Privacy notice

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

SAT.ws ("SATWS"), indicating as address to hear and receive notifications the one located at, Calle Campeche, No. 429, Int. No. 6C, Col. Hipódromo Condesa, Alcaldía Cuauhtémoc, C.P. 06170, CDMX, México, we know how important is for you the protection of the Personal Data you share with us. The purpose of this Notice is to inform you of any operation or set of operations, whether or not automated procedures, such as the collection, recording, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other type of enabling access, matching or interconnection, limitation, deletion or destruction ("Processing") of your Personal Data.

At all times, you are the sole Owner of the Personal Data you provide to us. By accepting this Notice, we act as "Responsible" for the processing of your Personal Data and we undertake only to collect and use them as provided in this Notice and only for the purposes you have authorized as provided herein.

this Notice and only 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 states that it has the proper authorizations and has made known to its customers/users the corresponding notice of conformity in accordance with the Law on Protection of Personal Data Held by Private Parties and its Regulations (the "Law"). In this sense, SATWS does not collect personal data from the customers/users of the Users; therefore, in the event that the User provides such data, SATWS shall be considered as ("Entrusted" as defined in the Law) and the User as ("Responsible" as defined in the Law).

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

What personal data do we collect?

SATWS collects your Personal Data only to the extent that you provide it to us. By accepting this Notice and providing us with your Personal Data you are expressing your consent to the Processing of your Personal Data as provided herein.

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

You may revoke your consent to this Notice at any time in accordance with the provisions of the Section entitled "MECHANISM AND PROCEDURE FOR REVOCATION OF CONSENT".

SATWS has the appropriate technical, administrative and organizational security measures in place to ensure 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) ability to ensure the ongoing confidentiality, integrity, availability and resilience of the Processing systems and services, (iii) ability to restore availability and access to Personal Data promptly in the event of a physical or technical incident, (iv) a process of regular verification, evaluation and assessment of the effectiveness of the technical and organizational measures to ensure the security of the Processing. However, in the event that we have any breach of our security, we will notify you as soon as we become aware of such breach, when it significantly affects your economic or moral rights, so that you can take appropriate measures to defend your rights.

Sensitive personal data to be processed

Sensitive personal data are those that affect the most intimate sphere of the Data Subject, or whose improper use may give rise to discrimination or entail a great risk to the Data Subject. In particular, sensitive personal data are considered those 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 ("Sensitive Personal Data").

At SATWS, we do not use Sensitive Personal Data. If for any reason you provide us with any of this information, it will be used only to the extent that you have authorized and for the minimum time necessary.

Purposes of the treatment

a. Primary

SATWS collects your Personal Data for the following purposes: (i) identify and manage the registration of your account (the "User Account"), (ii) answer questions from our users, (iii) carry out the necessary steps for the formalization of contracts, (iv) processing, updating, modification, cancellation and/or confirmation of services, products, and information sent by SATWS to the Holders through the Platform, telephone calls and/or e-mail, (v) to comply with the obligations contracted by the Holder with SATWS, (vi) to respond to requests to exercise the cancellation of consent of Personal Data or Arco Rights of the Holders.

b. Secondary

Also, 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 to provide better service to the owners: (i) improving, perfecting, modifying, expanding and developing our services and/or products, (iii) developing new services and/or products, (iv) evaluating the quality of SATWS 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 Responsible for your Personal Data, we will ensure that they are relevant, correct and kept 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 the cancellation of the same.

Transfers of personal data to be carried out

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 Federal Law for the Protection of Personal Data in Possession of Individuals: (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 the prevention or medical diagnosis, the provision of healthcare, medical treatment or the management of healthcare services; (iii) when the transfer is made to holding companies, subsidiaries or affiliates under common control of the controller, or to a parent company or any company in the same group of the controller that operates under the same internal processes and policies; (iv) when the transfer is necessary by virtue of a contract entered into or to be entered into 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 safeguard 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 a judicial process, 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 Controller were to provide Personal Data of third parties, he/she expressly states that he/she has the express consent of his/her clients/users, as well as the corresponding privacy notice in accordance with the provisions of the Mexican legislation in force.

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

To limit the use or disclosure of your Personal Data, not to receive promotions of our products and / or services, you can make the free registration in our internal lists of exclusion, following the same procedure indicated in the section called "MEANS FOR THE EXERCISE OF THE ARCO RIGHTS" below of this Notice.

Means for the exercise of arch rights (access, rectification, cancellation or opposition)

At any time you may access, rectify, cancel or oppose the use of your personal data by sending your request to the following email privacidad@sat.ws, which corresponds to the department in charge of Personal Data within SATWS (the "Controller"). 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 proving your identity or legal representation of the Data Subject; (iii) a clear and precise description of the Personal Data with respect to which you wish to exercise your ARCO rights; (iv) any other document that facilitates the location of the Personal Data, and (v) in case of rectification, the documentation that supports your request.

