Human Resources Privacy Notice

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.

  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 in connection with an employment relationship or potential employment relationship.

    The data controller 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, if applicable, process the following personal data, based on the legal or non-legal relationship that exists with the Data Subject, including Sensitive Personal Data, as detailed below:

    • Full name

    • Age

    • Date of birth

    • Address

    • Marital status

    • Email address

    • Social media accounts

    • Contact phone numbers (mobile, work, home)

    • Tourism, sports, social, and entertainment preferences

    • CURP (Unique Population Registry Code)

    • RFC (Federal Taxpayer Registry)

    • Social Security Number

    • Employee number

    • Employee category and position

    • Salary, earnings, and deductions

    • Personal and family references

    • Information related to beneficiaries and/or economic dependents

    • Spouse’s and parents’ names

    • Spouse’s date of birth

    • Father’s name

    • Mother’s name

    • Medical history of the Data Subject, family members, beneficiaries, and/or economic dependents

    • Psychometric evaluation results

    • Technical evaluation results

    • Medical evaluation results

    • Blood type

    • Religious preferences

    • Medical certificates and treatment information

    • Video recordings

    • Academic degree and institution

    • Major/Specialization

    • School period

    • Degree status (in progress, incomplete, completed)

    • Name of last employer and city/town

    • Position held and duration

    • Subcontracted company

    • Reason for hiring

    • Name of the person being replaced

    • Date of hire

    • Position

    • Office

    • Work schedule

    • Information regarding job performance

    • IP address

    • URL information

    • Cookies

    • Web Beacons

    • Medical unit affiliation

    • Bank account number

    • Credit data from Infonavit, Fonacot, or any other social security benefit

  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 our facilities, branches, and corporate offices are equipped with video surveillance and/or audio recording systems. Therefore, images and audio of the Data Subject may be obtained through our security cameras for purposes of identification, control, and safety 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 and contact

    • Location

    • Employment history

    • Statistical purposes

    • Control and security

    • Rectify employment relationship

    • Respond to any complaint, question, or comment

    • Send notifications, notices, promotional materials or advertising, information, and news about our products or services from ETN TURISTAR LUJO, S.A. DE C.V. or its affiliated companies

    • Create databases for statistical purposes

    • Create administrative employee files

    • Create medical employee files

    • Payroll payment and management

    • Payment of benefits, salaries, bonuses, reimbursements, pensions, insurance, and others

    • Insurance contracting

    • Assign work tools and document/control the allocation of computing and communication assets

    • Internal audits

    • Create and assign work email accounts

    • Create company directory

    • Assign access credentials and passwords

    • Ensure compliance with confidentiality and other labor and tax obligations

    • Verify personal and employment references

    • Contact family members, economic dependents, and beneficiaries in case of emergency

    • Send information about providers offering products, services, and/or employment benefits

    • Send notifications of changes to this privacy notice

    The Data Subject is also responsible for the truthfulness, accuracy, and timeliness of the personal data published on their social media profiles or on the social media platforms of ETN TURISTAR LUJO, S.A. DE C.V., as well as for the degree of dissemination and access to such information that they allow or authorize third parties to have through those profiles.

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

    If you have requested the right to Object to the processing of Personal Data, ETN TURISTAR LUJO, S.A. DE C.V. will consider the following:

    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 Object to 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. REVOCATION OF CONSENT

    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 the identity of the Data Subject, 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 legal 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 fifteen (15) 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.