In order to comply with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties, its Regulations and Applicable Guidelines (the "Law"), NAOUI SOFTWARE LABS, S. DE R.L C.V. its affiliates and / or subsidiaries, and / or its related parties ("ICALIA"), with address in Monterrey, Nuevo León (the "Address"), Website www.icalialabs.com (the "Site"), and email +++ (the "E-mail"), makes this available to you:


PRICACY POLICY,


In order to give a legitimate, controlled and informed treatment to your personal data, which you currently provide us or in the future work in our databases, or that have been collected by cookies, or any other web tracking technology, as well as , guarantee your privacy and your right to informative self-determination when providing us with said data, being ICALIA responsible for the use and protection of your personal data which will be treated based on the principles of legality, consent, information, quality, purpose, loyalty, proportionality and liability provided for in the Law.


USE OF THE INFORMATION.

The information that you provide us through access, registration and creation of a User profile on the Site, and / or email, and / or filling out forms or physical or electronic surveys, in real time or history, will be processed and ordered. , to generate data indicators, which ICALIA may use to make decisions relevant to its business, under its own analysis and responsibility. All the information that is collected will be used for statistical purposes in a generic and non-personalized way, associated with the growth, maintenance and administration of ICALIA, respecting your privacy at all times. These uses include our internal operations and administration, communication with you and the fulfillment of requests for services and / or products provided by ICALIA, as well as to improve, develop, perfect and provide ICALIA services, through its subsidiaries. , or authorized suppliers and / or business partners, establishing the appropriate measures in order to limit the use of the information collected from you, only for legal purposes and authorized in accordance with this Notice, as well as with the appropriate confidentiality and security measures.


ICALIA may also collect your IP (Internet Protocol) address to help diagnose problems with the ICALIA server, and to administer the Site. An IP address is a number that is assigned to your computer when you use the Internet. Your IP address is also used to help identify you within a particular session and to collect general demographic information. ICALIA may make use of "push" technology through the application that ICALIA uses to send notifications with the prior authorization of the user, this means of communication does not have any type of access to other functions or information of the equipment with which it connects to the Site . The information may include the URL they come from (whether or not they are on the Site), which URL they access next (whether or not they are on the Site), which browser they are using, as well as the pages visited, the searches carried out, the publications, commercial preferences, messages, etc.


USE OF COOKIES.

ICALIA informs you that through the use of cookies and similar technologies, it seeks to guarantee the best possible experience on the Site by providing you with personalized information, remembering your service and marketing preferences, and helping you obtain the appropriate information. In the event that you require more information regarding the use of cookies and similar technologies, ICALIA makes the Cookie Use Policy available to you.


  1. PERSONAL DATA REQUESTED

ICALIA, and / or its controlling companies and / or affiliated and / or subsidiary companies and / or related parties and / or those third parties that, due to the nature of their work or functions, have the need to process and / or use your data personal data ("Related Third Parties"), requests and obtains personal data in general, as well as personal data considered sensitive by the Law (hereinafter "General Personal Data" and "Sensitive Personal Data", respectively; and jointly referred to as the "Personal Data") of the people hereinafter described.


Sensitive Personal Data may be requested by electronic or physical means, with the understanding that all information provided in physical form will be considered and treated as if it had been provided and authorized on the Site, and for which it will be governed by this document.


In all cases, the collection of Personal Data by ICALIA is carried out in good faith and for the purposes set forth herein; For this reason, it is presumed that the data provided by its owners are true and complete, so they are the responsibility of the owner who provides them.


  1. EMPLOYEES AND CANDIDATES. The Personal Data that will be collected from employees and candidates are necessary to document the employment relationship that exists or may exist with each of them. The Personal Data that you will provide voluntarily and freely to ICALIA, consist of personal information that is included or may be included in contracts, letters, formats, lists, databases or other physical and / or electronic means, as appropriate, for the purposes of ICALIA can document its relationship with the company, the selection and recruitment process that it has had or will have, can keep an adequate record of the employment relationship with its employees and comply with internal policies, procedures and other legal obligations applicable to the company.


