PRIVACY NOTICE

1. RESPONSIBLE PARTY FOR PERSONAL DATA

GUJALU DESARROLLADORA INMOBILIARIA SA DE CV legal entity referred to as “SEEDNESS”) with a business address at Río Ganges 45 ,Cuauhtémoc, Cuauhtémoc 06500 Mexico city, hereinafter “Seedness” is the entity responsible for your Personal Data. We hereby inform you that by collecting and processing your Personal Data, we are committed to you and to the protection of your Personal Data. Therefore, we present this Privacy Notice.

2. PURPOSES OF PROCESSING YOUR PERSONAL DATA:

A. Primary Purposes:

Your Personal Data will be used for the following purposes:

All purposes necessary to fulfill the obligations arising from the legal relationship with Seedness regarding the services or products requested or contracted, including but not limited to the following:

• Provision of professional services for the promotion and sale of real estate.
• Preparation of real estate purchase and sale agreements.
• Assistance in obtaining mortgage loans.
• Issuance of electronic invoices.
• Management of accounts receivable, collections, and payment applications.
• Compliance with federal, state, or local regulatory obligations.


For the purposes mentioned above, we collect and process the following data:

I. Personal Data

a) Identification Data

• Name(s) and surname(s)
• Date of birth
• Address
• Age
• Marital status
• Phone number
• Email address
• RFC (Federal Taxpayer Registry)
• CURP (Personal Identification Code in Mexico)


II. Financial and Property Data

• Economic activity, occupation, and business sector
• Place of employment
• Social Security number
• Pay slips or employment certificates
• Income statements
• Bank account listings
• Bank account number


III. Sensitive Personal Data

• Photographs
• Images and sounds captured by surveillance cameras for security measures protecting clients, visitors, and occupants of Seedness offices.

B. Secondary Purposes:

• Advertising and marketing promotions
• Statistical purposes
• Tracking the customer’s purchasing process
• Evaluation of the service quality provided during the purchasing process


For Secondary Purposes, you, as the Data Subject, have 5 business days to express your objection, regardless of this period, at any time, the Data Subject may express their objection through Mechanisms to exercise ARCO Rights. The objection regarding the use of your Personal Data for secondary purposes will not, under any circumstances, prevent the provision of the requested service or product.

3. TRANSFERS MADE BY THE COMPANY

The Personal Data collected may be transferred to our affiliated or subsidiary companies of GUJALU DESARROLLADORA INMOBILIARIA SA DE CV; this action will be carried out for marketing, advertising, or commercial prospecting purposes.

We hereby inform Data Subjects that we make transfers of Personal Data in the following cases:

• To carry out procedures and management of mortgage loans with multiple banking institutions in the financial sector. [ ]
• To carry out procedures before a Notary Public. - When you contract or purchase any of our services to acquire real estate, it is necessary to carry out procedures before a Notary Public. In this regard, we will transfer your personal data to the notaries with whom we have agreements. [ ]
• By order of a competent authority. - In this case, we will transfer your personal data to the competent authority, upon written instruction.

4. MECHANISMS TO REQUEST THE EXERCISE OF ARCO RIGHTS

In accordance with the Federal Law on the Protection of Personal Data Held by Private Parties, you have the following rights, known as ARCO Rights; these are:

• Access: To your Personal Data, the notice, and the terms of processing.
• Rectification: When the Personal Data provided is incomplete, incorrect, or has changed.
• Cancellation: When you no longer wish your Personal Data to be processed, due to the failure to comply with the principles of purpose and proportionality.
• Opposition: When you wish to prevent processing for legitimate reasons, in a justified manner.


As the Data Subject, you may request information for the exercise of your ARCO rights from the Personal Data Department of Seedness, express your objection, as well as the revocation of consent and the limitation of the use and/or transfer of your Personal Data, in the following ways:

• By sending a free-form letter signed and addressed to the Personal Data Department of the Real Estate Company, delivered to the address: Río Ganges 45 ,Cuauhtémoc, Cuauhtémoc 06500 Mexico city,
• Via email to: ventas@seedness.com
• Via email to: ventas@seedness.com


As required by law, you must also attach a document proving your identity or, where applicable, your legal representation, and only in the case of Rectification, provide a document that allows us to identify the Personal Data to be corrected.

A. Deadlines:

From the moment your request is submitted, we inform you that the deadlines to address said request will be as follows:

We have 5 business days to inform you that your request has been received and assign it a request number.

If the information provided in your request is insufficient or incorrect for processing, or if the documents previously mentioned are not included, you will be required to submit the necessary elements or documents to proceed with your request within the following 10 (ten) business days to address the information request. If you fail to comply with this request, your application will be considered as not submitted.

If no additional information is required, the Real Estate Company has a period of 20 (twenty) business days to communicate the resolution adopted, so that, if applicable, your request will be processed within the 15 (fifteen) business days following the date on which the response is communicated.

5. MEANS THROUGH WHICH PERSONAL DATA IS COLLECTED

a. Personal conversations with sales advisors and/or personnel of the Real Estate Company. b. Via email c. Via telephone d. Website

6. USE OF COOKIES, WEB BEACONS, OR OTHERS

Cookies are text files that are automatically downloaded and stored on the user’s computer hard drive when browsing a specific webpage. These files allow the web server or email server to remember, and may be used to monitor a visitor’s behavior, such as storing information about the user’s IP address, duration of interaction on the webpage, and the type of browser used, among other things.

7. OPTIONS AND MEANS PROVIDED BY THE DATA CONTROLLER TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA

Seedness has internal mechanisms to limit the use and disclosure of your Personal Data, as well as administrative, physical, and technological security measures to ensure the proper processing of your Personal Data.

Our Personal Data Department is responsible within the Real Estate Company for promoting and safeguarding the protection of the Personal Data in our possession, as well as for addressing the rights of the Data Subjects.

We inform you that there are other mechanisms to limit the use and disclosure of your data, such as the Public Registry to Prevent Advertising (REPEP) of PROFECO or the Public Registry of Users (REUS) of CONDUSEF, where you can find more information regarding registration on the websites of each agency.

8. PROCEDURES AND MEANS THROUGH WHICH WE WILL COMMUNICATE CHANGES TO THE PRIVACY NOTICE TO DATA SUBJECTS

Seedness may, at any time, modify this Privacy Notice by publishing it on the website https://seednessmx.com; therefore, it is recommended to visit it periodically.

9. IMPROPER PROCESSING OF YOUR PERSONAL DATA

If you believe that:

I) Your right to the protection of your Personal Data has been violated by any conduct of our employees during these actions or responses; or II) You suspect that the processing of your Personal Data involves a violation of the provisions established by the Federal Law on the Protection of Personal Data Held by Private Parties, you may file a complaint or report with the INAI (National Institute for Transparency, Access to Information, and Personal Data Protection) on the following website: inai.org.mx