MEZUBO S.A.S. MX PERSONAL DATA PROCESSING POLICY

Mezubo, S.A. de C.V. (“Mezubo”), located at 424 Montes Urales Street, Lomas de Chapultepec neighborhood, Miguel Hidalgo borough, ZIP code 11000, Mexico City, recognizes the importance of the legitimate, controlled, and informed processing of your Personal Data and provides you with this Privacy Notice so that you may understand our practices regarding the collection, use, disclosure, storage, and, in general, the processing of your Personal Data, in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties (the “Law”) and other applicable legal provisions in this regard.

Mezubo will at all times, when collecting, using, storing, and generally processing your Personal Data, act in accordance with the Law, its regulations, and other applicable legal provisions, observing at all times the principles of lawfulness, consent, information, quality, purpose, fairness, proportionality, and accountability provided for in the Law.

What Personal Data does Mezubo collect?

Mezubo may request the following Personal Data from you, which may vary depending on the circumstances, so that Mezubo can negotiate, clarify, define, or establish the relationship that exists or may exist between Mezubo and you:

1. Identification Information.

First name, father’s surname, mother’s surname, Unique Population Registry Code (“”), address, nationality, age, date of birth, country and state of birth, nationality, telephone number (landline and/or mobile), email address, signature, and, where applicable, first name, father’s surname, mother’s surname, telephone number (landline or mobile), C.U.R.P., and signature of the spouse, and any other information that allows us to identify and know you, as well as official identification or other public or private documents that verify the accuracy of the aforementioned information, such as a voter ID card, passport, driver’s license, proof of address, C.U.R.P. certificate, and professional license.

Sensitive Personal Data.

Estado civil, género, intereses y sexo, así como los documentos públicos o privados que permitan acreditar la veracidad de la información antes mencionada, como el acta de matrimonio, identificación oficial y/o documento donde se haga constar el divorcio.

Professional and Employment Information.

Current occupation, name, home address and phone number, and workplace address; professional, employment, and educational information; personal and employment references; educational background; and any other information that provides insight into your professional and employment history, as well as public or private documents that verify the accuracy of the aforementioned information.

Financial Information.

Bank accounts, account number and interbank code, branch number, checking account, income, fixed and movable assets, savings, vehicles, housing, funds, debts, net worth, financial products, donations, and/or any other financial, economic, or asset-related information necessary for the services provided by Mezubo, and any public or private documents that verify the accuracy of the aforementioned information.

Tax Information:

Tax address, Federal Taxpayers Registry ID number, and tax identification card or proof of registration with the Federal Taxpayers Registry, as well as public or private documents that verify the accuracy of the aforementioned information.

Personal Data is collected directly or through the use of applications, websites, or platforms owned by Mezubo and/or its business partners, as well as indirectly through transfers from our customers, suppliers, business partners, and/or any other third parties you have authorized to share your Personal Data with Mezubo.

How does Mezubo use your Personal Data?

General Purposes:

Mezubo collects and uses your Personal Data for the following purposes:

