Privacy Policy

I. THE IDENTITY AND ADDRESS OF THE CONTROLLER WHO PROCESSES PERSONAL DATA

NEVER7LOST S.A. DE C.V., (hereinafter also referred to as the “Controller”, “Never7Lost” or “N7L”), with address to hear and receive notifications regarding personal data at Cerrada Presa Escolta 44 Interior 25, San Jerónimo Lídice, Alcaldía Magdalena Contreras, Postal Code 10200, Mexico City, in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties and the regulations derived therefrom, provides and makes available the following privacy notice for its clients or users of the app (hereinafter also referred to as the “owner” or “owners”).

II. PERSONAL DATA THAT WILL BE SUBJECTED TO PROCESSING

a. Identification and contact information.
b. Your pet’s information.
c. Identification and contact information of your pet’s veterinarian.
d. Data on distance traveled.
e. Beacon location data.
f. In the case of veterinarians, your name and professional license number.
g. Voice messages.

III. THE EXPRESS INDICATION OF THE SENSITIVE PERSONAL DATA THAT WILL BE PROCESSED

This Controller collects sensitive personal data, corresponding to the voice.

IV. THE PURPOSES OF THE PROCESSING

A. Primary purposes

You are informed that the following purposes give rise to and are necessary for the existence, maintenance and fulfillment of the legal relationship between you and this Controller, so your personal data may be used to:

a. Identify you and verify your identity.
b. Contact you for validation processes of the information you upload to our systems and applications, as well as for any issue related to the services, terms and conditions offered by this Controller.
c. Register on our website and/or application.
d. Browse and use our portals and applications.
e. Demand for compliance with the terms and conditions between this Controller and the client or user.
f. Respond to requirements and requests from any authority.
g. Compliance with national regulations.
h. Respond to questions, queries, complaints, suggestions, claims, requests to exercise ARCO rights, to refuse the processing of personal data, to revoke consent, and to limit the use or disclosure of personal data.
i. Transmit the location of the beacon to other users of the platform, when the tracking system is activated.

B. Secondary purposes

a. Send you, through the means of contact that you have provided us, marketing, promotional and/or advertising messages about our services, studies on animals, products and services that may be of convenience to you and your pet, whether offered by this Controller or by other individuals and/or legal entities.
b. To carry out surveys on the quality of the service.
c. Invite you to in-person or virtual events.

V. MECHANISMS FOR THE OWNER TO EXPRESS HIS/HER REFUSAL TO HAVE HIS/HER PERSONAL DATA PROCESSED FOR PURPOSES THAT ARE NOT NECESSARY, NOR HAVE GIVEN RISE TO THE LEGAL RELATIONSHIP WITH THE CONTROLLER

If you do not wish your personal data to be used for any of the secondary purposes, you may send a request, in accordance with the procedure established in sections VIII. IX. and X. of this Privacy Notice.

VI. PERSONAL DATA TRANSFERS THAT, IF APPLICABLE, ARE MADE; THE THIRD PARTY RECIPIENT OF THE PERSONAL DATA AND THE PURPOSES OF THE SAME

You are informed that, in order to fulfill the purposes established in this Privacy Notice, your personal data may be transferred and processed within and outside the United Mexican States to persons other than the Controller. In this regard, and based on the Federal Law on the Protection of Personal Data Held by Private Parties and its Regulations, this Controller may make the following national transfers without your consent:

A. Transfers without consent

a. To accounting and/or legal offices, to carry out procedures for the recognition, exercise and defense of the rights of this Controller, pursuant to the terms and conditions between this Controller and the client or user.
b. Natural persons and/or legal entities that provide accounting services, for support in the issuance of tax receipts, as well as for any tax and/or accounting aspect that arises due to the use of the application.
c. To authorities and individuals, pursuant to the provisions of national regulations.
d. To any authority, due to a request.
e. To other pet-related companies for the navigation and interactive virtual reality service.

B. Transfers with consent

a. To companies that produce, distribute and market pet food.
b. To companies that sell any type of goods or products for pets, as well as beauty and cosmetic services.

training.

VII. THE CLAUSE INDICATING WHETHER THE OWNER ACCEPTS THE TRANSFER OR NOT, WHEN SO REQUIRED

By accepting this Privacy Notice, you agree that your personal data may be shared, in the cases provided for in the previous section on “Transfers with consent”. If you do not agree with this, you may activate the procedure provided for in sections VIII. IX. and X. of this Privacy Notice.

VIII., IX., X. THE MEANS AND PROCEDURE FOR EXERCISING ARCO RIGHTS; THE MECHANISMS AND PROCEDURES SO THAT, IF APPLICABLE, THE OWNER CAN REVOKE HIS/HER CONSENT, AND; THE OPTIONS AND MEANS THAT THE CONTROLLER OFFERS TO THE OWNER TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA

To exercise your right to access, rectify, cancel and oppose the processing of your personal data, revoke consent, or to limit the use or disclosure of your personal data, you must send a request, in free writing, signed by hand, to the following email account: n7l.datospersonales@gmail.com

This email account is managed by the personal data department, an account that is established as a means of contact with this Controller for matters related to personal data, such as questions and complaints in this matter.

The request must contain:

1. The name of the owner, and the means to communicate the response to your request, as well as to make any type of notification in these procedures.

The applicant must specify an email account to inform you of the Controller’s determinations in relation to your request. If you do not specifically specify an email account, communications will be sent to the email account from which you sent your request, or to the address you have expressly indicated for such purposes.

