Privacy Notice and Cookie Usage Policy

Data Controller

The Data Controller for your personal data is the legal entity DIRECTO TELECOM, S.A. DE C.V. (hereinafter referred to as "DIRECTO"), with its address for receiving and handling any type of notification at Pedregal 24, 6th Floor, Office 601, Colonia Molino del Rey, Alcaldía Miguel Hidalgo, Mexico City, C.P. 11040.

You can consult this Privacy Notice at any time on the website: www.directo.com

Services

DIRECTO offers Telecommunications services and related services (hereinafter collectively referred to as the "Services"). Its clients include financial institutions, service providers, and others.

Categories of Personal Data Subject to Processing

To provide our Services and fulfill the purposes outlined in this Privacy Notice, DIRECTO needs to process the following personal data:

a) Personal Data

DIRECTO will process the following categories of personal data:

  • Identification and authentication data
  • Contact data
  • Financial and/or asset data

Identification Data

  • Full Name
  • Date of Birth
  • CURP
  • RFC
  • Residential Address
  • Tax Address

Contact Data

  • Email
  • Landline Phone
  • Mobile Phone

Banking and/or Asset Data

  • Bank Account (optional)

Sensitive Data

DIRECTO does not request Sensitive Personal Data at any time.

Primary Purposes of Data Processing

DIRECTO will process the personal data described in this Notice to carry out any or all activities necessary for the development and fulfillment of obligations arising from the Services, including the following purposes:

  • Identification: DIRECTO may verify and authenticate your identity in accordance with our procedures and policies, including verifying your voter ID and fingerprint similarity with the National Electoral Institute.
  • Contact: DIRECTO may communicate with you for commercial and customer service purposes, as well as to send notifications.
  • Registration: DIRECTO generates databases with dissociated Personal Data for internal consultation by personnel handling your Personal Data.
  • Preparation of Service and/or Employment Contracts.

Secondary Purposes of Data Processing

DIRECTO will process your personal data to carry out any or all of the following secondary purposes:

  • Marketing and Advertising: To inform you about the launch or changes of new products, goods, services, promotions, and/or offers from DIRECTO, in line with your interests, including phone calls, emails, text messages, and other physical or electronic communication methods.
  • Debt Collection: Regarding the commercial relationship you maintain with DIRECTO, your contact data will be used to make phone calls, send emails, and other physical or electronic communication methods regarding outstanding debts with the company.

Refusal of Consent

If you do not wish for DIRECTO to process your personal data for any of the purposes described in this section, please send an email at any time to datospersonales@directo.com.

It is important to note that if you grant your consent, it will remain valid, meaning DIRECTO may continue to process your personal data necessary to fulfill these secondary purposes. However, you may revoke this consent at any time as stipulated in this Privacy Notice.

Data Transfers

a) Not Subject to Consent

DIRECTO may transfer your personal data to both national and foreign entities without requiring your consent in the following cases:

  • When the transfer is necessary or legally required for safeguarding public interest or for the administration of justice.

b) Subject to Consent

DIRECTO does not transfer your Personal Data to Third Parties.

Means and Procedure to Exercise ARCO Rights and/or Revoke Consent for Personal Data Processing

You or your legal representative may exercise any of the rights of access, rectification, cancellation, or opposition (hereinafter "ARCO Rights"), as well as revoke your consent for the processing of your personal data by sending an email to DIRECTO's Personal Data Department at datospersonales@directo.com, where you will be attended to promptly.

Your request must be made through the ARCO Rights Exercise Form, Revocation of Consent, and/or Limitation of Use or Disclosure of Personal Data (hereinafter the "Form"), which must be sent to the email datospersonales@directo.com. This Form is available on DIRECTO's website or can be obtained by sending an email to the aforementioned address.

For DIRECTO's Personal Data Department to process your request, you or your legal representative must correctly verify your identity by completing all fields in the Form and attaching a copy of a valid official identification.

Accepted Identification Documents:

  • Voter ID (INE)
  • Professional License (Digitized)
  • Passport
  • FM2, FM3 (Migration Document)
  • Driver's License type A, B, or C (Issued in Mexico, foreign licenses are not accepted)

Additional Documents for Legal Representatives:

  • Notarized Power of Attorney.
  • Power of Attorney signed before two witnesses.