Register on any of the platforms and/or websites of Mezubo and/or its business partners.
Verify and confirm your identity for the purpose of offering and properly providing the products and services offered by Mezubo through any means or channel.
Send communications regarding Mezubo’s services and, in general, the provision of its services through any communication channel, including but not limited to social media, text messages, push notifications, email, and phone calls, among others.
To carry out management, administrative, sales, payment, collection, and compliance activities as a user of Mezubo’s services on behalf of our clients. This includes sales management and pre-litigation and litigation collection, handled by us or third parties through the following channels: WhatsApp, phone calls, WhatsApp calls, email, text messages, or any official Mezubo communication channel.
To use the provided data in communication, sales, outreach, and promotional campaigns or to offer products, activities, and/or services via: email, WhatsApp, SMS, Facebook, Messenger, Instagram, and other social media platforms; push notifications; calls; video calls handled by human and/or digital agents; or any official communication channel of Mezubo or its business partners and clients.
To send messages, calls, and video calls related to sales support, customer service, promotions, marketing, advertising, and other information based on your preferences, as well as social media advertising, through social media platforms, on behalf of Mezubo or its clients or business partners. This includes the possibility of communication via messages, calls, and video calls through instant messaging apps and, eventually, your inclusion in groups that engage in this type of communication (from which you may opt out at any time by sending a message to Mezubo’s official channels).
Maintain historical records of and stay in contact with users and customers of Mezubo’s services and products.
To record information about its employees, suppliers, customers, users, third parties, authorized individuals, and collaborators.
To provide support for external and internal audit processes.
To carry out measures for fraud control and prevention, anti-money laundering control and prevention, countering the financing of terrorism, operations involving funds of illicit origin, transparency and corporate ethics programs, and other corporate social responsibility controls.
Take the necessary steps to address and resolve requests, complaints, and claims.
Participate in surveys, sweepstakes, and other promotional activities, online or elsewhere, through Mezubo’s communication channels.
Create a database of Mezubo users and/or customers.
Enter into any agreement, contract, and/or arrangement that may be necessary or appropriate.
To fulfill its obligations and exercise its rights under the agreements, contracts, and other arrangements Mezubo has entered into with you.
To maintain records containing the information and/or documentation provided in transactions conducted by Mezubo.
For the issuance of Digital Tax Receipts via the Internet and compliance with tax obligations imposed by the SAT and applicable regulations.
To keep Mezubo’s records of all types, including legal ones, up to date and to verify the accuracy of the information you provide.
Video surveillance and security at Mezubo’s facilities through video and audio monitoring (CCTV).
To store, process, manage, and safeguard the Personal Data that Mezubo collects and processes in accordance with the security and confidentiality standards established in applicable laws.
To comply with the applicable laws related to the services, products, and activities that Mezubo provides to you, as applicable.

Purposes for Users and Customers:

With regard to Mezubo users and customers, Mezubo collects and uses your Personal Data for the following purposes:

To manage and provide software, data processing, cloud computing, and/or hardware services provided by Mezubo.

To provide Mezubo’s services to its clients, for which you have authorized the processing of your Personal Data for the purpose of purchasing and receiving the products and/or services offered by such clients (including interactions through various channels with our agents).

To implement any security measures and manage access to the platforms and websites of Mezubo and/or its business partners.

Conduct marketing analysis, product preference analysis, or user scoring on the Mezubo platform or website.

Perform and carry out all necessary actions and procedures so that Mezubo users and customers, as well as the users and customers of the latter, can access and use Mezubo’s websites and platforms, including, without limitation, digital and cloud computing platforms. In this case, your Personal Data will also be used to improve interactive services to achieve effective communication among all participants and operators.

Classify and implement any necessary security measures on the platforms and websites operated by Mezubo.

Employment Purposes:

1. To review your employment and/or professional profile in order to consider you for a job opening at Mezubo, and for any actions necessary for the selection and hiring process.

2.To fulfill its obligations and exercise its rights under the agreements, contracts, and other arrangements that Mezubo has entered into with you (including employment contracts of any kind).

3. To register or deregister you and carry out any type of procedure or formalities with the Mexican Social Security Institute, the National Workers’ Housing Fund Institute, the National Fund for Workers’ Consumption

The Retirement Savings System, and/or any other agency, entity, body, organization, and/or legal entity regarding labor matters, social security, and/or any other labor-related benefits granted in your favor.

To collect and pay any amount you owe to Mezubo or that Mezubo owes you for any reason, and for any other activity related to payment processing.

To respond to medical emergencies or emergencies of a similar nature.
To manage Personal Data in order to establish access controls for Mezubo’s physical, logical, digital, and computational infrastructure.
To obtain benefits for Mezubo employees from third parties, including banks or credit institutions.
The Personal Data you voluntarily provide to Mezubo by sending a letter, package, message, comment, email, fax, or suggestion via the website, among other means, will be used to contact you if necessary, or to send you information of interest regarding the relationship that exists or may come to exist between Mezubo and you.
Your Personal Data may be used for purposes other than those mentioned above, provided that such purposes are consistent with those described. The purposes mentioned in this Privacy Notice are necessary to establish any relationship, including a legal one, that may exist between Mezubo and you, as well as for the continuation, maintenance, and fulfillment of such a relationship.

