Rotoplas Investors - Privacy Notice

Rotoplas Privacy Notice

In compliance with the provisions of the Federal Law for the Protection of Data Held by Individuals or Private Companies (hereinafter "the Law") of the United Mexican States, we hereby inform you of the following:

Data controller’s identity and mailing address:

Grupo Rotoplas, S.A.B. de C.V., (hereinafter "Rotoplas"), whose address for hearing and receiving any and all notifications is located at Pedregal 24, Piso 19, Col. Molino del Rey, Alcaldía Miguel Hidalgo, C.P. 01140, Mexico City, shall be responsible for all personal data provided by individuals (hereinafter the "Data Subject"), for Company itself or for any of the business entities that are its holding companies, subsidiaries or affiliates.

Personal Data to be subjected to Processing

When entering our facilities or work centers, Rotoplas may gather identification data, which may include biometric data related to your facial features, contact data, demographic data, employment data, technical and operational information, network traffic and characteristics of the devices you use to access our services, as well as data generated as a result of the use of our services. Additionally, in order to comply with the various guidelines issued by the three branches of governmental health authorities and to address health contingencies announced by the competent authorities, Rotoplas may also gather sensitive data regarding bodily temperature of individuals entering its facilities and/or those of third parties, data regarding their vaccination status against SARS-CoV2, which causes the disease COVID-19, and/or health conditions that may pose a risk to people in general.

For job applications, Rotoplas shall gather identification data, including biometric data, which may include facial features, contact data, demographic data, education data, employment data and assets data. If you are hired, such data shall then become part of your personal employment file.

Once you become an employee, we shall process the following personal data: personal identification data, including biometric data, which may include facial features, contact data, demographic data, education data, employment data and assets or financial data. Please be advised that the processing of such data is necessary to fulfill the obligations arising from the legal relationship between you and Rotoplas, therefore your consent is therein exempted.

Pertaining to customers, we may gather identification, contact, demographic, tax, employment, financial and asset data.

Rotoplas may process third parties' personal identification and contact information when you provide us with such so that said third parties may be contacted as personal and/or family references for purposes of contact, collection, research or validation of information provided by you. By providing this information you acknowledge that you have informed such third parties of the use of their data and have obtained their prior consent for Rotoplas to process such data for the above purposes.

Use of cookies and web beacons

The website www.rotoplas.com (hereinafter "the Website") and our licensed applications (hereinafter "Services") use a number of technologies to improve efficiency and enhance your browsing experience. Among such technologies is the use of cookies, which are small amounts of data stored in the browser used by the user so that our server remembers certain information that can be used at a later time. Such data allow us to identify you and save your personal preferences in order to provide you with an improved browsing experience.

The Services likewise use web beacons, also known as Internet tags, pixel tags and clear GIFs, which either separately or combined with cookies gather information about your use of websites and your interaction with e-mail to recognize the data being processed on your computer, as is the case with cookies, time and date when the site and its sections are viewed.

The different types of cookies we use to obtain identifying data and details related to your purchasing habits and use of the Services on the Internet are:

Essential Cookies: We use these technologies to enable an appropriate use of our Services, therefore these cookies cannot be deactivated, for they are necessary to allow you to use the functionalities of our websites and technological tools.
Cookies used to recognize your preferences and experience: by using these technologies we are able to retrieve your browsing hours, time spent browsing our website, sections viewed, and websites accessed prior to visiting ours. These cookies allow us to remember your preferences, browsing choices and personalized features.
Cookies for performance and analysis purposes: We may use our own and third-party cookies to obtain data of technical and statistical nature that allow us to identify the way in which you use our services in order to improve their performance and future developments.
Own- and third-party advertising cookies: We may place our own and third party advertising cookies (such as business partners and Group Companies) in order to gather information pertaining to your shopping, consumption and website viewing preferences so as to show you advertising we deem relevant to you.
Other data: Additionally, as part of our internal processes for improving our products and services, we may, on occasion, gather anonymous responses through surveys and requests related to the use of our products and services. Occasionally and when necessary, we may implement data anonymization techniques in order to perform certain predictive and statistical studies based on the information generated from using our Services.

Some of the cookies we use on our Website are necessary to enable its proper operations and cannot be deactivated from our systems.

Some of the cookies we use on our Website are necessary to enable its proper functioning and cannot be deactivated from our systems.

However, you may choose to deactivate the non-essential cookies by following the appropriate procedure for the browser you use when accessing our Website:

(i) Internet Explorer: Tools -> Internet options -> Privacy -> Settings. For more information, please visit this link

(ii) Firefox: Tools -> Options -> Privacy and Security. For more information, please visit this link.