If the information provided in the Form is incorrect or insufficient, or if the required identification documents are not attached, DIRECTO's Personal Data Department may, within five (5) business days of receiving the request, ask you to provide the necessary elements or documents to process it. You will have ten (10) business days to respond to the request, counted from the day after you receive it. If no response is received within this period, the request will be considered not submitted.

DIRECTO's Personal Data Department will inform you of the decision made within a maximum of twenty (20) business days from the date the request was received, so that, if applicable, you can enforce it within fifteen (15) business days after the response is communicated. If the request is denied, the Data Subject will be notified. The response, whether positive or negative, will be sent electronically to the email address specified in the Form at no cost to the Data Subject.

DIRECTO's Personal Data Department

It is important to note that DIRECTO has a Personal Data Department which, as part of its functions, is responsible for resolving any questions you may have regarding the use of your information. Additionally, the Personal Data Department will handle any complaints or claims you may have related to the processing of your personal data.

You can contact DIRECTO's Personal Data Department by sending an email to: datospersonales@directo.com.

DIRECTO Facilities

If you visit DIRECTO's facilities located at Pedregal 24, 6th Floor, Office 601, Colonia Molino del Rey, Alcaldía Miguel Hidalgo, Mexico City, C.P. 11040, you will be recorded by security cameras. The images and sounds captured by the surveillance cameras will be used for your safety and the safety of those visiting the offices.

Changes to this Privacy Notice

DIRECTO reserves the right, at its sole discretion, to change, modify, add, or remove parts of this Privacy Notice at any time. In such cases, DIRECTO will keep the updated Privacy Notice on the website www.directo.com. We recommend that you periodically visit this page to stay informed of any changes.

Cookie Usage Policy

1. Introduction

At DIRECTO, we respect your privacy and are committed to ensuring that your personal data is protected while browsing our website or using our online services. This Cookie Usage Policy explains what cookies are, how we use them, and how you can manage them. By continuing to use our services, you agree to the use of cookies in accordance with this policy.

2. What are Cookies?

Cookies are small text files that are downloaded to your device (computer, tablet, smartphone) when you visit a website. These files allow the website to recognize your device and remember information about your visit, improving your user experience.

3. Types of Cookies Used

DIRECTO uses the following categories of cookies:

  • Essential or Technical Cookies: These are necessary for our website to function correctly. They enable navigation and the use of essential functionalities, such as accessing secure areas.
  • Performance and Analytics Cookies: These help us understand how users interact with our site, improving performance and functionality. They collect information anonymously and allow us to know which pages are most visited.
  • Functionality Cookies: These cookies allow us to remember your preferences and personalize your experience on our website (e.g., your preferred language or region).
  • Advertising and Marketing Cookies: These cookies are used to deliver relevant advertising to you and your interests. They are also used to limit the number of times you see an ad and measure the effectiveness of advertising campaigns.

4. How Do We Use Cookies?

DIRECTO uses cookies for various purposes, including:

  • Improving User Experience: We remember your preferences and login data to provide faster and more personalized navigation.
  • Analyzing Web Traffic: We use cookies to collect anonymous information about user behavior and improve our services based on the data obtained.
  • Personalized Advertising: Third-party cookies allow us to offer you ads tailored to your interests when browsing other websites or using our applications.

5. Third-Party Cookies

In some sections of our site, we use cookies provided by third parties. These cookies may be used for:

  • Analyzing site performance and usage.
  • Delivering personalized advertising.
  • Connecting with social networks (e.g., if you use a "share" button on our page).

These third parties are subject to their own privacy and cookie policies, so we recommend reviewing them for more information.

6. How to Control or Delete Cookies

You can decide at any time about the use of cookies on our website. You can do this by configuring your browser to reject some or all cookies or to delete cookies that have already been stored. Below are links with instructions for managing cookies in the main browsers:

  • Google Chrome
  • Mozilla Firefox
  • Microsoft Edge
  • Safari

Please note that if you choose to block or disable some cookies, certain functionalities of our website may not be available, or your user experience may be affected.

7. Data Retention

Cookies do not store personal data such as name, address, or payment details. However, when personal data is collected through cookies, the provisions of our Privacy Policy apply. We will retain the information obtained through cookies only for as long as necessary for the purposes mentioned above.

8. Updates to this Cookie Policy

DIRECTO reserves the right to update this policy at any time. We recommend that you review this policy regularly to stay informed of any changes. The date of the last update is at the beginning of this document.

9. Contact

If you have any questions or concerns about our Cookie Policy, you can contact us through the following means: