PRIVACY NOTICE

Chapter I: Introduction, Purpose, and Scope of the Policy

Purpose of the Privacy Policy:
This Privacy Policy aims to inform clients and potential clients, as well as users of this website—particularly those involved in the maritime sector, such as cargo consignees, shipowners, freight forwarders, among others—about the principles, policies, and procedures that Representaciones Marítimas, S.A. de C.V., along with all related companies within its commercial group, follows for the collection, use, storage, processing, transfer, and protection of their personal data, in accordance with the applicable provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (hereinafter “LFPDPPP” or the “Law”) and its Regulations.

Scope of Application:
This policy applies to all personal data processed by Representaciones Marítimas, S.A. de C.V. in the course of its business and operational activities, including but not limited to vessel consignment, port operation management, customs clearance, and the provision of maritime transport and logistics services, both nationally and internationally.

Legal Basis and Governing Principles:
Representaciones Marítimas, S.A. de C.V. adheres to the principles of lawfulness, consent, information, quality, purpose, loyalty, proportionality, and responsibility established by the Law. This policy also complies with specific regulations applicable to the Mexican maritime sector, ensuring that the processing of personal data is conducted responsibly and securely.

Commitment to Compliance:
Representaciones Marítimas, S.A. de C.V. is committed to protecting its clients’ personal data by implementing the necessary technical, organizational, and legal measures to comply with applicable legislation. Any personal data processing will be carried out in accordance with this policy and the applicable legal framework.

Chapter II: Definitions of Terms and Key Concepts

Definitions of Personal Data and Data Controllers:

• Personal Data: Any information relating to an identified or identifiable natural person, such as full name, address, email, telephone number, banking information, tax identification information, among others.
• Sensitive Personal Data: Information that affects the most intimate sphere of its owner or whose improper use could lead to discrimination or a serious risk to them.
• Data Controller: A natural or legal person (in this case, Representaciones Marítimas, S.A. de C.V.) who decides on the processing of personal data.
• Data Processor: A natural or legal person who processes personal data on behalf of the Data Controller. In this case, the Legal Department is the Data Processor for Representaciones Marítimas, S.A. de C.V.
• Data Transfer: Any communication of data made to a party other than the Data Controller or Data Processor.
• User: A natural person who, on their own behalf or on behalf of another individual or legal entity, browses the Representaciones Marítimas, S.A. de C.V. website.

Chapter III: Collection, Use, Storage, and Transfer of Personal Data

Types of Data Collected:
Representaciones Marítimas, S.A. de C.V. will collect and process, in accordance with the purposes set forth herein, the following types of personal data:

• Personal Identification Information: Full name, official identification number, address, email, telephone number.
• Financial and Transactional Data: Banking details, account numbers, billing information, payment history.
• Legal and Contractual Information: Contracts, service agreements, purchase orders, customs documentation.
• Operational Information: Cargo details, shipping manifests, customs clearance documents, among others related to port and maritime transport operations.

Purposes for Processing Personal Data:

• Provision of Shipping Agency Services: Management of vessel dispatch operations, cargo loading and unloading, and other port services.
• Compliance with Legal Obligations: Satisfaction of regulatory requirements imposed by maritime, customs, and tax authorities.
• Commercial Relationship Management: Promotion of company services, customer service, and market research.
• Operational Security and Control: Identity verification of clients, fraud prevention, and compliance with internal security policies.

Data Storage:
Personal data will be securely stored in databases for the necessary period to fulfill the purposes outlined herein and in accordance with applicable laws.
Data will be securely deleted once they are no longer required for the specific purposes for which they were collected, following internal data retention and deletion policies.

Data Transfers to Third Parties:
Representaciones Marítimas, S.A. de C.V. may transfer personal data to third parties such as customs agents, port authorities, logistics service providers, insurers, and other stakeholders in the maritime sector as necessary to fulfill contractual and legal obligations.
Data transfers to third parties will always be carried out with the data subject’s consent, except in cases where the Law permits such transfers without consent.

Chapter IV: Rights of Data Subjects and Procedure for Their Exercise

ARCO Rights (Access, Rectification, Cancellation, and Opposition):
Data subjects have the right to access their personal data, request its rectification, request its cancellation, or object to its processing in accordance with applicable legal provisions.

• Access: To know what personal data Representaciones Marítimas, S.A. de C.V. holds about them.
• Rectification: To request correction of their data if it is incorrect or outdated.
• Cancellation: To request deletion of their data when it is no longer necessary for the purposes collected.
• Opposition: To object to the processing of their personal data for specific purposes, such as direct marketing.

Procedure to Exercise ARCO Rights:
To exercise these rights, the data subject must submit a written request to the Data Protection Department at Representaciones Marítimas, S.A. de C.V. by emailing privacidad@maritimex.com.mx or by submitting the request directly at our offices located at Frontera 67, Colonia Tizapán, Alcaldía Álvaro Obregón, C.P. 01090, Mexico City, Mexico.

The request must include: full name of the data subject, copy of official identification, a clear and precise description of the data and the right they wish to exercise, and any other document that facilitates the location of the data.

Representaciones Marítimas, S.A. de C.V. will respond to the request within a maximum of 20 business days, informing the data subject of the decision adopted.

Chapter V: Security Measures, Internal Control, and Incident Notification

Security Measures Implemented:

• Administrative Measures: Ongoing staff training, internal data management policies, confidentiality agreements.
• Technical Measures: Data encryption, authentication systems, firewalls, and intrusion detection systems.
• Physical Measures: Access control to facilities, secure storage of documents, surveillance systems.

Internal Control and Confidentiality:
All personnel of Representaciones Marítimas, S.A. de C.V. and any third parties with access to personal data are obligated to maintain confidentiality regarding such data, even after the termination of their employment or contractual relationship.

Notification of Security Incidents:
In the event of a security breach affecting personal data, Representaciones Marítimas, S.A. de C.V. will notify the data subject within 72 hours of detecting the incident, detailing the nature of the breach, the compromised data, and the measures taken to mitigate the impact.

Chapter VI: Modifications to the Privacy Policy and Communication to Data Subjects

Updating and Modifying the Policy:
This policy may be modified by Representaciones Marítimas, S.A. de C.V. at any time. Modifications will be communicated to data subjects through the company’s website and, when necessary, through direct communication.

Acceptance of the Privacy Policy:
The use of services provided by Representaciones Marítimas, S.A. de C.V. implies acceptance of this Privacy Policy. Data subjects are encouraged to review this policy periodically to stay informed of any changes or updates.

REPRESENTACIONES MARÍTIMAS, S.A. DE C.V.
September 2024