Privacy Notice

Blackmun, S.A.P.I. de C.V., and/or Manalu, S.A.P.I. de C.V. and/or Blariz, S.A.P.I de C.V., commercially known as BlackTrust (together with its affiliates and subsidiaries, hereinafter “Black Trust”), with address at California 105, Colonia Insurgentes San Borja, Alcaldía Benito Juárez, C.P. 03100, Mexico City, Mexico , and with Internet portal http://www.blacktrust.net, is responsible for the use and protection of your personal data and/or sensitive personal data, and in this regard we inform you of the following:

Who is the Personal Data Protection Officer?

BlackTrust informs you that a Data Privacy Officer, called the “Data Privacy Officer”, has been appointed to oversee and implement BlackTrust’s Data Privacy Policy.

For what purposes will we use your personal and/or sensitive data?

The personal and/or sensitive data that we collect from you will be used for the following purposes, depending on the nature of the legal or commercial relationship between Black Trust and you.

I. Prospective Client:

In the case of data requested to establish a possible business relationship with you, we will use such data for the following purposes, which are necessary for the service you request:

  • Evaluation to determine if it will be possible to establish a commercial relationship;
  • Purchase of products or services from BlackTrust;
  • Research of commercial and supplier relationships and references;
  • Determination of a term and credit limit, if applicable;
  • Definition of commercial conditions; and
  • Evaluation to determine if it is possible to establish a professional and commercial relationship.
  • For any other compatible or analogous purpose.

In addition, we will use your personal information for the following secondary purposes that are not necessary for the requested service, but that allow and facilitate us to provide you with better service:

  • Delivery of promotional material; and
  • Service quality evaluations.

In case you do not want your personal data to be processed for these additional purposes, you can submit your request now by e-mail to

privacidad@blacktrust.net

 your letter, stating the above.

II. Supplier:

In the case of data requested to establish a business relationship with you, as a supplier or potential supplier of Black Trust, we will use your personal and/or sensitive data for the following purposes, which are necessary for the service you request:

  • Register you as a supplier;
  • Enter into such legal instruments as may be necessary to
    document the relationship you have or would like to have with you;
  • Fulfillment of obligations derived from the legal relationship that
    you have with you;
  • To enforce and/or execute a contract;
  • Quotation of goods and/or services required by Blacktrust Trust;
  • Conducting surveys and training programs;
  • Attention to doubts and suggestions; and
  • Payment of consideration and invoicing.
  • For any other compatible or analogous purpose.

III. Candidates and Employees:

In the case of data requested from candidates for BlackTrust or BlackTrust client job openings, or from BlackTrust employees, you are informed that we may use your personal and/or sensitive data for the following purposes, which are necessary for the service you are requesting:

  • To verify and confirm your identity,
  • Review of professional and academic information,
  • Contact in case your professional and academic information is of interest to Black Trust or Black Trust clients and you are applying for a vacancy,
  • Conduct evaluations for recruitment,
  • Recruitment, personnel selection, business consulting, training, hiring and training of personnel, payroll services, as well as the performance of socio-economic studies and application of all types of aptitude and competency tests.
  • Human Resources and labor processes for current and potential employees, candidates, temporary employees and independent contractors.
  • Investigation of judicial, criminal, labor, credit, social and personal background,
  • Request and receive payment for services requested,
  • Share information with billing and collection providers for electronic transactions,
  • Application of toxicological tests according to the express consent given by the holder and,
  • For any other compatible or analogous purpose.

IV. Citizens:

In the case of data requested from citizens to perform the identity verification service, we inform you that we may use your personal and/or sensitive data for the following purposes, which are necessary for the service you request:

  • To verify and confirm your identity.

V. General Public:

In the case of data requested from the general public, we inform you that we may use your personal and/or sensitive data for the following purposes, which are necessary for the service you request:

  • Sending information. Black Trust may send you information regarding particular topics of interest to the company.

