USER AND CUSTOMER PRIVACY NOTICE

 
 
 
CMS ONLINE SERVICES, S.C. (HEREINAFTER IDENTIFIED AS ("CleverClick 360") AS THE COMPANY RESPONSIBLE AND RESPONSIBLE FOR THE PERSONAL DATA, MAKES AVAILABLE THE PRESENT PRIVACY NOTICE IN ORDER TO GUARANTEE THE RIGHT OF THE OWNERS TO INFORMATIVE SELF-DETERMINATION.
 
THIS PRIVACY NOTICE IS MADE AVAILABLE TO THE OWNERS ON THE WEBSITE WWW.CLEVERCLICK360.COM (HEREINAFTER REFERRED TO AS THE WEBSITE).

I. RESPONSIBLE PARTY: IDENTITY AND ADDRESS.

The party responsible for processing personal data is CMS ONLINE SERVICES, S.C. (hereinafter, CleverClick 360), located at Tlaxcala 178, Hipódromo, 06100, Cuauhtémoc, CDMX. The entity commits to respecting the provisions of this Privacy Notice, as well as the Federal Law for the Protection of Personal Data Held by Private Parties (hereinafter the "Law"), its Regulations, and the Privacy Notice Guidelines.

 

I.PERSONAL DATA SUBJECT TO PROCESSING.

Under this Privacy Notice, CleverClick 360 informs the holder that it will process the following personal data:

I.I. Users:

a) Identification Data. 

b) Contact data. 

c) Browsing data.

I.II. Clients: 

a) Identification Data. 

b) Contact data.

c) Financial and property data.

Additionally, it is informed to the holder that CleverClick 360 will not process Sensitive Personal Data.

In terms of Article 8 of the Law, the holder expressly consents to CleverClick 360 processing their personal data, including financial and property data.

II. PURPOSES OF PERSONAL DATA PROCESSING. 

CleverClick 360 will process the holder's personal data for the following purposes:

II.I. Users:

A) Primary Purposes:

  1. Maintain communication with the holder regarding the services offered by CleverClick 360 to the general public.
  2. To send you the proposals of those services that are of your interest in CleverClick 360 .

B) Secondary purposes: 

  1. Analyze, evaluate habits, as well as improve the Holder's browsing experience on the CleverClick 360.
  2. Send promotional and advertising material about the products and services marketed by CleverClick 360.

II.II. Clients: 

A) Primary Purposes: 

  1. Verify the holder's identity and confirm the accuracy of personal data provided to CleverClick 360.
  2. Contact the holder to send proposals for services offered by CleverClick 360 and follow up on these.
  3. Carry out the provision of services contracted by the holder. 
  4. Create, manage, and administer the tools enabling the provision of services acquired by the holder at CleverClick 360.
  5. Issue and keep invoices for operations and services contracted by the holder at CleverClick 360
  6. Maintain necessary communication with the holder to fulfill contractual obligations. 
  7. Keep the holder's information up to date.
  8. Maintain a record in CleverClick 360's accounting and administrative systems about the holder, the services provided, and payments made or to be made.
  9. Address requests for rights from the holder at CleverClick 360.

B) Secondary purposes:

  1. Contact the holder to notify website updates, reports on the processing and status of their personal data.
  2. Prepare reports on the holder's activity at CleverClick 360.
  3. Send promotional and advertising material about the products and services marketed by CleverClick 360.

III. MECHANISMS FOR THE HOLDER TO EXPRESS THEIR REFUSAL FOR THE PROCESSING OF THEIR PERSONAL DATA FOR SECONDARY PURPOSES.

In the event that the holder does not want their personal data to be used for all or some of the secondary purposes contained in the previous section, they must send an email to the address [email protected] with the subject "Refusal of Processing for Secondary Purposes." In the email, the holder must specify for which purposes they wish to express their refusal, as well as their identification data, so that their request can be fulfilled.

IV. TRANSFER OF PERSONAL DATA.

The holder is informed that CleverClick 360 will carry out the following transfers of their personal data:

Third Party Purpose ConsentPurposeConsent
Judicial and/or administrative authorities.Compliance with legal provisions and exercise of CleverClick 360's rights.Not necessary.

V. MEANS AND PROCEDURE FOR THE EXERCISE OF THE RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION, OR OPPOSITION.

CleverClick 360 recognizes the possibility for the holders to exercise ARCO Rights over their personal data, which consist of the following:

A. Right of Access: To know which of their personal data CleverClick 360 holds and the purposes of its processing.

B. Right of Rectification: To request the correction of their personal data in case they are outdated, inaccurate, erroneous, or incomplete.

C. Right of Cancellation: Request for the deletion of any record or copy of their personal data, whether physical or electronic.

D. Derecho de Oposición: Solicitar el cese en el uso de sus Datos Personales.

The exercise of the rights described in this section is carried out through a written request sent by email to the address [email protected] with the subject "Exercise of ARCO Rights." The aforementioned email address corresponds to the department that will process the requests in question and can be contacted by the holders at any time.

The holder must provide the following information:

  1. Full name and address. 
  2. Clear and precise description of the personal data regarding which they intend to exercise any of the ARCO Rights, in addition to any document that allows locating them. 
  3. Indication of the ARCO Right they wish to exercise. 
  4. In case of a request for data rectification, the modifications to be made should be indicated, and the documentation justifying the reason for the requested changes should be provided.

Additionally, the request must be accompanied by the following documents:

  1. Copy of the official identification of the holder or their representative. 
  2. Document and/or information that proves that the personal information is in possession of CleverClick 360.
  3. In the event that the holder does not personally present the request, whoever does so must accredit their representation, through a public deed or power of attorney signed before two witnesses, along with the official identifications of the holder and representative.