(iii) Chrome: Settings -> Security verification and/or -> Privacy and security. For more information, please visit this link.

(iv) Safari: Preferences -> Security. For more information, please visit this link.

(v) Opera: Settings -> Privacy, search and services and/or Site permissions. For more information, please visit this link.

Through your web browser, you may also view the cookies on your device and delete them as you see fit.

Additionally, please be aware that our Services also use cookies for mobile devices, so if you wish to disable such cookies, we recommend that you follow the instructions specified for your mobile device by the developer of the web browser.

Use of personal data

In case you are our customer, Rotoplas shall process your personal data for the following purposes: (i) to identify and/or register you as a customer or user of our goods, products and services, including the use of Rotoplas websites and/or applications and verify your identity in accordance with our internal procedures or those required by applicable regulations; (ii) to determine your geographical location or position through the devices you are using to access our websites and/or applications; (iii) to communicate with you; (iv) to contact you through phone calls, sending e-mail communications, short messages and other physical and/or electronic means of communication; (v) to send information and/or merchandise to you; (vi) for statistical purposes; (vii) to review and respond to your comments; (vii) to keep the security of our networks, electronic communications services and applications, detect failures or technical errors in the transmission of electronic communications as well as to ensure the security of our technological infrastructure; (viii) to perform billing and collection activities and to process payments through the methods and mechanisms enabled by Rotoplas; (ix) to provide technical and service usage reports, predictions and analyses regarding the use and quality of the Services; (x) to address and follow up on investigations and reviews of complaints and/or claims related to the detection, prevention and control of activities that may contravene the provisions of applicable regulations and/or the Services we offer; and (xi) to comply with obligations under the legislation in force.

Rotoplas shall process your personal data in order to perform any or all the secondary purposes mentioned below:

To keep you informed of the launch or changes of new products, goods, services, promotions and/or offers from Rotoplas in line with your interests.
To perform mass data analysis techniques for profiling activities by combining the information provided by you, information obtained from publicly available sources, such as social networks, and information which may be inferred or obtained as a result of the application of a variety of data analysis technologies. The foregoing for the purpose of contacting you and sending you advertising, promotional and/or informational materials that we believe may be of interest to you;
To publish any stories you wish to share;
To invite you to take part in events, games, promotions, and contests.
To create consumer profiles and habits so that our business partners can contact you and send you advertising, promotional and/or informational materials that they believe may be of interest to you and/or so that they can assess, on the basis of their internal procedures, whether you are likely to obtain the service you have requested from such third party;

If you do not want Rotoplas to process your personal data for one or more of the purposes described in this section, please send an e-mail to privacy.mx@rotoplas.com. You may change your options at any time.

It is important that you keep in mind that, in case you give your consent, it shall remain valid even when the legal relationship between you and Rotoplas is terminated, and this means that Rotoplas may continue to process your personal data necessary to fulfill the above secondary purposes.

When applying for a job position, Rotoplas shall process your personal data to perform the following primary and necessary activities:

To identify you;
To contact you through a variety of electronic means of contact that you provide;
To verify that you have the skills and aptitudes to perform the job in accordance with the requirements of the job profile;
To perform employment investigations and to request references from you;
To request employment references of you, to the contacts you provide;
To conduct socioeconomic studies;
To contact you and inform you about the recruitment and selection processes;
To make, as applicable, a financial offer; and
To verify the accuracy of the information you provide.
To inform you about different employment options that fit your profile.
To comply with obligations set forth in the applicable regulations.

If you are hired, such data shall then become part of your personal employment file.

The personal data requested by Rotoplas in the event of a health contingency may be processed for the following purposes:

To give you access to Rotoplas' facilities;
To provide you with guidance and information regarding the prevention of health contingencies.
To become aware of information related to the health status of the collaborator/visitor, such as symptoms, illnesses, care, vaccinations, type of vaccination, and doses received.
To have a record and/or database of contacts of individuals with symptoms and/or who have tested positive for the disease;
To send notifications through our official application, or any other means, in case there is confirmation of having been near or in contact with a symptomatic person and/or a person who has tested positive for a specific disease within our facilities.
To determine what percentage of the company’s personnel is vaccinated;
To assess whether an employee is able to continue working or whether they are considered part of vulnerable population;
To determine the employee's manner of incorporation, whether it shall be on-site, home office or mixed;
To determine whether an employee is able to perform their duties within our facilities;
To provide information and support to a staff member, in case any side effects of the vaccine administered to them is announced;
For generating statistical studies and research activities, and
To perform preventive and necessary actions for the prevention and mitigation of diseases and health contingencies, as well as to ensure the health and safety of you and any third parties within our facilities.
To cooperate with competent authorities in addressing health contingencies.
To comply with applicable health obligations, as well as with the requirements of competent authorities in cases of health emergencies.