VI. Visitors:

In the case of data requested from visitors, you are informed that we may use your personal and/or sensitive data for the following purpose, which is necessary for the service you request:

  • Maintaining access control, as well as safeguarding the security of BlackTrust’s facilities, employees and the confidentiality of BlackTrust and BlackTrust customer proprietary information.

VII. Visitors to the website:

In the case of data requested from visitors to our website, we inform you that we may use your personal and/or sensitive data for the following purposes, which are necessary for the service you request:

  • Register you in the programs in which you have voluntarily enrolled and send you requested information or information about BlackTrust and/or its products, events, promotions and activities in general, that we believe may be of interest to you, as well as answer your questions or comments.
  • Creation and administration of your account, when you decide to create it.
  • Sign up to receive information of interest from BlackTrust or on a particular topic.

What is the legitimate basis for processing your personal data?

You are informed that BlackTrust only processes Personal Data if the Data Subject has consented to the use and processing of his or her Personal Data, if the processing is necessary for the performance of a contract to which the Data Subject is a party or for the implementation at the Data Subject’s request of pre-contractual measures; or if the processing is necessary for compliance with a legal obligation applicable to the data controller.

What personal and/or sensitive data will we use for these purposes?

For the purposes of this privacy notice, personal data shall be understood as any information concerning an identified or identifiable natural person, for example, identification data, employment data and patrimonial data, among others, and sensitive personal data shall be understood as those personal data that affect the intimate sphere of its owner, particularly those data that may reveal aspects such as racial or ethnic origin, present and future state of health, genetic information, religious, philosophical and moral beliefs, union affiliation and political opinions are considered sensitive.

In order to carry out the purposes described in this privacy notice, we will use the following personal data and/or personal information sensitive:

I. Prospective Client:

Personal data:

  • Identification data
  • Contact information
  • Equity and/or financial data

II. Supplier:

Personal data:

  • Identification data
  • Contact information
  • Employment data
  • Nationality or origin data
  • Equity and/or financial data

III. Candidates and Employees:

Personal data:

  • Identification data
  • Contact information
  • Employment data
  • Academic data
  • Equity and/or financial data

Sensitive personal data:

  • Judicial background data
  • Biometric data (image)
  • Nationality or origin data
  • Health data (such as toxicology test results).

IV. Citizens:

Sensitive personal data:

  • Identification data,
  • Data on physical characteristics,

Sensitive personal data:

  • Biometric data (image),
  • Nationality or origin data,

V. General Public:

Personal data:

  • Identification data,
  • Contact information,

VI. Visitors:

Personal data:

  • Identification data,
  • Contact information,

VII. Visitors to the website:

  • Identification data,
  • Contact information,

With whom do we share your personal information and for what purposes?

We inform you that your personal data and/or sensitive personal data, if applicable, are shared with the following persons, companies, organizations or authorities other than us, safeguarding the privacy of the same, solely and exclusively for the following purposes, unless you expressly tell us otherwise:

Recipient of personal and/or sensitive data Purpose Consent required
Customers or Third Parties related to BlackTrust. Statistical purposes. Human Resources Processes.
Follow-up and training of employees.
Profile exchange for recruitment and selection.
Safety and risk mitigation assessment.		 No personal data of citizens is transferred in connection with the verification of the identity of the Holders.
Only the personal data of employees and candidates are transferred, so only the consent of such data subjects is required.
Third parties that carry out studies, provide courses and/or trainings Human Resources training and coaching. No
BlackTrust providers for electronic transactions Request and receive payment for services requested. Yes

With respect to transfers that require your consent, if after reading this privacy notice you do not object to such transfers, we will assume that you have given us your consent. We provide you with the mechanism described in the following section of this privacy notice so that, if necessary, you can communicate your refusal to allow such transfers to take place.

How long will your personal data be kept?

Your personal data will be retained for as long as you are interested in BlackTrust’s services or as long as we are required by applicable law to retain your information to comply with legal obligations.

What rights do you have regarding your personal data?

