PRIVACY NOTICE

Last update: October 21, 2022.

GRAN ARMEÉ DEL CABO, SOCIEDAD ANÓNIMA DE CAPITAL VARIABLE, its subsidiaries, affiliates, and trusts belonging to the same business group, hereinafter ("GRAN ARMEÉ DEL CABO") in its capacity as responsible for the processing of your personal data, states that for purposes of this notice, its address is located at PREDIO PARAÍSO ESCONDIDO SIN NÚMERO, CABO SAN LUCAS, BAJA CALIFORNIA SUR; MEXICO, C.P. 23450.

GRAN ARMEÉ DEL CABO presents this privacy notice to comply with articles 15, 16 and other related articles of the Federal Law for the Protection of Personal Data in Possession of Individuals (THE LAW).

GRAN ARMEÉ DEL CABO offers its CUSTOMERs products and services of consulting, supervision, and control of all types of work or design of engineering and architecture; purchase and sale of all types of materials for construction in general; administration, purchase, sale and rental of all types of real estate, among others, also undertakes that these data will be treated under the strictest security measures to ensure confidentiality.

The CUSTOMER authorizes GRAN ARMEÉ DEL CABO to process his/her personal data in accordance with the purposes described below, for use during the development of the operations and services contracted. GRAN ARMEÉ DEL CABO will be responsible for protecting them while they are in its possession.

1. PERSONAL DATA RECEIVED FROM THE CUSTOMER

The CUSTOMER expressly agrees to provide GRAN ARMEÉ DEL CABO with the following personal data for processing, including but not limited to:

a) General data of the holder: Paternal Surname, Maternal Surname, Name(s), Date of Birth, Federal Taxpayers Registry (RFC), Sex, Nationality, Place of Birth, official identification, marital status, spouse's name, patrimonial regime, unique population registry code (CURP), profession, occupation, e-mail. In the case of a legal entity, articles of incorporation, RFC, proof of address, account statements, INE and legal accreditation of the legal representative.
b) Address: Street, exterior number, interior number, neighborhood, zip code, State, delegation/municipality, telephone, e-mail.

SENSITIVE PERSONAL DATA. In order to comply with the purposes, set forth in this Privacy Notice, GRAN ARMEÉ DEL CABO informs you that, by way of example but not limited to, sensitive personal data is collected and processed:

a) Financial and Banking Data.- The financial and banking data that may be requested are the following: Financial information, bank accounts, credit and debit card data, income and expenses, bank CLABE, RFC, references and credit history;
b) Patrimonial Data: Information of movable and immovable property. For the treatment of Financial and Banking data, your express consent is required by signing this privacy notice.

This data will be treated under the strictest security measures that guarantee its confidentiality. Other personal data, sensitive and non-sensitive, which are not included in the above lists may be processed as long as such data are considered of the same nature and are not excessive with respect to the purposes for which they are collected. For the treatment of your Sensitive Personal Data, Financial and Bank and Patrimonial Data, your express consent is required by signing this privacy notice.

2. PURPOSE OF THE PERSONAL DATA

THE CUSTOMER consents to the use of his/her personal data by GRAN ARMEÉ DEL CABO for the main purpose of:

a) Identification, location and contact with the holder.
b) Generate intermediation contract with the owner and/or developer.
c) Carry out the deed process.
d) To generate a promise of sale, administration or rental contract or any other contract or preparatory agreement that may be required to be entered into between the CLIENT and GRAN ARMEÉ DEL CABO.
e) Any other purposes that may be necessary for the provision of the services required by you.
f) Issuance of invoices and tax receipts.

SECONDARY PURPOSES

a) To carry out internal studies and processes.
b) To carry out surveys on quality of service and CUSTOMER
c) For marketing, advertising, or commercial prospecting purposes.
d) To comply with applicable legal and regulatory requirements.

In case you do not want your personal data to be processed for these secondary purposes, you have a maximum period of 5 (five) business days to communicate the above to the Contact Department: privacy@pueblobonito.com

The refusal to use your personal data for these purposes may not be a reason for us to deny you the services and products you request or contract with us.

3. SECURITY OF PERSONAL DATA

In accordance with the provisions of Article 16 of the Political Constitution of the United Mexican States, as well as the provisions of the Federal Law for the Protection of Personal Data in Possession of Individuals, GRAN ARMEÉ DEL CABO will implement the necessary technical, administrative and physical security measures to ensure the integrity of your personal data and prevent its damage, loss, alteration, destruction or unauthorized use, access or processing.