To whom shall we share your information?

Rotoplas may disclose, without requiring your consent, the necessary personal data to competent authorities when legally required; to third parties, both national and foreign, involved in providing the products and/or services requested by you; as well as to companies of Grupo Rotoplas, which operate under the same privacy policies and controls in order to comply with the purposes informed in this Privacy Notice.

ARCO Rights and procedure to exercise them

Either you or your legal representative may exercise any of the rights of access, rectification, cancellation or opposition (hereinafter "ARCO rights"), as well as to revoke your consent for the processing of your personal data by sending an e-mail to the Rotoplas Privacy Officer at the following e-mail address: privacy.mx@rotoplas.com

Please be advised that said ARCO rights and/or revocation of consent can only be exercised by the Data Subject or their legal representative upon proof of identity, which is why the communication you send us must be accompanied by a copy of any of the following official identification documents: INE, Passport or Migratory Document evidencing the foreigner's legal presence in the country.

Likewise, pleased be advised that that in order for your request to proceed, it is required that you provide all the information listed below, which shall be used to prove your identity:

PERSONAL INFORMATION OF DATA SUBJECT Full name, complete mailing address, phone number, email address (to which communications regarding your request shall be sent).
INFORMATION OF THE LEGAL REPRESENTATIVE (ONLY IF APPLICABLE): Full name. In case of being the legal representative of a Data Subject, the corresponding public deed must be attached in original to such request, or as applicable, a power of attorney signed before two witnesses.
ARCO RIGHTS: State the right(s) you wish to exercise: Access, rectification, cancellation and/or opposition. Furthermore, you must provide a description of the personal data for which you are seeking to exercise the right(s) outlined above and/or any other comments that may help us to better address such right.
OTHER NECESSARY DOCUMENTS: Please submit any documentation that you deem may support your request and help us to process it accordingly. Specifically, when requesting the rectification of personal data (incorrect data, correct data and supporting documents).

In case the information provided in your written request is incorrect or insufficient, or if the corresponding accreditation documents are not provided within five (5) business days after receiving your request, the Rotoplas Privacy Officer may require you to provide such necessary elements or documents to process it. You will have ten (10) business days to comply with such request, starting from the day after it is received. If you fail to respond within such period, the corresponding request shall be deemed as not submitted.

The Rotoplas Privacy Officer shall communicate the decision made within a maximum period of twenty (20) business days from the date on which your request was received, so that, if approved, you can make the request effective within fifteen (15) business days after the decision is communicated to you. Such communication shall be sent electronically to the e-mail address specified in your letter.

How can you restrict the use and/or disclosure of your personal data?

You may restrict the use or disclosure of your personal data by sending your request to Rotoplas, at the address privacy.mx@rotoplas.com. In case your request is accepted, you shall be registered in Rotoplas' own exclusion list.

Changes to the Privacy Notice

Rotoplas reserves the right to update this policy in order to adapt it to legislative or jurisprudential developments and industry practices. In such event, said adopted changes shall be announced on this page with reasonable notice prior to their implementation.

Any changes to this Privacy Notice can be viewed at: http://www.rotoplas.com.

Country-specific Provisions

In addition, please be advised that, due to the nature of the services we provide in the different jurisdictions in which we operate, specific personal data protection provisions may apply, as specified in this document's Appendix. The provisions of this Privacy Notice shall prevail over the country/region’s specific provisions of the Appendix, unless otherwise required by applicable data protection laws and, in particular, by applicable national data protection laws.

Last updated on: May/26/2022.

By providing their personal data to Rotoplas, the Data Subject expressly acknowledges and accepts this Notice, however, such acknowledgement may be amended or adjusted, and consents to Rotoplas to proceed with the processing of their personal data in the manner explained herein. Should the Data Subject not accept this Notice, they may exercise their rights conferred by Law, as described above.

APPENDIX – COUNTRY-SPECIFIC PROVISIONS

Argentina

Rights:

Pursuant to the provisions of Law 25.326 and its Regulations, you may exercise your rights of information, access, rectification, updating or deletion by following the procedure set forth in the Rotoplas Privacy Notice.

Rotoplas may deny access, rectification or deletion based on the protection of the defense of the Nation, public order and public safety, or the protection of third parties' rights and interests.

The deletion of your personal data shall not proceed if such deletion might cause damage to the rights or legitimate interests of third parties, or if there is a legal obligation for the data to be kept.

