Privacy Notice for Commercial Purposes

The legitimate, controlled, and informed processing of your personal data is of vital importance for achieving the corporate objectives of ETN TURISTAR LUJO, S.A. DE C.V., across all business areas. We reaffirm our commitment to your privacy and your right to informational self-determination. Therefore, in compliance with the Federal Law on Protection of Personal Data Held by Private Parties, we provide you with our PRIVACY NOTICE.

This notice applies to all products, services, programs, and/or websites operated by ETN TURISTAR LUJO, S.A. DE C.V., depending on the nature of the Personal Data collected and in accordance with current legislation on privacy and personal data protection. ETN TURISTAR LUJO, S.A. DE C.V. may publish new specific Privacy Notices or updates, which may or may not require the express consent of the data subject. However, through our website: ../../../english/ or at our central offices, the applicable privacy policies for the Personal Data provided to us are made publicly available.

At ETN Turistar, we make responsible use of personal information, protecting the privacy of Users who have entrusted us with their data and taking the necessary measures to ensure the security of our system.

  1. NAME AND ADDRESS OF THE DATA CONTROLLER

    This section covers the disclosure and processing of your Personal Data. This includes data disclosed through our websites, technological tools, or directly to our representatives.

    The data controller for any relationship arising from the use of our products and/or services is ETN TURISTAR LUJO, S.A. DE C.V.. We are a company incorporated under the laws of the United Mexican States.

    Our central office is located at:

    • Capital Reforma, Paseo de la Reforma number 250

    • Tower A, 23rd Floor, Colonia Juárez

    • Cuauhtémoc Borough, Postal Code 06600, Mexico City

    For any information regarding this Privacy Notice, or to exercise any of your rights related to your Personal Data, please contact our Privacy Department.

    You can reach us via email at [email protected] or by phone at 800 8000 386. Our hours are Monday to Friday, from 9:00 a.m. to 6:00 p.m.

  2. PERSONAL DATA COLLECTED

    To fulfill the purposes described in this Privacy Notice, ETN TURISTAR LUJO, S.A. DE C.V. may collect and, where applicable, process the following personal data, based on the legal or non-legal relationship that exists with the Data Subject:

    • Full name

    • Age

    • Date of birth

    • IFE or INE

    • Address

    • Email address

    • Contact phone number(s): mobile, work, home

    • Social media accounts

    • Employment data

    • URL and IP information

    • Video recordings

    • Web Beacons

    • Cookies

    • Federal Taxpayer Registry (RFC)

  3. PURPOSES FOR THE USE OF PERSONAL DATA

    The personal data we collect from you is necessary to fulfill the obligations, relationship, and/or provision of services that exist or may exist between the Data Subject and ETN TURISTAR LUJO, S.A. DE C.V., which uses, stores, transmits, or transfers such data to the extent permitted by law, in order to comply with obligations arising from the legal or non-legal relationship established with the Data Subject.

    We also inform you that the facilities, branches, and corporate offices of ETN TURISTAR LUJO, S.A. DE C.V. are equipped with video surveillance systems, through which images and audio of the Data Subject may be obtained for purposes of identification, control, and security of users, suppliers, and personnel of ETN TURISTAR LUJO, S.A. DE C.V.

    Below is a list of the purposes for which we will process your Personal Data:

    • Identification

    • Contact

    • Location

    • User service history

    • Fulfillment of contractual obligations

    • Control

    • Security

    • Service improvements

    • Billing

    • Rectify commercial relationship

    • Improve our commercial and promotional initiatives (marketing)

    • Send information or messages about new products and/or services

    • Respond to your request for information, products, or use of services, including exclusively the services of Destinos Parhikuni, S.A. de C.V.

    • Address any complaint, question, or comment

    • Send notifications, notices, promotional materials, or advertising about our products or services to the extent permitted by applicable law

    • Send information and news about our services, as well as communications or advertising from ETN TURISTAR LUJO, S.A. DE C.V. or its related companies

    • Create databases for statistical purposes, research, and development of new products or services

    • Transfer to other participants in attended events for commercial, professional, and business purposes, as well as to service providers whose products and services are applicable to the sector

    • Send notifications of changes to this privacy notice

  4. PUBLIC REGISTRIES

    The Public Registry of Consumers, Users, and other related entities mentioned in provisions concerning the Protection of Personal Data will remain in effect and be governed in accordance with the applicable laws and regulations, along with the rights they establish.