2. Documents proving your identity or, where applicable, the legal representation of the holder.

In order to analyze the right you exercise, you will need to prove your identity. For this purpose, you must attach a clear and legible digital copy of your current official identification with a photograph (IFE/INE credential, passport, driver’s license, military service card, professional ID, or in the case of foreigners, a current official immigration document with a photograph). Likewise, in the event that any of these rights are exercised through a third party, you must send the document that accredits the representation (public deed, power of attorney signed by two witnesses, with a digital copy of your current official identification with a photograph – whether it is an IFE/INE credential, passport, driver’s license, military service card, professional ID, or in the case of foreigners, a current official immigration document with a photograph), as well as a clear and legible digital copy of the current official identification of the holder and the representative (IFE/INE credential, passport, driver’s license, military service card, professional ID, or in the case of foreigners, a current official immigration document with a photograph).

In all the above cases (except for those relating to witnesses in power of attorney letters), it will be necessary to compare the digitalization of the official identification(s) in question with its original(s), in accordance with the provisions of article 89 of the Regulations of the Federal Law on the Protection of Personal Data Held by Private Parties, by presenting said person(s) at the address of the Responsible Party, after an appointment granted by said Responsible Party, or by videoconference.

3. The clear and precise description of the personal data in respect of which one seeks to exercise any of the aforementioned rights, as well as the particular right that one seeks to exercise.

You must specify the right you are exercising through your request, which may be any of the following:

• Right of access
• Right of rectification
• Right of cancellation
• Right to object to the processing of personal data
• Revocation of consent
and/or
• Limitation on the use or disclosure of personal data

Likewise, if you wish to exercise your rights over any personal data in particular, you must specify over which data you are exercising your right. This situation will be necessary in the case of the right of rectification, in which the data to be rectified must be indicated, and the corresponding rectification, attaching, where appropriate, the supporting documentation that supports the modification, update, correction or rectification to be made.

4. Any other element or document that facilitates the location of personal data.

This Responsible Party will be the one who will directly process and respond to your requests.

In the event that the information provided in the request is insufficient or erroneous, or

If the documents required by the regulations are not submitted, this Controller may require you, once only, and within 5 days following receipt of your request, to provide the elements or documents necessary to process it within 10 business days following notification of the respective requirement. If the request is not fulfilled, or if it is not satisfactorily fulfilled, the request will be deemed not to have been submitted.

This Controller will notify you within a maximum period of 20 business days from receipt of your request, or from its clarification when the requirement referred to in the previous paragraph is satisfactorily fulfilled, of the determination regarding the admissibility of the right you have exercised. This period may be extended, on one occasion, for up to 20 more business days by determination of the Controller, and it will be the responsibility of the Controller to notify the applicant of said extension within the original period, explaining the causes that gave rise to it.

Likewise, this Controller has a maximum period of 15 business days after the date on which the response is notified, to make effective the exercise of the corresponding right, a period that may be extended, on one occasion, for up to 15 more business days by determination of the Controller, being responsible for notifying the applicant of said extension within the original period, in which the causes that gave rise to it are explained.

The means by which the right of access to personal data will be made effective will be through the sending of the information by email, or through the issuing of simple copies to be delivered to the address of this Controller, after paying the costs of reproduction and shipping, if applicable, in accordance with the provisions of article 93 of the Regulations of the Federal Law on the Protection of Personal Data Held by Private Parties. If applicable, other means may be enabled to give access to your personal data, in accordance with the provisions of article 102 of the Regulations of the Federal Law on the Protection of Personal Data Held by Private Parties.

Applicants are informed that Articles 22 to 35 of the Federal Law on the Protection of Personal Data Held by Private Parties, as well as Articles 87 to 110 of its Regulations, regulate the procedure for exercising the ARCO rights referred to.

Article 8 of the Federal Law on the Protection of Personal Data Held by Private Parties, as well as Article 21 of its Regulations, establish the right to revoke consent, delegating to the Controller the establishment of the procedure for its attention. In this sense, the requirements and procedure described in this section for the exercise of ARCO rights are those that this Controller has defined and established for the attention of requests for revocation of consent, in accordance with Article 21 of the Regulations of the Federal Law on the Protection of Personal Data Held by Private Parties.

Likewise, in accordance with article 16, section III of the Federal Law on the Protection of Personal Data Held by Private Parties, it is established that the procedure contained in this section is the one that this Controller offers to the owners to limit the use or disclosure of their personal data, in order to consider their refusal to continue receiving communications or promotions from this Controller.

XI. INFORMATION ON THE USE OF MECHANISMS IN REMOTE OR LOCAL MEDIA OF ELECTRONIC, OPTICAL OR OTHER TECHNOLOGY COMMUNICATION, WHICH ALLOW THE COLLECTION OF PERSONAL DATA AUTOMATICALLY AND SIMULTANEOUSLY AT THE TIME THAT THE OWNER MAKES CONTACT WITH THEM, IF APPLICABLE.

This Controller on its website and application uses cookies to record session information, but said information is used on an anonymous and aggregated basis in such a way that it cannot be identified in it.

On the website or in the application, advertising may be displayed or third-party functions may be executed that send cookies to users’ computers. Through the use of these cookies, users are not personally identified, only their computer.

As a user, you may change your options through your computer or internet browser to stop accepting cookies, or confirm whether you allow or reject them. However, if you disable cookies, you may not have access to some of the personalized functions of our Website.

XII. THE PROCEDURES AND MEANS THROUGH WHICH THE CONTROLLER WILL INFORM THE OWNERS OF CHANGES TO THE PRIVACY NOTICE

This Controller will inform changes to the Privacy Policy through its website www.never7lost.com