The General Personal Data that will be requested are the following: full name; home and / or mobile phone number; email; Federal Taxpayers Registry Code (RFC) and copy of Tax Identification Card; Opinion on compliance with tax obligations; Unique Population Registry Code (CURP) and proof copy; copy of official photo identification (voting credential or passport); age; place and date of birth; copy of birth certificate; address and copy of proof of address; copy of released military record (if applicable); marital status and copy of the marriage certificate (if applicable); nationality and copy of immigration document (if applicable); social security number and copy of the credential of the Mexican Social Security Institute (“IMSS”); current profession and occupation; education certificates or transcripts; certificates or proof of language proficiency; employee number; employee category and position; salary, earnings and deductions; copy of the certificate of registration, withdrawal or modification of salary from the IMSS; copy of the proof of earnings of the last job; Photographs; data of direct relatives and personal and / or work references; contact details in case of emergency; information related to beneficiaries or economic dependents, which may include full name, date of birth and other identification data, such as copies of the birth certificates of economic dependents; Curriculum vitae; information regarding employee performance; proof of previous employment; copy of proof of affiliation to AFORE; copy of proof of mortgage loans (INFONAVIT); Letters of recommendation and / or any other documentation or information related to the employment relationship that exists or will exist between ICALIA and you as a worker of the same.


  1. SUPPLIERS AND CLIENTS. The Personal Data that will be collected from ICALIA suppliers and clients are necessary to document the legal relationship that exists with each of them. The Personal Data that you will provide voluntarily and freely to ICALIA consist of personal information that is included or may be included in the ICALIA Database, as appropriate, so that ICALIA can keep an adequate record of its relationship with its suppliers and clients and comply with internal policies, procedures and other applicable legal obligations.


The General Personal Data that will be requested from you as individuals or representatives or proxies of the Company related to ICALIA are the following: full name, nationality, age, place and date of birth, address, home and / or mobile phone number, email electronic, marital status, profession, Federal Taxpayer Registry Code (RFC), Unique Population Registry Code (CURP) mainly. In the event that Suppliers and / or Clients are legal entities, the General Personal Data that will be requested are, company name, commercial name, registered office, social nationality, Company incorporation data and all changes or reforms made to the same, data of the act where the granting of powers of the representatives or legal proxies is recorded, and all those that it considers necessary for its commercial relationship.



2. PURPOSES OF THE PROCESSING OF PERSONAL DATA

The Personal Data provided to ICALIA will be used as explained below. In all cases, once the purposes of processing your Personal Data have been fulfilled, and when there is no legal provision that establishes otherwise, ICALIA will proceed to cancel, eliminate and / or destroy the Personal Data received, under the terms established by the law.


  1. WORKERS. Purposes that are necessary for the existence, maintenance and fulfillment of your employment relationship with ICALIA, which are but not limited to the following: (i) comply with the obligations arising from the employment relationship with you; (ii) carry out adequate personnel administration; (iii) create employee files; (iv) create medical records; (v) payroll payment and administration; (vi) payment of benefits, salaries and benefits, bonuses, reimbursements, pensions, insurance and others; (vii) contracting insurance; (viii) document and control the allocation of computer and communications equipment; (ix) internal audits; (x) creation of work email account; (xi) preparation of the company's directory; (xii) assign work tools; (xiii) assign keys and passwords; (xiv) ensure compliance with confidentiality obligations and other labor obligations; (xv) verify personal and work references; (xvi) contact their family members, economic dependents and / or beneficiaries in case of emergency.


  1. CANDIDATES. Purposes that give rise to and are necessary for the ICALIA job selection and recruitment process, which are, but not limited to, the following: (i) to process your job application; (ii) consult the information in publicly accessible sources; (iii) verify the veracity of the information provided; (iv) conduct labor investigations; (v) conduct socioeconomic research; (vi) identify, locate, contact and report on the development of the selection and recruitment process; (vii) prepare an economic proposal, if applicable; (viii) create your employment record, if hired; and (ix) maintain the security of our facilities during the interview process.