Once the holder's request is received, CleverClick 360 will send an acknowledgment of receipt by email. Subsequently, it will respond to the holder's request by email within a period not exceeding 20 (twenty) business days from the date of receipt. This period will only be applicable as long as CleverClick 360 has sufficient information to address the request, in terms of what is established in the following paragraph.

The holder must consider that, in order to have sufficient elements to address their petition, CleverClick 360 may request additional information within 5 (five) business days following the receipt of the request. From CleverClick 360's request, the holder will have a period of 10 (ten) business days to address this requirement. In this case, the period of 20 (twenty) business days mentioned in the previous paragraph will begin to run the day after the holder has addressed CleverClick 360's request.

If the request is declared appropriate and the holder has accredited their personality and the ownership of the ARCO Right they intended to exercise, the access to personal data, the requested changes, the cancellation, or the response to the opposition will be made within a maximum period of 15 (fifteen) business days from the date on which the response to the request was given. 

In the case of access requests to personal data, their delivery will proceed upon accreditation of the identity of the applicant or representative, as appropriate. This delivery will be made in simple copies at the address mentioned in this document, or in electronic documents to the email address from which the request was sent.   

In the event that the purpose of the request is opposition, the processing of personal data will cease the next business day following the date on which the affirmative response was communicated to the holder.

VI. MEANS AND PROCEDURE FOR REVOCATION OF CONSENT.

At any time and for any reason, the holder may revoke the authorization given to CleverClick 360 for the processing of their personal data. CleverClick 360 states that, for the fulfillment of certain purposes, the revocation of consent could mean the impossibility of continuing the relationship between the holder and CleverClick 360.

In this case, the revocation of consent will be carried out according to the following procedure:

A. Sending an email to the address [email protected] with the subject "Revocation of Consent."

B. In the body of the message, the following should be indicated:

  1. The full name of the holder. 
  2. Date from which they wish the revocation to be effective. 
  3. Copy of the official document proving their identity, which should be attached to the request. In the event that the holder does not personally present the request, whoever does so must accredit their representation, through a public deed or power of attorney signed before two witnesses, along with the official identifications of the holder and representative.

CleverClick 360 will respond to the request by email within a period of 20 (twenty) business days from the date of receipt. This period will only be applicable as long as CleverClick 360 has sufficient information to address the request, in terms of what is established in the following paragraph.

The holder must consider that, in order to have sufficient elements to address their petition, CleverClick 360 may request additional information within 5 (five) business days following the receipt of the request. From CleverClick 360's request, the holder will have a period of 10 (ten) business days to address this requirement. In this case, the period of 20 (twenty) business days mentioned in the previous paragraph will begin to run the day after the holder has addressed CleverClick 360's request.

VII. RESPONSIBLE FOR PROCESSING ARCO RIGHTS REQUESTS, LIMITATION OF USE AND DISCLOSURE, AS WELL AS REVOCATIONS.

In case the Holder wishes to revoke their consent, limit the use and disclosure of their information, as well as to Access, Rectify, Cancel or Oppose the Processing of their Personal Data, they must do so through the Department designated by CleverClick 360, whose contact details are listed below:

A. Responsible: PERSONAL DATA PROTECTION DEPARTMENT OF CleverClick 360.

B. Email: [email protected]

VIII. MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA.

CleverClick 360, in order to ensure the protection of the Personal Data of the Holders, commits to the execution of legal acts, the adoption of privacy policies, Personal Data protection, and information security requirements within its organization, as well as implementing technological, physical, and administrative security measures.

CleverClick 360 stores personal information in databases with limited access located in controlled facilities with security mechanisms. CleverClick 360 commits to treating the information provided by the Holder as confidential.

Additionally, CleverClick 360 provides alternative mechanisms to the exercise of ARCO Rights for Holders to limit the use and disclosure of their Personal Data. In this regard, it is made known to the Holder that, to avoid receiving advertising, they can register in the Public Registry to Avoid Advertising (REPEP) of the Federal Consumer Protection Agency (PROFECO), at the link https://repep.profeco.gob.mx/.

In case the Holder wishes to know more about what is addressed in this section, they can send an email to the address [email protected] with the subject "Limitation of Use or Disclosure", expressing their doubts, comments, and suggestions regarding the object of this notice.

IX. STORAGE PERIOD OF PERSONAL DATA. 

In compliance with the principle of quality, all the Personal Data of the Holder will be safeguarded for the time necessary to fulfill the purposes for which they were collected. Subsequently, there will be a blocking period prior to their cancellation.

X. CHANGES TO THE PRIVACY NOTICE. 

It is made known to the Holder that this Privacy Notice may be modified in the time and manner that CleverClick 360 determines, always in accordance with the legislation on the matter.

CleverClick 360 informs the Holders that the changes to this will be notified through the publication of its updated version on the website and/or by sending an email to the address provided by the Holder.

XI. COOKIE POLICY.

Cookies are text files that are stored on the computer equipment used by the Holder when using the website. Cookies help CleverClick 360 to provide a better experience when browsing the website and allow to improve such experience.

CleverClick 360 CleverClick 360 uses cookies on its website, however, each Holder can accept or reject the use of these through the configuration for such purpose on their used devices. Nevertheless, it is important for the Holder to consider that, if they do not accept the use of cookies, some functionalities of the website may not be available.

To deactivate the use of cookies, the Holder can consult the following links:

Firefox
https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we
Google Chrome
http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647
Microsoft Edge https://support.microsoft.com/es-mx/help/17442/windows-internet-explorer-delete-manage-cookies
 Opera http://help.opera.com/Windows/11.50/es-ES/cookies.html
 Safari
http://www.apple.com/legal/privacy/es/cookies/

XII. LAST UPDATE DATE: October 30, 2023. 30 de octubre de 2023.