Privacy Notice

Effective date: April 14, 2021

Personal data is the information relating to an identified or identifiable natural person (the "Data Subject"), such as, for example, name, identification number, location data, an online identifier, or one or more elements of the physical, physiological, genetic, mental, economic, cultural, or social identity of that person ("Personal Data").

At SAT.ws ("SATWS"), designating as our address for hearing and receiving notices the one located at Calle Campeche, No. 429, Int. No. 6C, Col. Hipódromo Condesa, Alcaldía Cuauhtémoc, C.P. 06170, CDMX, Mexico, we know how important the protection of the Personal Data you share with us is to you. The purpose of this Notice is to inform you of any operation or set of operations, whether automated procedures or not, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of enabling access, collation or interconnection, restriction, erasure or destruction ("Processing") of your Personal Data.

At all times, you are the sole Data Subject of the Personal Data you provide to us. By accepting this Notice, we act as "Controllers" of the Processing of your Personal Data and we undertake to collect and use it solely as set forth in this Notice and exclusively for the purposes you have authorized as provided herein.

If the User (as defined below), through the Platform (as defined below), were to provide personal data of third parties, then the User expressly represents that they have the required authorizations and have made the corresponding notice available to their clients/users in accordance with the Ley de Protección de Datos Personales en Posesión de Particulares and its Regulations (the "Law"). In this regard, SATWS does not collect personal data of the Users' clients/users; therefore, should the User provide such data, SATWS will be considered the ("Processor" as defined in the Law) and the User the ("Controller" as defined in the Law).

This Notice applies to any website, applications, and digital tools owned by SATWS (the "Platform"), regardless of the form and place of access.

What personal data do we collect?

At SATWS we collect your Personal Data only to the extent that you provide it to us. By accepting this Notice and providing us your Personal Data, you are expressing your consent to the Processing of your Personal Data as set forth herein.

To use our Platform you must have accepted our Terms and Conditions, have provided us information through a form, and have an account as a client ("User") of SATWS.

You may revoke your consent to this Notice at any time as provided in the Section entitled "MECHANISM AND PROCEDURE FOR REVOKING CONSENT".

At SATWS we have the appropriate technical, administrative, and organizational security measures in place to guarantee a level of security that protects your Personal Data against any: destruction, loss, accidental or unlawful alteration, and unauthorized communication or access, such as: (i) pseudonymization and encryption of personal data, (ii) the ability to ensure the ongoing confidentiality, integrity, availability, and resilience of Processing systems and services, (iii) the ability to restore the availability of and access to Personal Data quickly in the event of a physical or technical incident, (iv) a process for regularly verifying, assessing, and evaluating the effectiveness of the technical and organizational measures for ensuring the security of the Processing. However, in the event of a breach of our security, we will notify you immediately upon becoming aware of such breach, when it significantly affects your property or moral rights, so that you can take the corresponding measures in defense of your rights.

Sensitive personal data to be processed

Sensitive personal data is data that affects the most intimate sphere of its Data Subject, or whose misuse may give rise to discrimination or entail a serious risk for the Data Subject. In particular, data that may reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical, and moral beliefs, union membership, political opinions, or sexual preference is considered sensitive ("Sensitive Personal Data").

At SATWS, we do not use Sensitive Personal Data. If for any reason you were to provide us with any such data, it will be used exclusively to the extent you have authorized and for the minimum time indispensable.

Purposes of the processing

a. Primary

At SATWS we collect your Personal Data for the following purposes: (i) to identify and manage the registration of your account (the "User Account"), (ii) to answer our users' questions, (iii) to carry out the steps required for the formalization of contracts, (iv) processing, updating, modifying, canceling, and/or confirming the services, products, and information sent by SATWS to Data Subjects through the Platform, phone calls, and/or email, (v) to comply with the obligations undertaken by the Data Subject with SATWS, (vi) to respond to Data Subjects' requests to withdraw consent to Personal Data or to exercise ARCO Rights.

b. Secondary

Likewise, the Personal Data collected may be used for the following additional purposes that are not directly related to the services provided or products offered, but that help us give data subjects better service: (i) to improve, refine, modify, expand, and develop our services and/or products, (iii) to develop new services and/or products, (iv) quality assessment of SATWS's services and/or products, (ii) receiving news, offers, promotions, and information from SATWS, (iii) sending newsletters, as well as (iv) sending information for marketing, advertising, and commercial prospecting purposes.

As Controllers of your Personal Data, we will endeavor to keep it relevant, correct, and up to date. When your Personal Data is no longer necessary for the fulfillment of the purposes set forth in this Notice, as well as the applicable legal provisions, we will proceed to delete it.