You have the following rights in relation to your Personal Data:

  • Right to access your personal data,
  • Right to request its rectification or suppression,
  • The right to request the limitation of their treatment,
  • Right to cancellation of use and deletion of your personal data, and right to be forgotten,
  • Right to object to the processing,
  • Right to the portability of your personal data,
  • Right to file a complaint with a supervisory authority.

How can you access, rectify or cancel your personal and/or sensitive data, or object to its use?

You have the right to know what personal and/or sensitive data we have about you, what we use it for and the conditions of the use we make of it (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); that we remove it from our records or databases when you consider that it is not being used properly (Cancellation); as well as to oppose the use of your personal and/or sensitive data for specific purposes (Opposition). These rights are known as ARCO Rights.

In order to exercise any of the ARCO Rights, you must submit the respective request in writing, at the Black Trust address mentioned above or through an email sent to the following address: privacidad@blacktrust.net and addressed to the person in charge of the Personal Data Department of BlackTrust.

The request referred to in the preceding paragraph shall contain: (i) name of the owner of the information, address and e-mail or other means to communicate the response; (ii) documents proving their identity or the corresponding legal representation; (iii) a clear and precise description of the personal data and/or sensitive personal data in respect of which the corresponding right is being exercised; and (iv) any other element that facilitates the location of personal and/or sensitive data.

Regarding the procedure and requirements for the exercise of your ARCO Rights, we inform you of the following:

a) By what means can the holder and, if applicable, his representative, as well as the latter's personality, prove their identity?

By means of a simple copy of their official identification, power of attorney of the legal representative and official identification of the legal representative, if applicable.

b) What information and/or documentation should the application contain?

The clear and precise description of the personal data and/or sensitive personal data in respect of which the corresponding right is exercised, as well as any background information that allows locating the corresponding data.

c) How long will it take to respond to your request?

Pursuant to Article 32 of the Federal Law for the Protection of Personal Data in Possession of Individuals, the holder will be informed about the determination, within a maximum period of 20 business days, counted from the date on which the request to exercise ARCO Rights was received. In the event that your request is granted, it will be effective within 15 business days following the date on which the response to the decision is communicated.

d) By what means will we communicate the response to your request?

By e-mail or to your home address, in case you do not have an e-mail address available.

e) On what media can the personal and/or sensitive data you request be reproduced?

Simple copy, electronic documents, storage media such as magnetic disks (floppy disks, hard disks), optical disks (CD, DVD) USB or via e-mail.

The delivery of personal data will be free of charge, and the holder will only have to cover the justified shipping costs or the cost of reproduction in copies or other formats.

Due to the type of service provided by BlackTrust, we inform you that the Unique Population Registry Code (CURP) will be kept dissociated for a period of two years for internal BlackTrust purposes.

For further information about the procedure, you may contact BlackTrust’s Personal Data Officer by e-mail or telephone as described below:

  • Name: Personal Data Department.
  • Address: California 105, Colonia Insurgentes San Borja, Alcaldía Benito Juárez, C.P. 03100, Mexico City, Mexico.
  • E-mail: privacidad@blacktrust.net
  • Telephone number: (55) 87 16 29 39

You can revoke your consent for the use of your personal data and/or sensitive

You may revoke the consent, if any, you have given us for the processing of your personal and/or sensitive data. However, it is important to note that not in all cases we will be able to fulfill your request or terminate the use immediately, since it is possible that due to some legal obligation we may need to continue processing your personal and/or sensitive data. You should also consider that, for certain purposes, the revocation of your consent will mean that we will no longer be able to provide you with the service you requested, or the termination of your relationship with us.

To revoke your consent, you must submit your request through the procedure and means described in the previous section.

In the event that irregularities are detected in these applications, BlackTrust may request additional information from you to confirm your identity.

How can you limit the use or disclosure of your personal information?

In order for you to limit the use and disclosure of your personal information, we offer you the following means:

  • Your registration in the opt-out list “Blacktrust opt-out list” so that your personal data will not be processed for marketing, advertising or commercial prospecting purposes by us. For further information please send an e-mail to the following address privacidad@blacktrust.net

Complaints to the Guarantor Body.

