Our Privacy Policy

WHAT DOES THE PROCESSING OF YOUR PERSONAL DATA CONSIST OF?

It consists of obtaining, using, disclosing and/or storing personal data, by any means. Use includes any action of access, handling, use, remittance, transfer or disposal of your personal data.

Therefore, in compliance with the Federal Law on the Protection of Personal Data in Possession of Private Parties, (hereinafter LFPDPPP) we make available to you this comprehensive privacy notice, by virtue of which we inform you of the form and means through which the collection and processing of your information is carried out:

IDENTITY AND ADDRESS OF THE DATA CONTROLLER AND PROTECTION OF YOUR PERSONAL DATA.

For the purposes of this Comprehensive Privacy Notice, Thor Urbana Management, Limited Liability Company of Variable Capital hereinafter "Bruma Wine Resort" is designated as responsible for the disclosure, storage, use, including action of access, handling, exploitation, transfer, or disposition of personal data, with address to hear and receive all types of notifications located at Avenida Paseo de la Reforma 2620, Piso 16, Colonia Lomas Altas, Alcaldía Miguel Hidalgo, C.P. 11950, Mexico City, will be responsible for the processing of your data, as the owner, whether personal or sensitive, as well as for the handling and protection of these.

INFORMATION ABOUT OUR COMPLIANCE DEPARTMENT.

Bruma Wine Resort has appointed the Compliance Department to be able to provide you with attention in terms of Personal Data, among which are:

Attention to requests for the exercise of your rights of Access, Rectification, Cancellation or Opposition (ARCO Rights).
To promote a culture of Personal Data protection within Bruma Wine Resort.
Safeguard the Personal and Sensitive Data that Bruma Wine Resort has in its possession.
Attention to doubts, complaints or suggestions regarding the processing of your Personal or sensitive Data.

For the foregoing and derived from any issue regarding Personal Data. You may contact our Compliance Department via email cumplimiento@thorurbana.com.

PERSONAL DATA COLLECTED TO CARRY OUT THE PROCESSING.

The personal data requested and collected by Bruma Wine Resort are those that, in your capacity as our client or potential client, are necessary to establish our legal and commercial relationship with you, and can identify you as an individual, these being: data and images of your official identification, full name, work, tax and conventional address, telephone numbers, email, nationality, country of birth, date of birth, activity or occupation, position and position held in an organization, unique population registry code (CURP), Federal Taxpayer Registry, employment history, social security number, education, economic dependents, identity of collateral and blood relatives, marital status, data of spouse or common-law partner, credit history, patrimonial and financial information, autograph signature, name of beneficiaries, registration of real estate owned by them, as well as video recording of images and sounds in offices, points of sale and service to the general public of Bruma Wine Resort.

PURPOSES OF PROCESSING YOUR PERSONAL DATA.

The personal data that are provided to Bruma Wine Resort by you, the Owner of your personal data, will have the following main purposes: a) To identify, update and conform physical and electronic files of you as a customer or user of the services provided by Bruma Wine Resort; b) To establish relationships aimed at generating a possible contractual relationship for the signing of contracts for the lease and sale of goods real estate, constitute real or personal rights over real estate, provide you with the services and products required by you; contract advertising space within the properties managed by Bruma Wine Resort, c) Contact you by telephone, SMS messaging or through the use of digital data messaging platforms or email with you when necessary to provide you with customer service, clarification of doubts or notify you of commercial aspects of your contracted products or services; d) to respond to a query made by you; e) To carry out an analysis of their financial, patrimonial and labor history; f) To comply with the various applicable federal and state legislations .

In the same way, and in a complementary manner, your personal data may be used for the following secondary purposes: a) to contact you by telephone, through SMS message or through the use of digital data messaging platforms or e-mail to inform you and offer you products or services; b) to carry out surveys to evaluate our own services; c) marketing, advertising, commercial prospecting purposes for new products and services; d) security measures implemented within the facilities, shopping malls and points of sale of Bruma Wine Resort; e) enable you to participate in the competitions and/or raffles and/or promotions that Bruma Wine Resort organises; f) share your personal data with people with whom you maintain relations of the Business Group, g) notify them regarding new openings of shopping malls or commercialized properties; h) Audits by internal or external personnel, of a fiscal, accounting, legal, financial, regulatory, performance and/or compliance nature.

OPPOSITION TO THE PROCESSING OF PERSONAL DATA.