  1. CLIENTS AND SUPPLIERS. Purposes that are necessary for the existence, maintenance and fulfillment of its legal relationship of supply with ICALIA: (i) register or grant the necessary information as an authorized supplier or client of ICALIA; (ii) verify the veracity of the information provided; (iii) maintain the security of our facilities; (iv) know the service needs that may be required or provided, (v) the nature and functionalities of the products that it provides or may need and; (vi) everything that emerges from the present or future commercial relationship that solidifies between the Provider and / or the Client and ICALIA.


In all cases, once the purposes of processing your Personal Data have been fulfilled, and when there is no legal provision that establishes otherwise, ICALIA will proceed to cancel, eliminate and / or destroy the Personal Data received, under the terms established by the law.



3.   TRANSFERENCE


TRANSFER OF INFORMATION.
The data referred to in this Notice may be transferred to (i) Related Third Parties, in order to enhance ICALIA's business proposal, as well as offer other products and services based on your needs; (ii) any third party with whom ICALIA, and / or Related Third Parties and / or Business Partners have entered into a contract with the purpose of offering and promoting products and / or services of said third party through the Site; (iii) to judicial authorities, Mexican and foreign, in order to comply with the law, notifications, requirements or judicial offices; (iv) to internet service providers on which ICALIA's technological infrastructure is mounted.
In the event of any transfer of your data, in which your express consent is required, we will inform you in order to collect it.


TRANSFERS OF PERSONAL DATA.
As part of the operations of the business and in order to fulfill the purposes described, ICALIA may share with third parties, nationals or foreigners, some or all of your Personal Data, in accordance with the following:



  1. WORKERS AND CANDIDATES. These third parties may be parent companies, related parties, affiliates and / or subsidiaries of ICALIA; authorities; banking institutions; external professional advisers; or other service providers that offer payroll administration, training and personnel training; health services, medical diagnosis or treatment; administration, training or formation of human resources; provision of insurance and other benefits; cost planning; technical and information technology support and, in general, any third party that acts as manager on behalf of and on behalf of ICALIA.


In the same way, ICALIA may share with third parties, nationals or foreigners, some or all of your Personal Data when they are requested as employment and / or personal references for the processing of all types of credits, leases, purchase and sale of articles, real estate and / or any other commercial activity that you carry out, as well as for employment references for future hiring. Likewise, ICALIA may transfer your Personal Data to third parties, nationals or foreigners, when said data communication is provided for in a law or Treaty to which Mexico is a party, or when required by court order or resolution of a competent authority.

These third parties may be authorities, parent company, subsidiaries, affiliates and / or companies that provide services to ICALIA, in order to comply with existing legal obligations; comply with a legal or court order; and as long as it is necessary for the ordinary operation and functioning of ICALIA in accordance with its internal selection and recruitment policies and procedures. Personal Data may also be transferred by ICALIA to third parties that provide medical examination application services to the company, in order to manage and administer these services on behalf of and for the benefit of you as the owner of the data for purposes derived from their possible hiring as a company employee.


  1. SUPPLIERS AND / OR CLIENTS. These third parties may be authorities, parent company, related parties, subsidiaries, affiliates and / or subsidiaries that provide services to ICALIA, in order to comply with existing legal obligations; comply with a legal or court order; and as long as it is necessary for the ordinary operation and functioning of ICALIA in accordance with its internal policies and procedures with suppliers and / or clients of ICALIA.