In the event that you feel that your rights concerning the protection of your personal data have been violated, especially if you have not satisfaction in the exercise of your rights, you may file a complaint with the National Institute for Transparency, Access to Information and Access to Justice. Information and Personal Data Protection as a regulatory authority for personal data protection http://inicio.inai.org.mx/SitePages/ifai.aspx

The use of analysis technologies

We inform you that we use web beacons or different bugs, through which it is possible to analyze your behavior as a user within our portal, in order to provide you with a better service and user experience when using our services, as well as to offer you new products and services based on your preferences. The personal and/or sensitive data we collect through these technologies will be used for the following purposes:

  • Analysis and statistics of our portal
  • Improve the service, quality and performance of our portal.
  • Offer you new products and services based on your preferences.

The personal and/or sensitive data we obtain from these analytics technologies are as follows:

  • Technical characteristics of the user equipment
  • User’s preferred language
  • Region in which the user is located
  • User’s browser type
  • Type of user’s operating system
  • Date and time of the beginning and end of a user’s session

These technologies can be disabled as long as you have a web browser with private browsing enabled.

Are there automated decisions, profiling or logic applied in relation to your personal data? To what end?

You are informed that in the processing of your personal data there are partially automated decisions, as well as profiling where an applied logic is required, which is performed according to the consent that the owner gives to BlackTrust.

Partially automated decision making and profiling is performed for the following purposes:

  • Human Resources Processes.
  • Recruitment and Selection.
  • Safety Assessment and Risk Mitigation.

It is specified that for the processing of sensitive data a human person is involved during the process. BlackTrust has also put in place measures to safeguard the owner’s data. If you would like to know what these measures are, BlackTrust makes the following e-mail address available to you:

privacidad@blacktrust.net

Data Processing

BlackTrust informs you that it processes personal data in accordance with the applicable national and international legal bases and in accordance with the instructions of the controller of the personal data, where applicable.

The processing is necessary to provide the functions and services that BlackTrust offers and that its customers request from it.

BlackTrust must collect and use certain information to provide its services. This includes the following:

  • Profiling information, this may include name, telephone number, address, official identification numbers (such as social security number, driver’s license, voting card or passport if required by law), date of birth, photo and signature.
  • Background check information, this may include judicial and criminal records (if permitted by law).

The processing is necessary to protect and satisfy the legitimate interests of BlackTrust or third parties. BlackTrust collects and uses personal information to the extent necessary to fulfill its legitimate interests. This includes the collection and use of information for the following purposes:

  • Maintaining and improving the safety of our customers
  • Prevent, detect and combat fraud related to the use of our services.
  • Provide customer support
  • Optimize service and develop new services
  • For research and analysis purposes
  • For advertising purposes

The processing is necessary to meet the legitimate interests of other persons or parties. BlackTrust collects and uses personal information to the extent necessary to fulfill the interests of others or the general public. BlackTrust may also process personal information related to matters of public interest in accordance with applicable laws.

What are the special conditions applicable to children under 16 years of age, in relation to the processing of their personal data?

For persons under the age of 16 who choose to use BlackTrust’s services and provide their personal data, we inform them that we will only process their personal data when the holder of parental or guardianship consent or authorize BlackTrust to process the personal data of the minor under 16 and only to the extent authorized by the minor.

How can you find out about changes to this privacy notice?

This privacy notice may be modified, changed or updated as a result of new legal requirements; our own needs for the products or services we offer; our privacy practices; changes in our business model, or for other reasons.

We are committed to keeping you informed of any changes to this privacy notice through updates to this privacy notice at notice published directly on: https://blacktrust.net/aviso-de-privacidad/

BlackTrust processes your personal data and/or sensitive personal data in accordance with the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility in terms of the provisions of the Federal Law for the Protection of Personal Data in Possession of Individuals, its Regulations and other applicable provisions.

At the time of this publication, the holder of the personal data confirms and authorizes the following:

  • I have read and confirm that I am aware of the Privacy Notice made available by Blacktrust.

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Last update: 15/08/2023

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