In the event that you, as the Owner of the personal data, do not agree that your data should be used for the secondary purposes described above, Bruma Wine Resort makes available to you the "ARCO Rights Form", available on the website https://www.brumawineresort.com/ or you can request it directly at the address of Bruma Wine Resort. The "ARCO Rights Form" is a tool created by Bruma Wine Resort to facilitate access to exercise your rights, however you may also use a free writing in which you must state which of these purposes you wish to exclude from the processing of your personal data, indicating the date of your request and your handwritten signature. which must be sent by email to the address cumplimiento@thorurbana.com or delivered directly to the address of Bruma Wine Resort, indicated above.

You as the owner have five working days, counted from the relationship entered into with Bruma Wine Resort, to express your refusal to the processing of your personal data for the secondary purposes mentioned in paragraph IV, immediately preceding through the means of contact in person or by email to the address cumplimiento@thorurbana.com

VIDEO RECORDINGS OF PERSONAL IMAGE.

By entering any of Bruma Wine Resort's shopping plazas, managed real estate, real estate developments, branches and/or corporate office, you consent to be videotaped by our security cameras. The videos, images and sounds that are captured by our cameras will be used for the following purposes:

Monitor the people who visit us for safety issues.
Safeguard the property owned by our clients and facilities of Bruma Wine Resort.
Provide video and audio (when the property has it) to competent authorities, following a well-founded and motivated legal requirement.
Provide Customer Service services.

Video recordings are kept for a maximum period of 30 calendar days for security reasons. They are subsequently deleted from the servers and/or memories of Bruma Wine Resort's equipment.

SENSITIVE PERSONAL DATA COLLECTED.

Sensitive Personal Data is data that reveals an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or sexual or health orientation. For the purposes described in this privacy notice, Bruma Wine Resort does not collect sensitive personal data from you as our client.

TRANSFER OF PERSONAL DATA.

Bruma Wine Resort informs you that, due to the processing of your personal data, they may be transferred or sent to natural or legal persons, public or private, national or foreign, as well as to local or foreign authorities, for the following purposes:

EXTERNAL THIRD PARTY RECIPIENT INDIVIDUALS OR LEGAL ENTITIES MAINLY ENGAGED IN THE FOLLOWING ACTIVITIES:	PURPOSE OF TRANSFER OR REMITTANCE
A) External auditors and consultants	Regulatory compliance procedures, review of transaction records, best regulatory practices and continuous improvement of processes.
B) National or foreign authorities	Compliance with the applicable regulatory framework. - Attention to administrative and/or judicial requirements. Compliance.
C) Computer services	Provision of technical support services as well as systems Computer.
D) Marketing services and targeted advertising.	Design and implementation of advertising and commercial prospecting strategies, brand promotion, promotion of real estate, products and services, notification of balances, payments, arrears or data updating and identification files.
E) Subsidiaries, Affiliates, Subsidiaries, Controlled or Controlling Companies, investors.	Bruma Wine Resort may share your personal data for statistical purposes, compliance, background, commercial prospecting, claims analysis, transactional profiling and control, with any of our affiliates and/or companies that belong to our same corporate group. While our affiliates, affiliates, subsidiaries, controlled or controlling companies and investors are located inside and outside Mexico.
F) External Legal Staff	Processing of lawsuits, conciliations, assignment of portfolio and collection management of judicial or extrajudicial portfolio
G) Companies what Provide services of Payment processing.	Payments by credit, debit card, SPEI, where the data related to the identification of your interbank CLABE, card number, bank account number, expiration date, address, name and signature are transferred or PIN, to validate their identity.

ACCEPTANCE TO CONSENT TO THE TRANSFER OF PERSONAL DATA

In the event that the Owner does not agree that his/her personal data will be transferred to those Third Parties indicated in subsection D) of the previous numeral, he/she must express his/her opposition to Bruma Wine Resort at the beginning of the commercial relationship, which he/she can do through the "ARCO Rights Form". If you do not express your refusal to carry out such transfers, you will be deemed to have consented and authorized, and your ARCO rights will be safeguarded at all times.

RIGHTS OF ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION (ARCO)

The Owner has the right to access, rectify, cancel and oppose the processing of their Personal Data, for which Bruma Wine Resort makes available to them at their home, as well as the digital means through which you as the Owner will be able to know the procedure and format to exercise your ARCO rights, or to revoke the consent granted for the processing and transfer of your Personal Data.