Brazil

Manner and duration of processing:

The duration of the processing shall match the period necessary to comply with the obligations arising from the legal relationship with you or, as the case may be, as far as you do not revoke your consent to the processing of your personal data, in the event that the latter is required.

Rights:

Pursuant to the provisions of Law 13.709, General Data Protection Act, you may exercise the rights of acknowledgement that your data is being processed, access, rectification, anonymization, portability, deletion, information regarding the shared use of your data, information about the possibility of not granting your consent and the consequences arising therefrom, revocation of consent and review of decisions based on automated data processing affecting your interests by following the procedure set forth in the Rotoplas Privacy Notice.

Costa Rica

Mandatory nature of your responses and consequences of refusal to provide your data:

In case you refuse to provide your personal data, Rotoplas shall not be able to identify you, contact you and provide you with the services you require, nor to enter into a legal relationship with you and comply with the obligations arising therefrom. By virtue of the foregoing, it is necessary that you provide appropriate answers to the questions you are required to answer on our website.

Rights:

Pursuant to the provisions of Law 89.68 and its Regulations, you may exercise your rights of information, access, rectification, updating or deletion by following the procedure set forth in the Rotoplas Privacy Notice.

The above rights may be limited for State security purposes; security purposes and the exercise of public authority; prevention, prosecution, investigation, detention and repression of criminal offenses, or of breaches of professional ethics; operation of databases used for statistical, historical or scientific research purposes, when there is no risk of individuals being identified; proper provision of public services and the efficient regular activity of the Administration, by official authorities.

Ecuador

Rights:

Pursuant to the provisions of the Personal Data Protection Law and its Regulations you may exercise the rights of information, access, rectification and update, deletion, opposition, portability, treatment cessation, and not to be subject to a decision based solely or partially on automated assessments regarding the processing of your personal data by following the procedure set forth in the Rotoplas Privacy Notice.

The exercise of the above rights shall not proceed in circumstances stipulated in article 18 of the Law.

The duration of your data processing shall match the period necessary to comply with the obligations arising from the legal relationship with you or, as the case may be, as far as you do not revoke your consent to the processing of your personal data, in the event that the latter is required.

El Salvador

Mandatory nature of your responses and consequences of refusal to provide your data:

Rights:

Pursuant to the provisions of the Personal Data Protection Law and Habeas Data you may exercise the rights of access, rectification, updating, inclusion, deletion, opposition, and not to be subjected to a legally binding decision that may significantly impact you regarding the processing of your personal data by following the procedure set forth in the Rotoplas Privacy Notice.

The exercise of the above rights shall not proceed in circumstances stipulated in article 26 of the Law.

Security measures:

Here at Rotoplas, we are committed to administrative, physical and technical security measures for the protection of your personal data. We recommend you not to disclose your personal data, including usernames and passwords, to anyone. At all times, the user is solely and fully responsible for maintaining the confidentiality of their personal data.

United States

Rights:

Under the provisions of the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) you have the right to know or request the following: Whether your data is being gathered; the categories and specific personal data Rotoplas has gathered about you; the sources from which Rotoplas obtained your personal data; the purpose for which your personal data may be used; the third parties to whom Rotoplas may sell your personal data, if applicable; to request that your personal data not be sold; to correct your information (right of rectification); to know for how long the data shall be kept; to restrict the use and disclosure of your personal data, and to request that Rotoplas deletes information about you as an individual. In order to exercise the above rights, you must adhere to the procedure set forth in the Rotoplas Privacy Notice.

Nicaragua

Mandatory nature of your responses and consequences of refusal to provide your data:

Rights:

Pursuant to the provisions of Law No. 787, you may exercise your rights of access, rectification, modification, deletion, complementation, inclusion, updating and cancellation of your personal data by following the procedure provided in the Rotoplas Privacy Notice.

The exercise of the above rights shall not proceed in circumstances stipulated in article 20 of the cited Law.

Peru

Rights:

Pursuant to the provisions of Law 29733 and its Regulations, you may exercise your rights of information, access, updating, inclusion, rectification, deletion and objective processing of your personal data by following the procedure set forth in the Rotoplas Privacy Notice.

The exercise of the above rights may be denied for reasons grounded on protecting the rights and interests of third parties or when it might hinder ongoing judicial or administrative proceedings related to the investigation of tax or social security obligation compliance, criminal investigations on the perpetration of misdemeanors or crimes, the development of health and environmental control functions, verification of administrative infractions, or when so provided by law.

Mandatory nature of your responses and consequences of refusal to provide your data: