PRIVACY NOTICE

COMPREHENSIVE PRIVACY NOTICE

In accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter, the “Law”), this Privacy Notice is made available to you in order to inform you of the information that will be collected and the treatment that will be given to the data you provide us, as well as the mechanisms available to you to exercise your rights of access, rectification, cancellation, or opposition to said treatment:

1. Identity and address of the Controller

VINTE VIVIENDAS INTEGRALES S.A.B de C.V. (hereinafter, “CONTROLLER”), with address located at Avenida Vía Real Manzana 16 Lote 1 Local 1, Colonia Real del Sol, Tecámac, State of Mexico, C.P. 55767, is the legal entity responsible for collecting, using, and protecting your personal data.

1. Processing of personal data

In order to fulfill the purposes set forth in this Privacy Notice, the CONTROLLER may collect the following information through digital, printed, audio, or any other technological means, as well as directly and/or in person:

Purposes of the processing of your personal and patrimonial data

The CONTROLLER will process the aforementioned data solely and exclusively for the following primary purposes:

• Register and verify your identity.
• Provide you with better personalized service.
• Address requests, inquiries, questions, suggestions, complaints, and reports.
• Provide you with information about a company belonging to the same group as
• the controller.
• Fulfill obligations undertaken with you.
• Request that you update your data and/or identification documents.
• Send you information about our products.
• Comply with the terms and conditions established with you.

Additionally, and for the purpose of providing you with better service, the CONTROLLER will use your personal data for the following secondary purposes:

• Quality evaluation and follow-up.
• Inform and invite you to learn about new developments, products, services, and promotions.
• Sending of newsletters, event invitations, and news.
• Communication of personalized promotions.
• Internal and external disclosure for the fulfillment of its corporate purpose.

Transfer of personal data

For the stated purposes, the CONTROLLER may transfer your personal data to “Processors” under the terms of the Law, as well as to Mexican or foreign third parties on which it relies for its operation, including subsidiaries, affiliates, parent companies, related companies, co-owners, and/or business partners; to third parties in the real estate and construction sectors, subdivision administrators, service providers; housing credit institutions; notaries; appraisers; civil associations or boards of directors formed in the housing developments.

II.3. Sensitive personal data for which express consent is required, purposes, and transfers

The CONTROLLER may request information related to your health status, in order to provide you with better service. With respect to this data, you authorize the CONTROLLER to process the information provided, as well as to transfer it to third parties on which it relies for the purposes described above.

The CONTROLLER may use images of minors from third-party databases under a usage license; such images are used for advertising and commercial prospecting purposes. It is clarified that the CONTROLLER does not collect, store, or transfer such images, nor any other personal data of minors, to third parties.

• Options provided to you to limit the use or disclosure of your data

As an alternative to limit the scope of the processing of your data, you may register in the Public Registry to Avoid Advertising (REPEP), an agency under the Federal Consumer Protection Agency (PROFECO). For more information about this registry, you may consult PROFECO’s website or contact it directly.

1. Access, rectification, or cancellation of your personal data or opposition to its use

As the owner of the personal data, you have the right to access, rectify, cancel, or object to the processing of your personal data (hereinafter, “ARCO Rights”), in accordance with the following:

• Access: the manner in which you prefer access to be provided;
• Rectification: the modifications requested and, where applicable, the documents and/or evidence necessary to support them;
• Cancellation: the reasons that motivate the request to delete the personal data; and
• Opposition: the situation that leads to requesting that the processing of personal data be concluded, as well as the harm that would be caused by continuing with it, or indicating the specific purposes for which you request that the processing be concluded.

To exercise your ARCO Rights, you must submit a request, which you may download here, addressed to the Privacy Officer, at the following email address: derechosarco@grupovinte.com

We inform you that the exercise of ARCO Rights will be free of charge, but if you reiterate your request within a period of less than 12 (twelve) months, it will have the cost defined by the Law, unless there are substantial modifications to the Privacy Notice that warrant new ARCO requests. You must cover the justified shipping costs or the cost of reproduction in copies or other formats and, where applicable, the cost of document certification.