In all cases, ICALIA will communicate this Privacy Notice to these third parties and will ensure through the signing of agreements and / or the adoption of other binding documents, that said third parties maintain the administrative, technical and physical security measures necessary to safeguard your Personal Data, as well as that said third parties only use your Personal Data for the purposes for which they were collected.
Likewise, both ICALIA, as the person responsible for collecting Personal Data, as well as any other person related to ICALIA who has access to the information contained in this Privacy Notice, will be obliged to protect it under the same security and confidentiality rules, and not to reveal it or misuse it, or otherwise they will be responsible in accordance with applicable laws.
Notwithstanding the foregoing, ICALIA will not transfer your Personal Data to third parties not related to ICALIA, except in the aforementioned cases and those provided by Law, without your prior consent.


4. MEANS AND PROCEDURES FOR THE EXERCISE OF ARCO RIGHTS

You, as the owner of the Personal Data provided to ICALIA, may request at any time, the exercise of your rights of access, rectification, cancellation or opposition (the "ARCO Rights") to the processing of your Personal Data, consisting of: (i ) access your Personal Data and the details of their treatment; (ii) rectify your Personal Data if it is inaccurate or incomplete; (iii) cancel your Personal Data when you consider that they are not required for any of the purposes indicated in this Privacy Notice, are being used for non-consensual purposes or your contractual or service relationship or any other with ICALIA has ended; and (iv) oppose the processing of your Personal Data for specific purposes.
For this purpose, you must submit your request in writing to the ICALIA Human Resources Department located at the Domicile, or send your request to the Email addressed to the person in charge of the Personal Data Department, as applicable, which must contain as at least the following information: (a) your full name and address, or another suitable means to communicate the response to your request; (b) the documents that prove your identity or, where appropriate, that of your legal representative; (c) the clear and precise description of the Personal Data with respect to which one seeks to exercise any of the aforementioned rights; and (d) any other element or information that facilitates the location of the Personal Data, as well as any other document required by current regulation at the time of submitting the request. You may also request more information from the Human Resources Department or the aforementioned Email on the procedure to exercise your ARCO Rights.


The response to your request will be made known to you by ICALIA in the terms and deadlines established in the Law. However, you will be able to obtain more information about the status of your request and the response time of the same, by contacting the Department of Human Resources or by sending your request to the Email, where you can also attend to any clarification or doubt you may have regarding the processing of your Personal Data and the exercise of your ARCO Rights.



5. REVOCATION OF CONSENT; LIMITATION OF USE AND DISCLOSURE OF PERSONAL DATA  

ou may also revoke, at any time, the consent that you have given ICALIA for the processing of your Personal Data, as well as request that the use and disclosure thereof be limited, as long as a legal provision does not prevent it. For this purpose, you must submit your request in writing to the ICALIA Human Resources Department located at the Domicile, or send your request to the Email - with attention to the person in charge of the Personal Data Department, as applicable. Said request must meet the same requirements mentioned in Section 4. above.

The response to your request will be made known to you by ICALIA in the terms and deadlines established in the Law. However, you will be able to obtain more information about the status of your request and the response time of the same, by contacting the Department of Human Resources or by sending your request to the Email, where you can also answer any clarification or doubt you may have regarding the treatment and these rights that correspond to your Personal Data.


In the event that your Personal Data had been sent prior to the date of revocation of consent and they continue to be processed by managers, ICALIA will inform the latter of said revocation, so that they proceed to carry out the necessary action.


6. CHANGES TO PRIVACY pOLICY

ICALIA reserves the right to modify and / or update this Privacy Notice in any or all of its parts at its sole discretion, in which case it will communicate it right here through its Site; and, depending on the particular case of each owner, through their internal networks, or by means of a notice that will be placed in the usual means (physical or electronic) of communication of ICALIA and in a visible place of the Domicile, or through a written notice addressed to your email, as legally required.


7. DIGITAL, ELECTRONIC OR ONLINE FORM

The Parties agree that the form to perfect the agreement of wills between them may be the Digital, Electronic or Online format, where it will be enough to express their will by means of their acceptance, as well as provide personal data , on the ICALIA Website itself without requiring the signature on any document.

Last modification date: August 30, 2019.