Client Privacy Notice

  1. Identity and Address of the Responsible Party.

In accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (the "Data Law"), its Regulations, and other applicable provisions, we inform you that Bluecomer, S. de R.L. de C.V. (the "Responsible Party"), with address at Circuito Plaza Esmeralda No. 19 local 205 Col. Rancho Viejo, Municipality of Atizapán de Zaragoza, State of Mexico, C.P. 52930 (the "Contact Address"), will treat your personal data under the terms of this privacy notice.

 

  1. Contact Details of the Responsible Party. 

The Responsible Party has designated a personal data manager (the "Privacy Officer"). Should you wish for any information regarding this privacy notice or in relation to the exercise of any of your rights derived from the processing of your personal data, please contact our Privacy Officer by sending an email to the following address: infoblue@bluecomer.com

 

  1. Personal Data to be Processed.

To achieve the purposes contained in this Notice, the Responsible Party may obtain and process the following personal data of the Holder: 

  1. Contact data. 

  2. Identification data.

  3. Location data. 

  4. Employment data. 

  5. Financial or patrimonial data. 

 

The Responsible Party also collects the full name and telephone number of the Holder's personal references, for the purpose of confirming the information provided by the Holder to the Responsible Party. The Responsible Party may collect your personal data personally, directly or indirectly, when you provide them, when using or requesting the products and/or services of the Responsible Party or when participating in promotions or contests sponsored by the Responsible Party, through the internet sites of the Responsible Party or other sources permitted by the Data Law. The Holder declares and accepts that they have the consent of those persons whose personal data they provide, on the understanding that said data will be governed by this privacy notice published at www.bluecomer.com.

 

Note: The Responsible Party will not process Sensitive Personal Data of the Holder.

 

  1. Purposes of the Processing of your Personal Data.

Your personal data will be processed for the following purposes:

  1. Necessary for the legal relationship between the Responsible Party and you (the "Holder"): 

  1. Attend to the request, analysis, and formalization of the leasing and/or credit services and products that the Holder has requested.

  2. Carry out all procedures related to the service(s) that the Responsible Party grants to the Holder (hereinafter the "Services"), including identification and knowledge of the Holder.

  3. Consult credit information companies regarding the Holder's credit history and information. 

  4. Estimate payment feasibility, using a quantitative and qualitative information analysis that allows establishing the Holder's creditworthiness and payment capacity.

  5. The identification, operation, and administration of the contracted Services.

  6. The prevention and/or detection of fraud or other illicit acts to the detriment of the Responsible Party and/or the Holder. 

  7. The contracting of insurance by the Responsible Party and/or in the name of the Holder that are mandatory and/or related to the Services and/or that are independent and/or additional to these. 

  8. Make inquiries, investigations, and/or reviews of the Holder's activities, operations, complaints, and/or claims related to the Services. 

  9. Comply with the obligations contracted with and by our clients. 

  10. Inform about changes related to the contracted Services.

  11. The extrajudicial and/or judicial collection of the Services to the Holder. 

  12. Compliance with applicable laws, regulations, and legal provisions.

  13. Generate reports or requirements to competent authorities that regulate the Responsible Party, including without limitation the applicable provisions on the prevention of money laundering.

 

  1. Not necessary for the legal relationship between the Responsible Party and the Holder: 

  1. Service quality measurement, statistics (including conducting internal studies on consumption habits), marketing, and/or reporting by the Responsible Party related to the Services and/or the Holder.

  2. Advertising, promotion, and/or telemarketing to the Holder, of the goods, products, and/or services offered by the Responsible Party or a third party, by any material and/or electronic means.

  3. Inform about new products and/or services.

 

  1. Options to Limit the Use or Disclosure of your Personal Data. 

In order for the Holder to limit the use or disclosure of their personal data so that they are not processed for purposes not necessary for the legal relationship with the Responsible Party, the Holder may register in the Public Registry of Users in accordance with the Law for the Protection and Defense of the User of Financial Services. This registry (REUS) allows the Holder to register in a database to restrict promotional calls to private numbers (landline or mobile), work, or email, seeking to maintain their privacy and avoid the inconveniences caused by these calls or sending of information. The Holder may register for REUS through the means established on the following Internet page: http://portalif.condusef.gob.mx/REUS/home.php

 

  1. Means to Exercise ARCO Rights  

The Holder may exercise at any time their rights of access, rectification, cancellation, or opposition to the processing we give to their personal data (the "ARCO Rights"). It is important to mention that the exercise of each of these rights is independent of each other, that is, it is not necessary to exhaust one to exercise any of the others.

