1.- IDENTITY AND ADDRESS:

FIDELIS VENTAS Y DESARROLLO S.A. DE C.V. with address located at Calle 10 Avenida Norte, Local 34B, Plaza Pelícanos, Manzana 100, Lot 001. SN, Colonia Centro, Municipality of Solidaridad, Playa del Carmen Quintana Roo, C.P. 77710, (hereinafter the “Company”); is constituted as the person responsible for the processing of the personal data that you provide us which will be protected in accordance with the provisions of the “Ley Federal de Protección de Datos Personales en Posesión de Particulares” (LFPDPPP), (hereinafter the “Law”), its regulations and other applicable provisions.

We inform you that your data will not be disclosed, sold or leased, since the Company’s intention is to collect the smallest amount of your data that will be used for what is established in this notice. You are also informed of the mechanism that You have to let us know if you do not agree to share your data. The period of conservation of your data is equal to the time required to carry out the purposes of the treatment, plus the applicable legal, administrative, accounting, tax, juridical and historical periods.

2.- PERSONAL DATA THAT WILL BE PROCESSED:

The personal data that the Company will collect from you through the information and/or documentation provided personally or directly by you, or those obtained indirectly, by any electronic means, including but not limited to, emails, applications, internet page, data messages, etc. and exclusively for the purposes indicated in clause 3 of this Privacy Notice are:

1. Name.
2. Address.
3. Email.
4. Telephone number.
5. Contact details.
6. Federal Taxpayer Registry Code.
7. Financial or asset data.
8. Documentation supporting travel and planning, including identity verification documents (if provided).
9. Username and password.
10. Photos, reviews, social media posts and videos you have shared with us.
11. Geolocation information.
12. Device information, such as access times, IP address, software or Internet browser used, preferred languages, unique device identifiers, and advertising identifiers.
13. Online activity, including pages viewed, content reviewed, and apps reviewed.
14. Purchase and reservation history.
15. Information about your travel plans and preferences.
16. Communications with our customer service team, including inbound and outbound calls.

You can always choose not to provide your personal data and if you do not agree, the operations you intend to carry out with the Company may not be carried out. On the other hand, the mechanisms you have to let us know your refusal are specified in point number 4 of this notice.

If you make reservations on behalf of a third party, you will inform them of this notice and obtain the prior consent of said third party to provide their personal data.

The Company may verify the personal data provided by consulting public entities, specialized companies or risk centers, respecting the legislation applicable to the entity.

By providing opinion, or uploading multimedia content through any sales channel, you understand that said content will not be treated confidentially and may be freely used by the Company for commercial purposes, subject to the limitations provided in the applicable legislation, you waive all rights to use this material, including privacy rights, property rights and publicity rights, and the right to object to the way this material is used. Granting all rights to the Company and its related companies to use, transmit, copy and display the Opinions in any media. No compensation will be paid for Reviews or multimedia material.

3.- PURPOSES OF THE PROCESSING OF PERSONAL DATA.

The personal data that the Company collects from you is used to:

1. Make reservations.
2. Prepare contracts and/or agreements.
3. Develop itineraries.
4. Sending information.
5. Payments for your services, quotes, as well as other commercial issues arising from the contract and/or main operation.
6. Process payments or credits.
7. Offer promotional opportunities, including contests, gift cards, rewards, rebates, and discounts.
8. Notify you about special offers, giveaways, contests and Services available from us, our affiliates or partners that may be of interest to you.
9. Personalize your experience by making inferences about your interests and preferences based on your activity and personalize the ads displayed on and off our website.
10. Respond to your questions and comments.
11. Document the internal processes derived from the Company’s policies.
12. Document the operations and/or transactions that are carried out.
13. To contact you and send you relevant information regarding various topics.
14. Request products and/or services,
15. Provide you with payment information.

Additionally, we will use your personal data strictly and exclusively for the following purposes that are not necessary for the legal relationship between the Company and you as the owner of the personal data:

To demonstrate the materiality of the operations carried out by the Company in tax matters.

