise, we inform you that after the deadline for the expression of your refusal, at any time you are entitled to exercise your ARCO rights or revoke your consent for the processing of your personal data, in accordance with the provisions of this Privacy Notice. 

The refusal to process your personal data for the primary and secondary purposes set forth herein may be invoked as a reason for ALXEDO to cancel the services or products requested or contracted previously or subsequently, in accordance with the Terms and Conditions signed by you.

5. STORAGE PERIOD OF YOUR PERSONAL DATA 
In order to comply with the principles of quality and proportionality in the processing of your personal data, we inform you that your personal data will be kept and used by ALXEDO for the time necessary to fulfil the purposes for which it was processed, as well as for a subsequent blocking period of 10 years for commercial purposes. Once the previously established retention periods have expired, your personal data will be securely deleted from each and every one of the physical and electronic databases in which they are stored.

 6. TRANSFER OF PERSONAL DATA 
We inform you that your personal data may be transferred to national or international companies of the ALXEDO group, which are mentioned below:     

THIRD
Holding companies, subsidiaries or affiliates belonging to the same corporate group      
PURPOSE
Fulfilment of primary and secondary purposes in general.      
CONSENT
These companies that are part of the group share the same privacy policies as ALXEDO and are obliged to maintain the confidentiality of the  information and not to use it in any way other than that permitted by the  applicable legislation. Therefore, consent is not required in accordance with the provisions of Article 37 section III of the Federal Law on the Protection of Personal Data in the Protection of Personal Data. Possession of Individuals.

ALXEDO, at different stages and for different purposes of the processing of your personal data previously identified, needs to request the intervention of Data Processors, who will be individuals or legal entities that carry out such processing in the name and on behalf of ALXEDO, the latter ensuring that such processing is carried out in accordance with the provisions of this Privacy Notice. 

By accepting this privacy notice, you consent to the transmission of some of your data such as name, email and preferences to software companies dedicated to mass mailing, city councils of different states of the Mexican Republic, as well as to different establishments such as cafes, restaurants, bars or similar, solely and exclusively for information and general information without transmitting personal data specifically. 

Derived from the above and in accordance with the provisions of Article 53 of the Regulations of the Federal Law on Protection of Personal Data Held by Private Parties, we hereby inform you that ALXEDO does not need to obtain your consent to carry out such actions as they constitute a transfer of personal data. 

7. MEANS AND PROCEDURES FOR THE EXERCISE OF RIGHTS ARC
You have the right to know what personal data we hold about you, what we use it for and the conditions of our use of it (Access). It is also your right to request that we correct your personal information if it is out of date, inaccurate or incomplete (Rectification); that we remove it from our records or databases when you consider that it is not being used in accordance with the principles, duties and obligations set out in the regulations (Cancellation); and to object to the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

ARCO Rights requests will be processed and resolved by ALXEDO's Privacy Department within the terms established by Article 32 of the Federal Law on Protection of Personal Data Held by Private Parties, therefore, once we receive your request, we will notify you the resolution to it within a period not exceeding 20 working days, which will be effective in the subsequent period of 15 working days. If you do not comply with all the requirements set forth in this Privacy Notice or if we consider it necessary, ALXEDO, within the first 5 working days after you have submitted your request, may make a request for information in order to complement your request and be able to process it, having to comply with such request within the following 10 working days, otherwise your request will be deemed not to have been submitted. 

If you do not receive a response to your request from ALXEDO within the established deadlines, you have the right to file a data protection request with the National Institute for Transparency, Access to Information and Protection of Personal Data (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales, INAI). For more information visit: www.inai.org.mx

For more information about the procedure for exercising ARCO rights, please contact the ALXEDO Privacy Department. 

8. WITHDRAWAL OF CONSENT FOR THE USE OF YOUR PERSONAL DATA
You may revoke any consent you may have given us for the processing of your personal data. However, it is important for you to bear in mind that we may not always be able to comply with your request or terminate the use immediately, as it is possible that due to the existence of the legal relationship or a legal obligation, we may need to continue to retain your personal data. Furthermore, you should consider that according to the secondary purposes, this does not mean that we will no longer be able to provide you with the service you have requested, or that we will no longer be able to terminate your relationship with us. 

For more information about the consent revocation procedure, please contact the ALXEDO Privacy Department. 

9. ATTENTION TO COMPLAINTS AND DENUNCIATIONS
In the event that you consider that your right to the protection of personal data has been violated in any way by ALXEDO, you may, at any time, bring the matter before the Instituto National Institute for Transparency, Access to Information and Protection of Personal Data (INAI) to file the corresponding complaint or denunciation. 

10. CHANGES TO THE 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.

We undertake to keep you informed of any changes to this privacy notice by means of a general notification through the ALXEDO mobile application at the time you access it.

Last update on 14th of July 2021