Your Personal Data may be stored physically, digitally, or through any other similar means that adequately safeguards the information, such as servers, cloud services, hard drives, and/or computers.

With whom does Mezubo share your Personal Data and for what purposes?

Your Personal Data will only be processed by Mezubo’s authorized personnel and individuals for the purposes mentioned above. Mezubo may transfer your Personal Data for the purposes listed below:

a) Any of your Personal Data may be transferred to the SAT and/or to any government agencies, offices, and/or departments responsible for tax or social security matters for the purpose of calculating, reviewing, and/or withholding applicable taxes (including income taxes), and to any government agency, office, and/or department of any kind in order to comply with any obligation established by law under applicable legal provisions.

b) Tus Datos Personales podrán ser transferidos a los proveedores, socios y aliados comerciales de Mezubo, y/o a cualquier otro tercero con

quien Mezubo tenga celebrado un contrato de servicios para el uso de sus plataformas y sitios web con el objeto de cumplir con las siguientes finalidades: (a) para proporcionarte los servicios de Mezubo y cumplir cualquier acuerdo, contrato y/o convenio celebrado por Mezubo que genere un beneficio y/o permita proporcionarte sus servicios en tu favor, (b) registrar la información de empleados, proveedores, terceros y todo tipo de usuarios en las plataformas de Mezubo, (c) conservar registros históricos y mantener contacto contigo como titular de los Datos Personales respecto de los servicios que proporciona Mezubo, (d) realizar las actividades necesarias para gestionar tus solicitudes, quejas y reclamos como titular de los Datos Personales; y direccionarlos a las áreas responsables de emitir las respuestas correspondientes, (e) administrar y prestar servicios de software, procesamiento de datos, computación en la nube y/o hardware, y (f) para mantener y actualizar las medidas de seguridad y acceso a la plataforma de Mezubo.

c) Any of your financial information may be transferred to any bank and/or credit institution so that Mezubo can make payments and collect any amounts (including fees, commissions, bonuses, and others).

d) Any of your Personal Data may be transferred to Mezubo’s advisors so that they may provide Mezubo with their advisory services, enabling Mezubo to continue providing you with its services.

e) Any of your Personal Data may be transferred to providers of data storage, processing, management, and communication services, including those known as “Clouds,” within or outside the national territory, with whom Mezubo contracts for such services.

f) Any of your Personal Data may be transferred to any third party when necessary to comply with any contract, agreement, and/or arrangement entered into by Mezubo and/or by you.

Asimismo, Mezubo podrá transferir tus Datos Personales sin tu consentimiento en los supuestos establecidos en el artículo 37 de la Ley y demás disposiciones legales aplicables al respecto.

How can you access, correct, delete, or object to the processing of your Personal Data?

You may exercise your rights of access, rectification, cancellation, and objection (the “ARCO Rights”), as well as revoke your consent and limit the use or disclosure of your Personal Data, by submitting a written request to Mezubo’s address addressed to the “Data Protection Officer,” or via email to info@heygia.ai. Through the aforementioned channels, you may inquire about the procedures to follow to (i) exercise your ARCO Rights, or (ii) revoke your consent to this Privacy Notice and the processing of your Personal Data, or (iii) limit the use or disclosure of your Personal Data.

Likewise, you may object to the processing of your Personal Data for purposes that, in your opinion, differ from those necessary to establish the relationship—including the legal relationship—between Mezubo and you, by sending a written request addressed to the “Data Protection Officer” at Mezubo’s registered office, or via email to info@heygia.ai.

Mezubo will have 20 (twenty) business days to respond to your requests, starting from the day after the request is received. This period may be extended once for up to 10 (ten) business days if circumstances warrant it, provided that the data subject is notified within the initial response period.

What other information does Mezubo collect?

When you browse the Mezubo website (www.heygia.ai) and/or access or use any application or platform of Mezubo and/or its business partners, information is collected through cookies, web beacons, and other technologies. The purpose of collecting this information is to generate statistics regarding visits to the Mezubo website and the referring sites that may have led you to that website. This information is also used to maintain and update user profiles on the Mezubo website, to personalize a user’s profile when they visit, and to tailor the information provided through the website, as well as to provide you with a better service and user experience when browsing the Mezubo website.