1. Means to revoke consent for the processing of personal data.

It is important for you to know that you may revoke your consent for the processing of your personal data in the same manner in which you granted your consent. Thus, if you request a confirmation of your request, the CONTROLLER, through the Privacy Officer, will respond to you expressly, terminating the existing legal relationship with the CONTROLLER.

The response process will be as follows:

The Privacy Officer will respond to your ARCO request and the reasons for its decision via email within a maximum period of 20 (twenty) business days from the day your ARCO request was received. If the ARCO request is answered affirmatively or favorably, the requested changes will be made within a maximum period of 15 (fifteen) business days. The CONTROLLER may notify you, within the periods referred to in this paragraph, of an extension thereof, on a single occasion, for a period equal to the original.

The CONTROLLER may deny access for you to exercise your ARCO rights, in the cases permitted by the Law, in which case it must inform you of the reason for such decision. Such denial may be partial, in which case the CONTROLLER will carry out your ARCO Rights to the applicable extent.

1. Use of tracking technologies on the CONTROLLER’s website

On our website we use tracking technologies such as cookies, web beacons, and web analytics tools, including Google Analytics, through which it is possible to monitor your visits as an internet user, provide you with better service and user experiences while browsing our website, as well as offer you, through promotional banners, new products and services based on your preferences. The data that may be obtained through these technologies includes, by way of example but not limitation: IP address, browser type and language, browsing times and schedules, sections consulted, website addresses, and other information related to the user’s interaction with the website. Likewise, the CONTROLLER’s portal has links to other external sites, for whose content and privacy policies it is not responsible. The personal data obtained through these technologies may be shared with Mexican or foreign third parties on which the CONTROLLER relies for its operation, as well as its subsidiaries, affiliates, and parent company.

For more information, a Cookie is a data file that is stored on the hard drive of a user’s computer equipment or electronic communication device while browsing the internet, which allows information to be exchanged between said site and the user’s browser. That information may reveal session identification means, authentication, or user preferences, as well as any data stored by the browser regarding the website. A web beacon is a visible or hidden image on a website or in an email, used to monitor users’ behavior through such means.

And Google Analytics is a web tool used to obtain statistical data on the viewing and interaction of users with the CONTROLLER’s website.

• Video surveillance

When you visit any of our business units or sales areas, you may be video-recorded, exclusively for security reasons. The captured images and sounds are retained in storage for a specified period.

• Changes to the Privacy Notice

This Privacy Notice may undergo changes or updates arising from new legal requirements; from the CONTROLLER’s own needs; or from changes in its business model, with the understanding that any modification thereto will be made known to you through the publication of this notice on the CONTROLLER’s website, so we recommend that you check it frequently.

As part of the CONTROLLER’s concern for the proper use of your data, in the possible event of a security breach at any stage of the processing of personal data that significantly affects your patrimonial or moral rights, the Privacy Officer will immediately communicate, on the CONTROLLER’s website, the occurrence of the security breach, so that you may take the necessary corresponding measures to defend your rights.

1. Protection mechanisms

We have internal controls in the handling of information and security measures, including tools to encrypt and authenticate information that keep your personal information safe. Your personal data is processed through secure network systems, and only a limited number of people with special rights may access such information, who are required to keep such information confidential.

If you consider that your right to the protection of your personal data has been harmed by any conduct or omission on our part, we suggest you visit the official website, https://www.gob.mx/buengobierno.

IF THE DATA OWNER DOES NOT AGREE WITH THE PROCESSING UNDER THIS NOTICE, THEY MUST STATE SO THROUGH THE MECHANISMS PROVIDED HEREIN AND NOT PROVIDE THEIR DATA.

INMOBILIARIA VINTE reserves the right to change, modify, complement and/or alter this notice, at any time, in which case it will be made known on the website www.vinte.com.mx in the Privacy Notice section.

SINCERELY

INMOBILIARIA VINTE