Bruma Wine Resort Wine Resort website https://www.brumawineresort.com/
Request the Form by Email to the following address: cumplimiento@thorurbana.com Definition:

ACCESS: It is the right of the Data Owner to know what Personal Data is in our databases and for what purpose they are processed by Bruma Wine Resort, its Controlling Companies, Affiliates, and Subsidiaries, Managers and Third Parties.
RECTIFICATION: It is the right of the Data Owner to be able to request the correction of their Personal Data, in case they are outdated, inaccurate or incomplete.
CANCELLATION: It is the right of the Data Owner to have them deleted from our records or databases when they consider that they are not being used properly, as long as there is no legal obligation in force with Bruma Wine Resort.
OPPOSITION: It is the right of the Data Subject to oppose the use of their Personal Data for specific purposes as long as there is no legal obligation in force with Bruma Wine Resort.

Procedure for the exercise of ARCO rights.

To exercise these rights, ARCO may complete and sign the ARCO RIGHTS FORM that is available on our website. Once the form has been completed, it must be sent via email cumplimiento@thorurbana.com, or physically delivered to the home of Bruma Wine Resort.

FIRST The holder and/or his/her representative must submit his/her application with the documentation indicated in the FORM OF ARCO RIGHTS through the means of communication defined in the first paragraph of this subsection.

SECOND The staff of the Compliance Department of Bruma Wine Resort will review your application and the attached documentation to prove the identity of the owner or that of his legal representative. It will verify that the requested documents are available and will validate that the information contained is adequate and/or correct.

In the event that the information provided in the request is insufficient or erroneous to meet it, or the requested documents are not attached, the compliance area staff may request through email to the holder, only once and within five business days of receiving the request, that provides the necessary elements or documents to process it.

The holder or his representative will have ten working days from the day after he has received it to respond to the requirement. If no response is given within this period, the corresponding application will be considered not submitted and will be rejected.

THIRD Once complete documentation and information are available, the Compliance Department staff will will have a period of 20 (twenty) business days to respond to the request of the owner and/or his representative.

ROOM In the case of Access Requests to personal data, will proceed after accreditation of the identity of the Owner and/or his/her representative, through the delivery of simple copies or e-mail, as requested. The data will be provided free of charge, unless shipping costs are incurred. In the event that the Owner reiterates the application in a period of less than twelve months, must cover the corresponding costs equivalent to no more than three Units of Measurement and Update (UMAS) in terms of the provisions of the Federal Law for the Protection of Personal Data in Possession of Private Parties (LFPDPPP).

In the case of rectification requests, the Owner must indicate the modification to be made, as well as provide the documentation that supports the request, such as the date of the contract or service provided, among others.

In the case of cancellation requests, the Owner will be subject to the provisions of Article 26 of the LFPDPPP, so it is hereby made known that not all personal data may be canceled, so the Compliance Department will review and give attention to the request for cancellation of your personal data. if applicable.

In the case of opposition requests, the Owner shall have the right at any time to object to the processing of his/her Personal Data. If your request is admissible, Bruma Wine Resort will stop processing your data. The right to object will not be applicable when the data processed is necessary for compliance with a legal obligation imposed between the parties.

In the case of Consent Revocations, the Owner may request the revocation of the consent previously granted for the Treatment or Transfer of their Personal Data, so any revocation will be subject to the provisions of the LFPDPPP, reserving the right of Bruma Wine Resort to refuse such revocation, when there is a contractual relationship between the Parties.

FIFTH The staff of the Compliance Department will respond to requests for ARCO rights and/or revocation of the consent received, regardless of whether or not the owner's personal data appears in their databases. in accordance with the established deadlines.

If the request is admissible, it will be made effective within 15 working days of the date on which the response is communicated.

Bruma Wine Resort may deny access to Personal Data or to make the rectification, cancellation or to grant opposition to the processing of these, in the following cases:

When the applicant is not the Owner or the legal representation of the same is not duly accredited.
When the requested Personal Data is not found in the Bruma Wine Resort database.
When the rights of a third party are infringed.
When there is a legal impediment or the resolution of a competent authority that restricts access to Personal Data or does not allow the rectification, cancellation or opposition of the Personal Data, and
When the access, rectification, cancellation or opposition has already been made.

The refusal referred to in the preceding paragraph may be partial, in which case Bruma Wine Resort will carry out the access, rectification, cancellation or opposition required by the Owner.

In the cases provided for above, Bruma Wine Resort will duly inform the Owner or legal representative of the reason for the decision, within the deadlines established for this purpose, by the same means in which the request was made or that indicated by the Owner.

For any questions or clarifications regarding the procedure for exercising ARCO rights and/or revoking consent, you can contact the Compliance Department of Bruma Wine Resort by sending the following email cumplimiento@thorurbana.com.