All of the aforementioned information is used to improve our websites and identify new needs so that we can offer users and customers content, processes, and services of the highest quality. In all cases, the information is collected anonymously, and website trend reports are generated without identifying individual users. You can disable, reject, or delete cookies—either in whole or in part—stored on your device at any time by adjusting your browser settings.

Web beacons: These are visible or hidden images embedded within a website or email that are used to monitor user behavior on these platforms. Through them, information such as the source IP address, browser used, operating system, time the page was accessed, and, in the case of email, the association of the aforementioned data with the recipient can be obtained.

Decisiones Automatizadas.

Automated decision-making occurs when an electronic or digital system processes information or Personal Data to make a decision without human intervention. Some of Mezubo’s procedures rely on automated decision-making mechanisms and artificial intelligence; therefore, Mezubo guarantees your right to request a review of decisions made solely based on the automated processing of your Personal Data in accordance with applicable legal provisions.

How do you give your consent to this Privacy Notice?

As the Data Subject, you hereby declare under oath that:

If this Privacy Notice is available via a website (or similar platform) or any other electronic device, clicking “accept” (or similar) or otherwise continuing to browse the website, or providing your Personal Data through it, constitutes an expression of your consent for Mezubo to process your Personal Data.

If this Privacy Notice is made available through audio, audiovisual, or any other technology, the fact that you provide your Personal Data constitutes your consent for Mezubo to process your Personal Data.

If this Privacy Notice is available in writing, your signature, initials, name, and/or fingerprint constitute your consent for Mezubo to process your Personal Data.
All information you provide is accurate and complete, and, accordingly, you will be responsible at all times for the Personal Data you provide.

If you see any notice containing information related to this Privacy Notice and proceed with the process of providing Personal Data, filling out a database, and/or any other similar activity, you will be automatically deemed to have accepted the terms of this Privacy Notice.
What are the ARCO Rights?
For your reference, the ARCO Rights are briefly described below:
Access. You have the right to be informed of the Personal Data contained in Mezubo’s databases, to be told how such Personal Data is used, its origin, and any communications made using it, as well as the general conditions of its processing. Likewise, you have the right to request that Mezubo provide you with hard copies or send electronic documents containing your Personal Data so that you may access them.
Correction. You have the right to have your Personal Data corrected and updated if it is inaccurate or incomplete. You are obligated to inform Mezubo of any changes that need to be made to your Personal Data when such changes are known only to you.
Deletion. You have the right to have your Personal Data deleted.

Right to Object. You have the right to object, on legitimate grounds, to the processing of your
Personal Data.How can you find out about changes to this Privacy Notice?

This Privacy Notice may be subject to modifications, changes, or updates; therefore, Mezubo undertakes to keep you informed of such changes through any of the following means:

Email. Upon your written request via email, Mezubo will send you this updated Privacy Notice via email.

Mezubo’s address. You can find this updated Privacy Notice at Mezubo’s offices located at 424 Montes Urales Street, Lomas de Chapultepec neighborhood, Miguel Hidalgo borough, ZIP code 11000, Mexico City.

On the Mezubo website http://www.heygia.ai.

How can you contact Mezubo?

If you have any questions, comments, or suggestions regarding this Privacy Notice, please contact the “Data Protection Officer” via the following email address: info@heygia.ai, or by sending a letter addressed to the “Data Protection Officer” at Mezubo’s address. You may also use the aforementioned methods to opt out of receiving further communications from Mezubo.

In accordance with the Law and its regulations, we hereby inform you that, in the event of a refusal to respond to requests regarding ARCO rights or if you disagree with the response, you may file the corresponding Request for Protection of Rights with the National Institute for Transparency, Access to Information, and Protection of Personal Data, in accordance with the terms established by the Law and its regulations. For more information, we suggest you visit the official website www.inai.org.mx.

Your failure to object to this Privacy Notice upon receiving it constitutes your consent to it under Article 8 of the Law and other applicable legal provisions.

Updates to this Privacy Notice – Last Updated: March 12, 2024.