  5. TRANSFER AND DISCLOSURE OF PERSONAL DATA

    As part of regular business operations and to fulfill the purposes described, ETN TURISTAR LUJO, S.A. DE C.V. may share some or all of your personal data with third parties, whether domestic or foreign.

    ETN TURISTAR LUJO, S.A. DE C.V. will ensure, through the signing of agreements and the adoption of other binding documents, that such third parties maintain appropriate administrative, technical, and physical security measures to safeguard your personal data, and that they use your data only for the purposes for which it was collected and in accordance with this Privacy Notice.

    ETN TURISTAR LUJO, S.A. DE C.V. may share all or part of your Personal Data with entities authorized under Mexican law to oversee the execution of our activities and product operations. These entities may or may not process your Personal Data on behalf of ETN TURISTAR LUJO, S.A. DE C.V., in accordance with the purposes and uses outlined in this Privacy Notice. Additionally, ETN TURISTAR LUJO, S.A. DE C.V. reserves the right to share your Personal Data with administrative, judicial, or governmental authorities of any kind within the United Mexican States.

    ETN TURISTAR LUJO, S.A. DE C.V. may transfer your Personal Data to the following parties:

    • Advisors and collection service providers.

    • Any acquirer of the company, parent companies, affiliates, or subsidiaries.

    • External professional advisors.

    • Providers offering services, technical support, and information technologies.

    • Any third party acting on behalf of ETN TURISTAR LUJO, S.A. DE C.V.

    ETN TURISTAR LUJO, S.A. DE C.V. may disclose Personal Data to companies responsible for receiving, safeguarding, and processing the Data Subject’s personal data in accordance with this Privacy Notice.

    Except for these cases, ETN TURISTAR LUJO, S.A. DE C.V. will not share or transfer your Personal Data to third parties unless provided for by the Federal Law on Protection of Personal Data Held by Private Parties or any other applicable legislation or regulation.

  6. SECURITY MEASURES

    ETN TURISTAR LUJO, S.A. DE C.V. 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 authorized personnel of ETN TURISTAR LUJO, S.A. DE C.V. who have met and observed the corresponding confidentiality requirements may participate in the processing of your personal data.

    Authorized personnel are strictly prohibited from:

    • Allowing access to unauthorized individuals.

    • Using your personal data for purposes other than those established in this Privacy Notice.

    The confidentiality obligation of those involved in processing your personal data remains in effect even after their relationship with the company has ended.

  7. STORAGE OF YOUR PERSONAL DATA

    ETN TURISTAR LUJO, S.A. DE C.V. may store your Personal Data in databases located in the United Mexican States or abroad without limitation, provided that reasonable commercial policies and technology and security standards have been implemented to protect the information you have provided.

  8. CHANGES TO THE PRIVACY NOTICE

    ETN TURISTAR LUJO, S.A. DE C.V. reserves the right to modify the terms and conditions of this Privacy Notice. Any changes will be communicated through the means ETN TURISTAR LUJO, S.A. DE C.V. deems most appropriate, which may include email, media announcements, direct communication, and/or a notice on our website or at our branches.

    ETN TURISTAR LUJO, S.A. DE C.V. and the Data Subject acknowledge that this Privacy Notice is of indefinite validity. However, ETN TURISTAR LUJO, S.A. DE C.V. will keep this Notice updated.

    ETN TURISTAR LUJO, S.A. DE C.V. recommends that the Data Subject regularly review this document to stay informed about any changes. Any alterations or modifications to this Privacy Notice will become effective immediately upon publication at our central offices, without prejudice to the use of other means by ETN TURISTAR LUJO, S.A. DE C.V. to disseminate such updates.

    Once the changes are made, it will be presumed that the Data Subject who continues to use or request services, or engages in the activities that originated the relationship with ETN TURISTAR LUJO, S.A. DE C.V., is fully aware of, has read, and has consented to the revised Privacy Notice.

  9. CONSENT

    The Data Subject expresses and consents to this Privacy Notice in accordance with the Federal Law on Protection of Personal Data Held by Private Parties, by not objecting to the Privacy Notice. No data will be processed until five days after it has been provided by the user and the user has not expressed their refusal.

  10. ARCO RIGHTS

    You may request access to your data, rectify it, cancel it, oppose its processing, limit its use or disclosure, or revoke your consent, in accordance with the Federal Law on Protection of Personal Data Held by Private Parties and other applicable provisions. To exercise these rights, you must contact the Privacy Department via the email and/or phone number listed above in our contact information.

