DelPaso Group

PRIVACY

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person. You may be asked to provide your personal information anytime you are in contact with DelPaso Group or an DelPaso Group affiliated company. DelPaso Group and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information

DelPaso Group may collect and how we may use it: What personal information we collect • When you contact DelPaso Group through any of it contact forms or including by social media or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, credit card information and profile information where the contact is via social media.

How we use your personal information

We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which DelPaso Group is subject, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by DelPaso Group or a third party to whom it may be necessary to disclose information. If you have questions about this legal basis you can contact the Mexican Data Protection Officer. • The personal information we collect allows us to keep you posted on DelPaso Group’s latest project announcements, new services, and upcoming events. If you don’t want to be on our mailing list, you can opt-out anytime by sending us an email requesting so. • We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of DelPaso Group ID account holders. • From time to time, we may use your personal information to send important notices, such as communications about new updates or changes to our terms, conditions, and policies. Because this information is important to your interaction with DelPaso Group, you may not opt out of receiving these communications. • We may also use personal information for internal purposes such as auditing, data analysis, and research to improve DelPaso Group’s products, services, and customer communications. • If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs. • If you apply for a position at DelPaso Group or we receive your information in connection with a potential role at DelPaso Group, we may use your information to evaluate your candidacy and to contact you. If you are a candidate, you will receive more information about how DelPaso Group handles candidate personal information at the time of application.

Source of your personal information where they are not collected from you We may have received your personal information from other persons if that person has shared their content with you, sent one of our websites links, or invited you to know DelPaso Group services or products. We may also validate the information provided by you when creating an DelPaso Group ID with a third party for security and fraud prevention purposes. If you are a potential candidate for employment with DelPaso Group, we may have received your personal information from third parties such as recruiters or external websites. We will use the personal information we receive to contact you about a potential opportunity or in evaluating your candidacy. If you did not provide us your personal information directly, we will inform you of the source when we first contact you regarding your candidacy. For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it: • We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an DelPaso Group product is used so that we can better understand customer behavior and improve our products, services, and advertising. • We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address. • With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve our apps. If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

DelPaso Group’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy. Ads that are delivered by DelPaso Group’s advertising platform may appear in DelPaso Group News and in the App Store. If you do not wish to receive ads targeted to your interests from DelPaso Group’s advertising platform, you can choose to enable Limit Ad Tracking, which will opt your DelPaso Group ID out of receiving such ads regardless of what device you are using. If you enable Limit Ad Tracking on your mobile device, third-party apps cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads in the App Store or News based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information. DelPaso Group also uses cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with DelPaso Group more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the DelPaso Group Online Store. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful shopping experience. Knowing someone using your computer or device has shopped for a certain product or used a particular service helps us make our advertising and email communications more relevant to your interests. And knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system, set up your iCloud service, and provide you with better customer service. If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your DelPaso Group mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the DelPaso Group website will not be available once cookies are disabled. As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. DelPaso Group may use this information in our marketing and advertising services. In some of our email messages, we use a “click-through URL” linked to content on the DelPaso Group website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties

At times DelPaso Group may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help DelPaso Group market to clients. When we do, we require those third parties to handle it in accordance with relevant laws. Personal information will never be shared with third parties for their marketing purposes. For example, when you purchase and activate your iPhone, you authorize DelPaso Group and your carrier to exchange the information you provide during the activation process to carry out service, including information about your device. If you are approved for service, your account will be governed by DelPaso Group and your carrier’s respective privacy policies.

Protection of Personal Information

DelPaso Group takes the security of your personal information very seriously. DelPaso Group online services such as the DelPaso Group Website and any other DelPaso Group’s Websites your personal information during transit using encryption such as Secure Socket Layer (SSL). When your personal data is stored by DelPaso Group, we use computer systems with limited access housed in facilities using physical security measures. When you use some DelPaso Group products, services, or applications or post on an DelPaso Group forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.