Only personnel authorized by GRAN ARMEÉ DEL CABO and designated as the person in charge of safeguarding your personal data may participate in the processing of your personal data. Authorized personnel are prohibited from allowing access by unauthorized persons and/or using personal data for purposes other than those set forth in this Privacy Notice. The obligation of confidentiality of the persons involved in the processing of your personal data subsists even after the termination of the relationship with GRAN ARMEÉ DEL CABO.

4. TRANSFERS

The CUSTOMER understands and accepts that GRAN ARMEÉ DEL CABO may transfer his/her personal data to GRAN ARMEÉ DEL CABO and to third parties contracted by GRAN ARMEÉ DEL CABO to perform on its behalf certain tasks related to commercial activities, promotion of products and services and in general activities related to the corporate purpose of GRAN ARMEÉ DEL CABO such as third-party developers, financial or credit institutions, advertising companies, insurance companies and collection agencies.

GRAN ARMEÉ DEL CABO hereby declares that GRAN ARMEÉ DEL CABO will transfer the information contained herein when necessary to the Ministry of Finance and Public Credit, law firms, Credit Bureau; in such cases GRAN ARMEÉ DEL CABO will ensure that these third parties give it the same treatment as that stated herein. Third parties will not have the right to retransmit the information or use it for purposes other than those designated by the owner through GRAN ARMEÉ DEL CABO.

Your personal data may also be transferred to the Mexican financial authorities in order to comply with laws and official requirements, authorities and institutions in the insurance and surety sector to provide the services contracted, as well as compliance with regulations on the prevention of money laundering, providing in this case the essential data; also, to the competent local and federal authorities when it is within the exceptions listed in the Law and its Regulations. In the case of transfers, treatment of your sensitive personal, financial, and banking data, your express consent will be required, by signing this privacy notice.

The transfer of personal data referred to in the preceding paragraph includes the disclosure of information in a confidential database to third parties who may be participating in a project or business transaction with GRAN ARMEÉ DEL CABO, including implementation of systems, financing, insurance, or, where appropriate, the assignment of rights, debt collection, socio-economic studies, among others.

GRAN ARMEÉ DEL CABO may freely transfer the CUSTOMER's personal data to the controlling companies, subsidiaries, or affiliates, to a parent company or to any company of GRAN ARMEÉ DEL CABO that operates under the same internal processes and policies.

5. LIMITATIONS ON DISCLOSURE OF INFORMATION

GRAN ARMEÉ DEL CABO undertakes not to transfer your personal information to third parties other than those mentioned in the previous paragraph without your consent and in the event that the CLIENT has consented to such transfers, GRAN ARMEÉ DEL CABO will inform the CLIENT through printed or electronic means the purpose for which such information will be transferred to third parties; also GRAN ARMEÉ DEL CABO will inform through the same means by which the personal information was collected (physical address and email address) any changes made to the privacy notice.

Likewise, THE CUSTOMER agrees to notify GRAN ARMEÉ DEL CABO of any change regarding its physical address and/or e-mail address, so that GRAN ARMEÉ DEL CABO may communicate with THE CUSTOMER to inform of any change or modification regarding the contents of this privacy notice.

GRAN ARMEÉ DEL CABO will not need the consent of THE CUSTOMER to transfer to third parties its information in the following cases:

1. When the transfer is provided for in a Law or Treaty to which Mexico is a party.
2. When the transfer is necessary for prevention or medical diagnosis, provision of health care, medical treatment, or management of health services.

III.        When required by competent authorities in accordance with the applicable legal provisions.

6. MEANS TO EXERCISE THE RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION (ARCO) OF PERSONAL DATA

GRAN ARMEÉ DEL CABO has appointed a person in charge of personal data (the "Privacy Officer") therefore you may limit the use or disclosure of your personal data by contacting the Privacy Officer at the following e-mail address: privacy@pueblobonito.com

You have the right to: (i) access your personal data in our possession and know the details of the processing thereof, (ii) rectify them in case they are inaccurate or incomplete, (iii) cancel them when you consider that they are not required for any of the purposes stated in this Privacy Notice, are being used for non-consensual purposes or the contractual or service relationship has ended, or (iv) oppose the processing thereof for specific purposes, as stated by law ( collectively, the "ARCO Rights").

The ARCO Rights shall be exercised by submitting the respective request, which may be requested to the Privacy Officer at the above-mentioned mail, denominating the mail as the "ARCO Request" which shall be sent to the Privacy Officer at the Contact Address, accompanied by the following information and documentation:

a) Your name, address, and e-mail address to communicate the response to the ARCO Request.
b) Documents proving your identity (copy of INE, passport or any other official identification) or, if applicable, documents proving your legal representation.
c) A clear and precise description of the personal data with respect to which you seek to exercise any of the ARCO Rights;
d) Any document or information that facilitates the location of your personal data.
e) In case of requesting a data rectification, you must also indicate the modifications to be made and provide the documentation supporting your request; and
f) Indication of the place where we can review the originals of the accompanying documentation.