Each of the rights respectively allows you to:

  1. Access: The Holder may request at any time to know what data of theirs has been collected and is kept by the Responsible Party in its databases, as well as the details of their processing.

  2. Rectification: In the event that any of your data is inaccurate or incomplete, you may request the Responsible Party to correct it in the databases, attaching the documentation that proves said modification.

  3. Cancellation: You may request the cancellation of your data from the databases held by the Responsible Party at any time when you consider that they are not required for the purposes indicated in this privacy notice, are being used for non-consented purposes, or our legal relationship has ended; if the request is appropriate, the data will be blocked and cannot be processed in any way.

  4. Opposition: At any time, the Holder may oppose the Responsible Party processing their data for specific purposes, for example, for sending advertising.

To exercise ARCO Rights, the Holder or their legal representative must prepare the "ARCO Rights Exercise Request" which can be requested at the email infoblue@bluecomer.com and must send it scanned, or present it at the Contact Address, to the attention of the Privacy Officer, for attention and follow-up.

For our Privacy Officer to follow up on your request, you or your legal representative must correctly prove your identity, for which it is necessary to complete all the fields indicated in the ARCO Rights Exercise Request and accompany it with a copy of one of the current official identifications indicated in it.

In the event that the information provided is erroneous or insufficient, or the corresponding accreditation documents are not attached, our Privacy Officer, within five (5) business days following receipt of the request, may require you to provide the elements or documents necessary to process it. You will have ten (10) business days to attend to the requirement, counted from the day following that in which you received it. If no response is given within said period, the corresponding request will be deemed not presented.

Our Privacy Officer will communicate the determination adopted to you within a maximum period of twenty (20) business days from the date the request was received, so that, if appropriate, it becomes effective within fifteen (15) business days after the response is communicated.

In case of exercising your right of access, the Privacy Officer will deliver your data through the email you indicate in the Request for the exercise of the Rights of the holders.

 

  1. Options to Limit the Use or Disclosure of your Personal Data. 

 

You may limit the use or disclosure of your personal data by sending your request to our Privacy Officer at the address: infoblue@bluecomer.com The requirements to prove your identity, as well as the procedure to attend to your request, will be governed by the same criteria indicated in the previous section. 

If your request is appropriate, our Privacy Officer will register it in the exclusion list owned by the Responsible Party. 

 

  1. Transfers of your Personal Data.

We inform you that, to comply with the purposes mentioned in this Notice, the Responsible Party may transfer the Holder's personal data without their consent: 

  1. To financial institutions and/or investors, to carry out the primary purposes established above, when the Responsible Party assigns, transmits, transfers, affects, encumbers and/or negotiates, in any way, the credit rights derived from the Services that are recorded in the respective credit contract or contracts that are entered into and/or, in the promissory note(s) that are signed under them, by the Holder (the "Credit Rights"), or when the Responsible Party enters into mergers and/or spin-offs in which said persons are involved. 

  2. To national or foreign third parties when the Responsible Party requires their support for the operation and/or administration of the Services. 

  3. To the holding company or to the subsidiaries, affiliates, or member companies of the same group as the Responsible Party that operate under the same internal policies on the protection of personal data; 

  4. To insurance companies for the contracting of insurance related to the Services.

  5. To the successors and/or beneficiaries of the contracted Services. 

  6. When the transfer is mandatory, necessary and/or convenient in relation to and/or with respect to the rights of the Services. 

  7. To any of the third parties that provide any related and/or connected product and/or service with the product(s) and/or service(s) requested from and/or offered by the Responsible Party, and/or that relate to the Services.

  8. To any authority for the purpose of complying with any applicable law, regulation, or legal provision when the transfer is mandatory. 

 

In these cases, we inform you that the Responsible Party guarantees that this privacy notice will be respected at all times by the principles of personal data protection established in the Data Law. Except in these cases, the Responsible Party will not share or transfer your personal data to third parties only if the Holder has consented to said transfer.

 

  1. Changes or Modifications to the Privacy Notice. 

The Responsible Party reserves the right to make modifications or updates to this privacy notice at any time, on the understanding that any modification thereto will be made known to the Holder through the visible publication on our website www.bluecomer.com.

 

  1. Use of Cookies and Other Tracking Technologies.

We inform you that the Responsible Party does not use cookies or other technologies through which it can collect your personal data without your consent.

 

  1. Consent. 

I acknowledge having received this privacy notice and by starting any procedure and sending my information I grant my express consent for the processing of my personal data, (Refusing to the processing of your personal data may result in the impossibility of establishing or continuing the legal relationship with the Responsible Party).