    Under applicable law, any request to exercise the aforementioned rights must include:

    1. Full name and address, which are essential to respond to your request.

    2. Documents proving your identity or, if applicable, legal representation of the person making the request on your behalf.

    3. A clear and precise description of the Personal Data you wish to access, rectify, cancel, or oppose, and any other element that facilitates locating your data.

    4. Any other requirement established by the Federal Law on Protection of Personal Data Held by Private Parties and/or other applicable provisions.

    At any time, you may request the suspension or cancellation of commercial messages, notices, or information about new products through our Privacy Department.

    If you request the rectification of personal data, you must also specify the changes to be made and provide documentation supporting your request.

    You will receive a response to your request within 10 (ten) business days from the date it was received. This period may be extended by 5 (five) additional business days in cases permitted by law. If the request is deemed valid, the necessary measures will be carried out within 15 (fifteen) business days following the date the response is communicated.

    The Data Subject must cover justified shipping costs or reproduction costs in copies or other formats. Depending on whether the information is delivered electronically or physically, ETN TURISTAR LUJO, S.A. DE C.V. will require a mailing address to send the information.

    When the data is no longer necessary to fulfill the purposes outlined in this Privacy Notice and applicable legal provisions, it must be canceled, blocked, and deleted by law.

    Requests will not be valid if the above requirements are not met.

    1. There is a legitimate reason and your specific situation requires it, which must justify that even if the processing is lawful, it must cease to prevent harm to the data subject.

    2. You wish to express opposition to the processing of your personal data so that it is not used for specific purposes.

    3. The processing is not necessary to comply with a legal obligation imposed on the data controller.

    If you have exercised your right to oppose the processing of your Personal Data, ETN TURISTAR LUJO, S.A. DE C.V. will add your Personal Data to an Exclusion List in accordance with the law.

  11. PROCEDURES FOR BLOCKING AND DELETION OF PERSONAL DATA

    Once the data has been canceled, ETN TURISTAR LUJO, S.A. DE C.V. will retain the Data Subject’s personal data for one additional month for clarification and preparation for deletion. After this period, ETN TURISTAR LUJO, S.A. DE C.V. will permanently block the Data Subject’s personal data, with no possibility of locating or contacting the individual.

    If the Data Subject engages in another transaction with ETN TURISTAR LUJO, S.A. DE C.V., it must be initiated as if no prior relationship existed. This is subject to the Privacy Policies regarding the retention of information by law or authority.

    Personal data that has fulfilled its purpose but cannot be canceled and/or deleted due to legal or contractual obligations will be blocked from the purposes to which it was previously subjected until it can be deleted. During this period, the data may only be stored and safeguarded, without further processing.

  12. COLLECTED PERSONAL DATA

    Consent may be revoked at any time without retroactive effect. To revoke consent, the Data Subject must send a written request to [email protected] including the following requirements:

    • The Data Subject’s name and address or another means to communicate the response to the request.

    • Documents proving identity, such as IFE and/or passport, or legal representation if applicable.

    • A clear and precise description of the relationship with the Company.

    • Supporting documentation for the request.

    • The request must be addressed to ETN TURISTAR LUJO, S.A. DE C.V.

    • Documents proving that the relationship with ETN TURISTAR LUJO, S.A. DE C.V. has ended.

    ETN TURISTAR LUJO, S.A. DE C.V. will issue a response confirming the revocation of consent or, if applicable, explaining the reasoning based on the specific case. The response will be issued within 15 (fifteen) days from the time the email is received by our server, and ETN TURISTAR LUJO, S.A. DE C.V. will issue an acknowledgment of receipt.

    Any subsequent request will have the same effect as an initial one, and both the Data Subject and ETN TURISTAR LUJO, S.A. DE C.V. will be subject to the same timeframes mentioned above.

    Requests will not be valid if the above requirements are not met.

  13. JURISDICTION

    This Privacy Notice, the processing of your Personal Data, and all related documents are governed by the Federal Law on Protection of Personal Data Held by Private Parties and other laws and regulations of the United Mexican States. Acceptance of this Privacy Notice or the continued request for services after the Notice has been published and made available implies express acceptance of its terms and submission to the courts of Mexico City for any dispute or claim arising from this Privacy Notice.

    I declare that I have read and understood this Privacy Notice and give my consent, where required, for the processing of my personal data under its terms. I confirm that I have informed the individuals whose personal data I have provided about the processing that will be carried out.