Provide them if they are required by the tax authorities or any other authority.

To contribute to judicial, administrative, or labor authority in any claim or conflict as required.

Additionally, the Company may process your personal data to create a database of clients and suppliers, as well as for marketing, advertising, or commercial prospecting purposes. Although these purposes are not necessary to create or maintain your legal relationship with the Company, they allow and facilitate better service to you.

The Company will process your personal data only for the time necessary to fulfill the purposes described in this Privacy Notice and/or in accordance with what is established by both the Law and the applicable legal and regulatory provisions.

4.- MECHANISM THAT THE COMPANY HAS IMPLEMENTED SO THAT YOU CAN EXPRESS YOUR REFUSAL FOR THE PROCESSING OF YOUR PERSONAL DATA IN RELATION TO PURPOSES THAT ARE NOT NECESSARY FOR THE LEGAL RELATIONSHIP BETWEEN THE COMPANY AND YOU.

You are informed that the email address [email protected]  is at your disposal to express your rejection or non-authorization for the processing of your personal data, particularly with regard to the purposes that are not necessary to create , modify and continue with the legal relationship that the Company has with you.

Likewise, for the above purposes, you may call the following telephone number 984 803 5484 from 08:00 to 20:00 from Monday to Friday, with the understanding that the refusal expressed by you by telephone must be ratified in writing, sending a communicated to the aforementioned email.

5.-TRANSFER OF PERSONAL DATA

You are informed that the Company transfers your personal data to third parties, only to comply with the obligations derived from the legal relationship that you have with the Company.

Specifically, the Company will send all or part of your personal data to service providers of tours, events, tourist activities, airlines, transporters, etc. as well as providers of internal audit, legal, foreign trade and customs services, or any other service provider. other services provided by the company’s suppliers on a regular basis, such as transportation services, transfers, among others, as long as they are necessary for the fulfillment of the obligations created between you and the Company.

The Company will ensure, through the signing of confidentiality agreements and/or the adoption of other binding documents, that said third parties maintain appropriate security, administrative, technical and physical measures to safeguard your personal data, as well as that said third parties only use your personal data for the purposes for which they were collected in accordance with this Privacy Notice.

Likewise, in the event of an official request, the Company may transfer your personal data to the requesting authority.

By virtue of the above, by ACCEPTING this Privacy Notice, you expressly accept the transfer of your data in the terms referred to above.

National or international data transfers may be carried out without the consent of the owner when any of the following situations occur:

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, the provision of healthcare, medical treatment or the management of healthcare services.

III. When the transfer is made to holding companies, subsidiaries or affiliates under the common control of the controller, or to a parent company or to any company in the same group of the controller that operates under the same internal processes and policies.

1. When the transfer is necessary by virtue of a contract concluded or to be concluded in the interest of the owner, by the person responsible and a third party.
2. When the transfer is necessary or legally required for the safeguarding of a public interest, or for the procurement or administration of justice.
3. When the transfer is necessary for the recognition, exercise or defense of a right in a judicial process, and

VII. When the transfer is necessary for the maintenance or fulfillment of a legal relationship between the person responsible and the owner.

6.-MEANS FOR THE EXERCISE OF ARCO RIGHTS.

You can at any time exercise your rights of Access, Rectification, Cancellation or Opposition (ARCO rights) regarding the treatment that the Company gives to your personal data. To exercise any of your ARCO rights you must:

Submit the respective request by filling out the Single Form for the Exercise of ARCO Rights, the request must be sent to the email: [email protected] ,  accompanied by the documents established in the format.

Prove your identity through the presentation or sending a copy of your official identification document, also exhibiting the original for comparison, or the personality of your representative through a public instrument, power of attorney signed before two witnesses or your statement in personal appearance and;

If you request rectification of your personal data, present the documentation that supports your request.

You are informed that the Company may deny access to personal data, or carry out rectification or cancellation or grant opposition to the processing thereof, whether in whole or in part, in the following cases:

1. When you are not the owner of the personal data, or your legal representative is not duly accredited to do so.
2. When your personal data is not found in our database.
3. When the rights of a third party are violated.
4. When there is a legal impediment, or the resolution of a competent authority, that restricts access to personal data, or does not allow rectification, cancellation or opposition thereof, and
5. When the rectification, cancellation or opposition has been previously made.

The Company will respond to your request and within a period of no more than 20 days, it will communicate the corresponding determination in writing to the address indicated above, or to the email address through which you sent your request, as the case may be. Our response may include simple copies, electronic documents in editable or PDF format, recordings or videos, or any other means of reproduction that the Company deems appropriate to provide a timely response to your request.

In the event of refusal to access personal data, you will be informed of the reason for our decision within the period indicated in the previous paragraph, with the evidence that we deem relevant.

If you have questions about how to exercise your ARCO rights, you can contact the Company’s legal department by email at [email protected];  or at the aforementioned address, during the following hours, Monday to Friday, 08:00 a.m. to 8:00 p.m.

7.-MECHANISMS AND PROCEDURES FOR REVOCATION OF CONSENT.

Additionally, you may limit or revoke the consent that, where applicable, you have granted to the Company for the processing of your personal data.

To limit or revoke your consent, you must submit the respective request and prove your identity, or if applicable, the personality of your representative, in accordance with the provisions and complying with the requirements referred to in the previous clause of this Privacy Notice. The Company will respond to your request and within a period of no more than 20 days it will communicate the corresponding determination to the same address where you submitted your request, or to the email through which you sent your request, as the case may be.

8.-OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA.

If you decide not to receive or limit the frequency of receiving promotions or communications through our advertising campaigns, you are informed that you can contact us by email at [email protected],  or at mentioned address. The Company will respond to your request and within a period of no more than 20 days it will communicate the corresponding determination to the same address where you submitted your request, or to the email through which you sent your request, as the case may be.

9.-USE OF COOKIES AND WEB BEACONS.

The Company’s Internet sites, and online services are based on the management of Cookies and Web beacons. For the purposes of this Privacy Notice, Cookies are defined as the data file that is stored on the hard drive of a user’s computer equipment or electronic communications device when browsing a specific website, which allows the exchange of information. state between said site and the user’s browser. State information may reveal means of session identification, authentication, or user preferences, as well as any data stored by the browser regarding the Internet site.

Additionally, Web beacons are defined as the visible image inserted within a website or email, which is used to monitor user behavior in these media. Through these you can obtain information such as the source IP address, browser used, operating system, time at which the website was accessed, and in the case of email, the association of the previous data with the recipient.

By entering and continuing to browse our websites, or by receiving and interacting with our emails, you consent to the Company collecting and processing your personal data. The use of this technology is necessary for the correct functioning of our website, to fulfill the purposes of processing your personal data, as well as for operational, technical and security reasons.

The Company will process your personal data only and exclusively in accordance with this Privacy Notice, as well as to comply with the obligations derived from the legal relationship that you have with the Company.

However, if you wish to disable these technologies, you are informed that you can contact us by email at [email protected], or at the address mentioned in this Privacy Notice. The Company will respond to your request and within a period of no more than 20 days it will communicate the corresponding determination to the same address where you submitted your request, or to the email through which you sent your request, as the case may be.

10.-CHANGES TO THE PRIVACY NOTICE

The Company may make changes to this Privacy Notice, in which case, you will be able to find out about the modifications and/or updates to it on the website https://v-luxurytravel.com/  or by requesting it directly following the route specified in the this Privacy Notice.

I declare that I have read and agree with the terms and conditions of this Privacy Notice made available to me by the Company, therefore I grant my express consent for the processing of my personal data in terms of what is established herein.

Last update February 13, 2024.