Transfers of personal data

We undertake not to transfer your Personal Data to Third Parties without your prior consent, except for the exceptions provided in Article 37 of the Ley Federal de Protección de Datos Personales en Posesión de los Particulares: (i) when the transfer is provided for in a Law or Treaty to which Mexico is a party; (ii) when the transfer is necessary for medical prevention or diagnosis, the provision of healthcare, medical treatment, or the management of health services; (iii) when the transfer is made to holding companies, subsidiaries, or affiliates under the common control of the controller, or to a parent company or any company of the same group as the controller operating under the same internal processes and policies; (iv) when the transfer is necessary by virtue of a contract executed or to be executed in the interest of the Data Subject, by the Controller and a Third Party; (v) when the transfer is necessary or legally required for the safeguarding of a public interest, or for the procurement or administration of justice; (vi) when the transfer is necessary for the recognition, exercise, or defense of a right in judicial proceedings, and (vii) when the transfer is necessary for the maintenance or fulfillment of a legal relationship between the Controller and the Data Subject.

If the Data Subject were to provide Personal Data of third parties, they expressly represent that they have the express consent of their clients/users, as well as the corresponding privacy notice in accordance with the provisions of current Mexican legislation.

Options and means offered by the controller to data subjects to limit the use or disclosure of their personal data

To limit the use or disclosure of your Personal Data, or to stop receiving promotions of our products and/or services, you can register free of charge in our internal exclusion lists, following the same procedure indicated in the Section entitled "MEANS FOR EXERCISING ARCO RIGHTS" below in this Notice.

Means for exercising ARCO rights (access, rectification, cancellation, or objection)

At any time you may access, rectify, cancel, or object to the use of your personal data by sending your request to the following email address privacidad@sat.ws, which corresponds to the department in charge of Personal Data within SATWS (the "Processor"). Such request must contain the following: (i) name of the Data Subject and address or other means to communicate the response to your request; (ii) documents evidencing your identity or the legal representation of the Data Subject; (iii) a clear and precise description of the personal data with respect to which you wish to exercise the ARCO rights; (iv) any other document that facilitates locating the Personal Data, and (v) in the case of rectification, the documentation supporting your request.

We will inform you of the determination adopted within a maximum period of 20 (twenty) business days from receipt of the request so that, if it is found to be appropriate, we can implement it within 15 (fifteen) business days from the date we communicate such response. Where circumstances justify it, the aforementioned periods may be extended for equal periods.

Limitation and portability of your personal data

At any time you may limit the Processing of your Personal Data, as well as request that we transmit it, following the same procedure in the section "MEANS FOR EXERCISING ARCO RIGHTS" above.

When the limitation prevents the provision of a service you have contracted with us, the Processing will continue as you have authorized until the completion of the service.

Mechanisms and procedures for revoking consent

At any time you may express your objection to this Notice by notifying the Processor at the email address privacidad@sat.ws.

Use of cookies, web beacons, and other tracking technologies

In addition to the Personal Data mentioned in this Notice, cookies are stored on your computer when you visit and use our Platform.

Cookies are small text files that are stored in your device's browser to save certain information. When you visit our Platform again from the same device, the information saved in the cookies is transmitted either to our Platform ("First-Party Cookies") or to another website to which the cookie belongs ("Third-Party Cookies").

Through the information saved and sent to the Platform, we recognize that you have accessed the site and visited it with the browser you use on that device. We use this information to be able to design and display the Platform optimally according to your preferences. In this regard, only the cookie is identified on your device. Beyond this, your Personal Data will only be saved with your express consent or when strictly necessary in order to use the service offered to you and that you accordingly access.

Below we list the different types of cookies, whose scope and functionality we will explain further on:

• Strictly necessary cookies (type A)
• Functionality and performance cookies (type B)
• Cookies for marketing, advertising, and/or commercial prospecting purposes (e.g. marketing cookies) (type C)

Strictly necessary cookies (type A)

Strictly necessary cookies guarantee functions without which you could not use our website as intended. We will be the only ones using these cookies, so they are first-party cookies. This means that all the information stored in the cookies will be sent to our Platform.

Strictly necessary cookies serve, for example, to guarantee that when you log in as a registered user, your session remains active when you access different subpages of our Platform, that is, that you do not have to re-enter your login details each time you access a new page.

The use of strictly necessary cookies on our Platform is possible without your consent. For this reason, strictly necessary cookies cannot be activated or deactivated individually, although you can deactivate cookies in your browser at any time (see how to deactivate them a little further below).

Likewise, in this Notice you can find more information about the types of cookies configured and used in the tools implemented on our Platform.