USE OF COOKIES AND WEB BEACONS.

Bruma Wine Resort uses Cookies on its website and Google Analytics, through which it allows it to provide the Owner with a personalized service and better experience when browsing the website, as well as to monitor the behavior of users.

The Personal Data that Bruma Wine Resort collects through these electronic means are: IP address, operating system data , URL, preferences within the website, browsing time, information displayed and browser.

Likewise, the Owner may directly provide data on the websites and social networks of Bruma Wine Resort, such as: Name, surname, State, City, email, telephone and subject to be addressed, which will allow Bruma Wine Resort to contact each other to provide the corresponding attention and services.

To disable the use of the Internet technologies mentioned in this privacy notice, the Owner may perform the following procedures:

To disable cookies in Google Chrome for Windows, follow these steps:

Click the Tools menu.
Select the Options feature.
Click the Advanced tab.
In the "Privacy" section, click Content settings.

To allow first-party and third-party cookies, select the option to allow local data to be set. If you are only required to accept first-party cookies, select the checkbox next to "Ignore exceptions and prevent third-party cookies from being enabled".

To disable, select "block site data and third-party cookies" as well as "Do not allow site data to be saved".

To disable cookies in Internet Explorer 7 or 8, follow these steps:

Click Start and then click Control Panel.
In Windows XP Classic View mode, click Start > Settings > Control Panel.
Double-click the Internet Options icon.
Select the Privacy tab.
Click Advanced.
In the "Advanced Privacy Settings" window, select the options to disable cookies.
In the Internet Options window, click OK to exit that dialog box. To disable cookies in Mozilla Firefox for Windows, follow these steps:
Click on Tools and then on Options.
In the top pane, click Privacy.
In the "Firefox may:" section, select the Use custom settings for history option.

Select the option to disable cookies

Click OK.

To disable cookies in Safari, follow these steps:

Access the Safari drop-down menu.
Select Preferences.
In the top pane, click Security.
Select the option to disable cookies.

Click OK.

XII.- OPTIONS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA.

In addition to the procedures and exercise of the ARCO rights of this Privacy Notice, the Owner may limit the use or disclosure of personal data in any of the following ways:

The owner can register in the Public Registry of Consumers of the Federal Consumer Protection Office (PROFECO). Regarding the latter option, you can obtain information by contacting PROFECO directly or by entering the following link: https://repep.profeco.gob.mx/

The Owner may request through the following email: cumplimiento@thorurbana.com to be included in the " BRUMA WINE RESORT EXCLUSION LIST, in order not to use their personal data for promotional, advertising or marketing purposes; as well as to comply with the determination made to the request to exercise the right of opposition that the Owner may present at the time.

The Account Holder may send an email to cumplimiento@thorurbana.com., stating their refusal to continue receiving communications or promotions from the data controller.

XIII.- CHANGES IN THE PRIVACY NOTICE.

Due to the fact that changes may be made to the Privacy Notice, Bruma Wine Resort informs you that any change to this Comprehensive Notice will be notified through printed means in our shopping malls and marketed properties, point of sale and address, as well as on the following website https://www.thorurbana.com/es/ therefore it is recommended to frequently consult the links provided above.

XIV.- IMPROPER PROCESSING OF PERSONAL DATA BY THE RESPONSIBLE PARTY.

If you, as the Owner of your personal data, consider that your right to personal data protection has been violated by any conduct or omission on the part of Bruma Wine Resort, or presume any violation of the provisions of the Federal Law on the Protection of Personal Data in Possession of Private Parties, its Regulations and other applicable regulations, may file their disagreement or complaint with the corresponding Authority.

RETENTION AND SECURITY OF PERSONAL DATA.

Bruma Wine Resort and/or its processors will keep the Personal Data for as long as necessary to process the requests for products and/or services offered, comply with the legal relationship entered into between the Owner and the Responsible Party, as well as to maintain records in terms of the LFPDPPP.

The Personal Data processed by Bruma Wine Resort and/or its managers are protected by appropriate administrative, technical and physical security measures against damage, loss, alteration, destruction or unauthorized use, access or processing, in accordance with the provisions of the LFPDPPPP.

CONSENT TO THE PROCESSING OF PERSONAL DATA.

The Owner declares that he/she has read, understood and accepted the terms set forth in the Privacy Notice, which constitutes the free , specific, unequivocal and informed consent, including with respect to the changes established in the updates made to it, with respect to the processing of Personal Data in compliance with the provisions of the LFPDPPP and the Guidelines on the matter.