We will notify you of the decision within 20 (twenty) business days after we receive the request so that if it is appropriate we can make it effective within 15 (fifteen) business days after we communicate such response. When circumstances so warrant, 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 to request that we transmit them, following the same procedure in the section "MEANS OF EXERCISE OF YOUR RIGHTS ARCO" above.

Where the limitation prevents the provision of a service you have contracted with us, Processing will continue as you have authorised until the service is completed.

Mechanisms and procedures for revocation of consent

At any time you can express your refusal to this Notice, by notifying the email privacidad@sat.ws, of the person in charge.

Use of web beacons cookies 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 on your device's browser to store certain information. When you revisit our Platform from the same device, the information stored in the cookies will be transmitted either to our Platform ("First Party Cookies") or to another website to which the cookie belongs ("Third Party Cookies").

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

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

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

Strictly necessary cookies (type A)

Strictly necessary cookies ensure functions without which you would not be able to use our website as intended. We will be the only ones to use these cookies, so they are our own cookies. This implies that all information stored in the cookies will be sent to our Platform.

Strictly necessary cookies serve, for example, to ensure that when you log in as a registered user, your session remains active when you access different sub-pages of our Platform, i.e. 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. Strictly necessary cookies can therefore not be individually activated or deactivated, although you can deactivate cookies in your browser at any time (see how to deactivate them below).

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

Functionality and performance cookies (type B)

Functionality cookies allow our Platform to store information you have already provided (such as registered user or language selection) in order to provide you with extended and more personalized features 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, content and functionality.

These cookies help us, for example, to determine whether and which sub-pages of our Platform are visited and what content users are particularly interested in. In particular, 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 the pages are accessed, as well as the proportion of mobile devices accessing our websites. We also capture movements, clicks and scrolling with the computer mouse to find out which areas of our Platform are of particular interest to users.

This allows us to tailor the content of our platform more specifically to the needs of our users and to optimize our offer. The IP address of your computer transmitted for technical reasons is automatically anonymised and does not allow us to draw any conclusions about the individual user.

To review and update your consent and final settings for the storage and use of cookies at any time, please read this Notice.

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

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

We also reserve the right to use information we have obtained through cookies derived from anonymous analysis of the usage behaviour of visitors to our Platform to display targeted advertising for some of our products on our websites. We believe this benefits you as a user by showing you advertising or content that we believe matches your interests based on your browsing behaviour, so that you see less random advertising or certain content that may be less interesting to you.

Type C cookies, which are those that come from external advertising companies (third party cookies) and are used to collect information about the websites that 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 set your browser to generally prevent cookies from being saved on your device and/or to ask you on each occasion whether you agree to allow the use of cookies. You can also delete cookies that have been re-activated at any time. To find out in detail how this procedure works, you can refer to the help function of your browser.

You should be aware that disabling cookies generally may cause functional restrictions on our Platform. However, you can block or disable them by activating the setting on your browser that allows you to refuse the installation of all cookies or some of them.

Most browsers allow you to be warned of the presence of cookies or to reject them automatically. If you reject them, you will still be able to use our Platform, although the use of some of your services may be limited and therefore your experience on our Platform less satisfactory.

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

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 you to change these settings. 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 the cookie store from other tools such as:

Your online choices

Ghostery

Website analysis

This Platform uses Google Analytics, a web analytics service provided by Google Inc ("Google"). Google Analytics uses a specific type of cookie that is stored on your computer and makes it possible to analyse your use of our Platform. The information generated by the cookie about your use of this Platform is usually transmitted to and stored on a Google server in the USA.

We would like to point out that Google Analytics has been integrated into this Platform to include the code "gat._anonymizeIp();" in order to ensure that the recording of IP addresses is done anonymously (so-called IP masking). Due to the IP anonymisation of this website, Google abbreviates 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 USA and shortened there in exceptional cases. Google is committed to respecting the EU-US 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 about the activities 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 in the event that 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 setting the appropriate settings using your browser software. In addition, you can prevent Google from recording the data related to your use of this Platform that generates the cookie (including your IP address) and from processing this 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 from time to time, and we will alert you of any changes by email. In order to continue using our services you must accept each update to our Notice.

Minors

SATWS does not collect Personal Data from children under the age of 18. If you are a minor and for some reason you provide us with this information, we will immediately cancel your personal data upon realizing it through our verification process.

If you believe that we may have Personal Information about a minor in our records, please contact us by sending an email to the following address privacidad@sat.ws.