Functionality and performance cookies (type B)

Functionality cookies allow our Platform to store information already provided (such as registered user or language selection) in order to offer you enhanced, more personalized functions based on this information. These cookies collect and store only anonymous information, so they cannot track your movements on other websites.

Performance cookies collect information about how our Platform is used in order to improve its attractiveness, its content, and its functionality.

These cookies help us, for example, to determine whether subpages of our Platform are visited and which ones, and in which content users are particularly interested. Specifically, we record the number of visits to a page, the number of subpages accessed, the time spent on our Platform, the order in which pages are visited, which search terms led you to us, the country, region, and, where applicable, the city from which access takes place, as well as the proportion of mobile devices accessing our websites. We also capture computer mouse movements, clicks, and scrolling to understand which areas of our Platform are of particular interest to users.

Thanks to this, we can tailor the content of our Platform more specifically to the needs of our users and optimize our offering. Your computer's IP address, transmitted for technical reasons, is automatically anonymized and does not allow us to draw any conclusions about the individual user.

To review and update your consent and final settings in the cookie storage and use system whenever you wish, continue reading this Notice.

Cookies for marketing, advertising, and/or commercial prospecting purposes (type C)

Cookies that are neither strictly necessary (type A) nor functionality or performance cookies (type B), e.g. marketing cookies.

We likewise reserve the right to use information we have obtained through cookies derived from an anonymous analysis of the usage behavior of visitors to our Platform in order to display specific advertising for some of our products on our websites. We believe this benefits you as a user, since we show you advertising or content that in our view matches your interests based on your browsing behavior, so that you see less random advertising or certain content that may be less interesting to you.

Type C cookies are those that come from external advertising companies (third-party cookies) and are used to collect information about the websites the user visits in order to generate relevant advertising based on their interests or those of other similar users.

Managing and deleting all cookies

You can configure your browser to generally prevent cookies from being saved on your device and/or to be asked each time whether you agree to allow the use of cookies. You can also delete cookies that have been reactivated at any time. To find out in detail how this procedure works, you can consult your browser's help function.

Please note that generally deactivating cookies may cause functional restrictions on our Platform. However, you can block or disable them by activating your browser settings that allow you to reject the installation of all or some cookies.

Most browsers make it possible to be warned of the presence of cookies or to reject them automatically. If you reject them, you can continue using our Platform, although the use of some of its services may be limited and, therefore, your experience on our Platform less satisfactory.

If you wish to withdraw your consent related to this Notice at any time, you must delete the cookies stored on your equipment (computer or mobile device) through your Internet browser's settings and configurations.

For more information on deleting, disabling, or blocking cookies, please visit: http://www.allaboutcookies.org/es/administrar-las-cookies

Unless you have adjusted your browser settings, our system will create cookies as soon as you visit our Platform. Please note that all Internet browsers allow this setting to be changed. For more information on how to adjust your cookie settings in the following browsers, we refer you to the relevant link:

Microsoft Edge

FireFox

Chrome

Safari

You can also manage cookie storage using other tools such as:

Your online choices

Ghostery

Website analytics

This Platform uses Google Analytics, a website analytics service of Google Inc. ("Google"). Google Analytics uses a specific type of cookie that is stored on your computer and enables the analysis of your use of our Platform. The information about your use of this Platform generated by the cookie is usually transmitted to a Google server in the U.S., where it is stored.

We wish to point out that Google Analytics has been integrated into this Platform so that it includes the code "gat._anonymizeIp();" in order to guarantee that IP addresses are recorded anonymously (so-called IP masking). Due to the IP anonymization on this website, Google shortens your IP address within the territory of the EU and the member states of the European Economic Area. The full IP address is only transmitted to a Google server in the U.S. to be shortened there in exceptional cases. Google has committed to respecting the EU-U.S. Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).

Google uses this information on our behalf to analyze your use of this Platform in order to compile reports on activity on the Platform and to provide additional services related to the use of websites and the Internet. Google may also transfer this information to third parties in accordance with the Law or where such third parties process this data on Google's behalf. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other Google data.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software. In addition, you can prevent Google from recording the data related to your use of this Platform generated by the cookie (including your IP address) and from processing such data by installing the browser plugin available for download at https://tools.google.com/dlpage/gaoptout?hl=es.

Procedure and means for communicating changes to the privacy notice

We are constantly trying to improve our services, so we reserve the right to change this Privacy Notice on occasion, and we will alert you to any change by email. In order to continue using our services you must accept each update to our Notice.

Minors

At SATWS we do not collect Personal Data from anyone under 18 years of age. If you are a minor and for some reason provide us with this information, upon becoming aware of it through our verification process we will proceed to immediately delete your personal data.

If you believe that Personal Data from a minor might be in our records, please contact us by email at the following address privacidad@sat.ws.