Your ARCO Request will be answered by e-mail by the Privacy Officer within 20 (twenty) business days from the day your ARCO Request was received. If the ARCO Request is answered in the affirmative or appropriate, such changes will be made within a maximum of 15 (fifteen) business days. The deadlines referred to in this paragraph may be extended once for an equal period if necessary.

It is important to inform you that GRAN ARMEÉ DEL CABO may deny access (the "Refusal") for you to exercise your ARCO Rights in the following cases:

1. When you are not the owner of the personal data, or your legal representative is not duly accredited to exercise through him/her, your ARCO Rights.
2. When our database does not contain your personal data.

iii.        When the rights of a third party are harmed.

1. When there is a legal impediment or the resolution of a competent authority, which restricts your ARCO Rights; and
2. When the Rectification, Cancellation or Opposition has been previously carried out.

In relation to the above, the Refusal may be partial, in which case GRAN ARMEÉ DEL CABO will carry out the access, rectification, cancellation or opposition in the appropriate part.

GRAN ARMEÉ DEL CABO will always inform you of the reason for its decision and will communicate it to you or, where appropriate, to your legal representative, within the previously established deadlines, by e-mail, accompanied, where appropriate, by the relevant evidence.

The exercise of the ARCO Rights will be free of charge, prior accreditation of your identity before the responsible, but if you repeat your request in a period of less than twelve months, the costs will be three days of General Minimum Wage in force in the Federal District, plus VAT, unless there are substantial modifications to the Privacy Notice that motivate new consultations. In all cases, the delivery of personal data will be free of charge, with the exception that you must cover the justified shipping costs or the cost of reproduction in copies or other formats.

THE CUSTOMER may revoke the consent given to GRAN ARMEÉ DEL CABO for the processing of personal data that are not essential for the fulfillment of the obligations arising from the legal relationship that binds them, so that GRAN ARMEÉ DEL CABO ceases to make use of them. To do so, it is necessary that the CUSTOMER submits its request in the terms mentioned above.

7. MECHANISM FOR REVOCATION OF CONSENT.

In case you decide to revoke your consent for GRAN ARMEÉ DEL CABO to stop processing your personal data, or object to the transfer of such data, you must send a request for revocation of consent to the Contact Address, and must be accompanied in the email with documents proving your identity (copy of IFE, passport or any other official identification) or, where appropriate, documents proving your legal representation and indicating the place where the original documents are made available to us.

To learn about the procedure and requirements for the revocation of consent, you may contact our Privacy Officer at the following email: privacy@pueblobonito.com

In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons about the processing of personal data and on the free movement of such data (hereinafter General Data Protection Regulation or "GDPR") GRAN ARMEÉ DEL CABO undertakes to continue to obtain your express consent to acquire, process and process your personal data in accordance with the provisions of the GDPR.

When you access the GRAN ARMEÉ DEL CABO website, the server stores the following information: the domain or IP address of the computer requesting access, the date of access, the HTTP response code, the web page from which you access and the number of bytes transferred through the connection, time spent browsing our website, sections consulted, and Internet pages accessed prior to ours. The above information is collected for system security purposes, as well as to monitor your behavior as an Internet user, to provide you with a better service and user experience when browsing our website, and to offer you new services based on your preferences. In some cases, GRAN ARMEÉ DEL CABO stores certain information on your PC by means of "cookies". A "cookie" is a data file that is stored on the hard drive of a user's computer or electronic communications device when browsing a specific website, which allows the exchange of status information between the website and the user's browser. The use of cookies may reveal means of session identification, authentication, or user preferences, as well as GRAN ARMEÉ DEL CABO may have access to your system or your personal data, unless you provide such information voluntarily. It is important to mention that standard browser settings allow the use of cookies, so you can disable these settings in your browser.

Our website may contain links to external websites and/or social networks that do not correspond to GRAN ARMEÉ DEL CABO and, therefore, have no relationship with us. We recommend that you review and read the privacy policies and terms of use of such external websites before using them. We assume no responsibility or risk with respect to privacy or any other legal issues relating to any of their services.

This Privacy Notice and any changes to this Privacy Notice will be posted at GRAN ARMEÉ DEL CABO's offices and/or on the following web site: www.quiviraloscabos.com