Privacy Notice OTC

PERSONAL DATA COLLECTED

We collect the following personal data from our users, which is collected when the user creates an account with us or by performing any operation on the platform:

• Contact information:

  full name, email address, telephone number, home address, CURP (Unique Population Registry Code) RFC (Federal Taxpayers Registry) number, occupation or economic activity from which he/she obtains income..

• Identification information:

  official identification number, date of birth, gender.

• Financial information:

  bank accounts, transaction history.

• Registration information:

  user name, password.

As a requirement of the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds, in order to provide you with the full range of Apolus services, we may ask you to provide us with copies of the digitized official documents.

DATA COLLECTED AUTOMATICALLY

We may collect certain information automatically through the use of cookies and other tracking technologies, including IP address, browser type, pages visited and time of visit.

If you would like to learn more about this, we invite you to review our cookie policy.

SENSITIVE PERSONAL DATA

We do not collect or process sensitive personal data, such as medical, religious or racial information, unless it is strictly necessary and we have your consent,religious or racial information, unless it is necessary and we have your express consent.

PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA

The personal data we collect is used for the following purposes:

1. To manage your registration as a user of the site, to identify you and to give you access to the Services available to users.
2. The development, fulfillment and execution of the contract for the provision of our services.
3. To contact you by email to update you and inform you about resources, products or services offered, including security updates to the platform, whenever necessary and reasonable.
4. Respond to requests or inquiries you make through the customer service channels available on our platform.
5. We also use your information to generate non-identifiable aggregate data. For example, to generate statistics about our users, their jobs or areas of expertise, the number of hits or clicks on a particular course or project, or their demographics.
6. For legitimate interests of us, such as:
7. We also use your information to generate non-identifiable aggregate data. For example, to generate statistics about our users, their jobs or areas of expertise, the number of hits or clicks on a particular course or project, or their demographics.
   1. To manage, develop and grow our business.
   2. To operate our site and provide our services.
   3. Properly select suppliers.
   4. Research and statistical analysis.
   5. Marketing development.
   6. Management and internal audit purposes.

TREATMENT OF YOUR PERSONAL DATA WITH RESPECT TO THIRD PARTIES

Your personal data may be shared with third parties only in the cases provided by law or when necessary for the provision of our services, ensuring at all times the confidentiality and security of your information.

In case of compliance with the provisions of this clause, we undertake to issue you express notice when the data you provided to us are transmitted to third parties.

TRANSFER OF PERSONAL DATA

We may transfer your personal data to third parties located within or outside Mexican territory, as long as there is a transfer agreement that ensures adequate protection of your data in accordance with applicable law.

MEANS TO EXERCISE YOUR RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION OR OPPOSITION (ARCO RIGHTS)

You have the right to access, rectify, cancel or oppose to the processing of your personal data, as well as to revoke the consent granted for its processing, by sending an email to [email protected]

COMPETENT AUTHORITY

In case you consider that your personal data have been improperly processed, you can file a complaint with the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI).

MAINTENANCE AND DELETION OF DATA

We will keep your personal data only for the time necessary to fulfill the purposes for which it was collected, unless it is necessary to keep it for compliance with legal obligations or the resolution of disputes.

MODIFICATIONS TO THE PRIVACY NOTICE

We reserve the right to modify or update this privacy notice at any time, being your responsibility to periodically review the notice to be informed about the changes, however, we will notify you of any changes to this notice through the following means:

• Through the email address you have provided to us.
• Through pop-up messages on the platform.

RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA

The person responsible for the processing of your personal data is Holder Bay OTC S.A. de C.V. with address at Montes Urales 415, piso 5, Lomas de Chapultepec III Sección, Miguel Hidalgo, Mexico City, C.P. 11000, who guarantees the confidentiality, integrity and availability of your information.