Privacy Policy

 

The terms used with initial capital letter will have the meaning established in the Federal Law for Personal Data Protection Held by Private Parties, the corresponding regulations, and/or the guidelines of the Privacy Policy, as modified from time to time.

Ventua Capital Privado, S.A. de C.V. (hereinafter as the “Responsible”), with domicile in Antonio Dovali Jaime #70, Tower A, Nineth Floor, Lomas de Santa Fe, Alvaro Obregon, Zip Code. 01219, Mexico City, Mexico.

Personal Data Collected

The Responsible, directly or indirectly through the website, will collect and treat de following Personal Data of (i) any interested person in investing in the Responsible’s private equity funds or of any of its affiliates or subsidiaries, (ii) offering an investment opportunity and (iii) apply for a job available (hereinafter the “Owner”):

Personal Data Collected

  1. General: Data that allows the identification of the Owner.
  2. Assets: Data that allows determining the properties of the Owner.
  3. Location: Data that allows the Owner to be located.
  4. Professional: Data that determines the education, work experience, qualifications and skills as well as prestige of the Owner.

Sensitive Personal Data

In the case of the Responsible’s employees, Sensitive Personal Data will be collected through the results of medical tests and COVID19 that may include (i) general health status; and (ii) positive or negative COVID19 status.

Notwithstanding, and in addition to, the provisions of this Notice, the primary purposes applicable to Sensitive Personal Data will be to (i) know health-related information; (ii) have a history of people with symptoms and/or who have tested positive for COVID-19; (iii) carry out preventive and corrective actions necessary for the prevention, care and mitigation of health emergencies, of COVID-19 and/or other diseases, as well as guaranteeing the health of the people who are in our facilities and/or third parties; (iv) allow the employees to assist to a laboratory to be tested for Covid-19; and (v) contact the employee for follow up regarding their health condition.

Purposes of Processing of Personal Data

The primary purposes that origin and are necessary for the fulfillment of the legal relationship between the Responsible and the Owner are the following:

  • All the procedures related with possible investments in which the Responsible may invest or disinvest, which may include the Owner’s companies, companies owned by third parties in which the Owner is a consultant or any other mean offered by the Owner, that may require information, identification and the Owner’s knowledge, its partners or employees;
  • The prevention or spotting of frauds or any other unlawful acts against the Responsible and/or the Owner;
  • Make Owner’s consults, investigations, analysis, and/or revisions of the activities, operations, objections, and /or complaints related to the investments; and
  • Compliance with laws, regulations, and applicable legal dispositions and,
  • Initiate a contractual relationship that allows to interact the Responsible and the Owner for any business opportunities or to grant professional services by the Owner in favor to the Responsible.

The Responsible will not collect any information considered secondary.

Transfer of Personal Data

The Owner’s Personal Data will be transferred nationally and internationally to the following persons:

  • When the Responsible considers necessary to transfer Personal Data to financial institutions and/or investors in order to carry out the primary purposes previously mentioned and any plausible investment transactions.
  • To authorities when the transfer is mandatory by any law, regulation or legal disposition.

Owner’s Consent to Transfer

The previously mentioned transfers do not require the Owner’s consent since they are considered primary and necessary in order to fulfill the legal relation between the Owner and the Responsible

Means and Procedure to Exercise the ACDO (ARCO for its Spanish initials) Rights

If the Owner desires to exercise his/her access, correction, deletion, or opposition rights to the processing of his/her Personal Data, he/she may send an e-mail to contacto@venturacp.com , whereby he/she must identify himself/herself with full name, legal relationship established with the Responsible and the contact information where he/she may be reached at. The proceedings to exercise the ACDO rights as well as to revoke his/her consent will be informed through e-mail once the request is received.

Means and Options to Limit the Use and Disclosure of the Personal Data

The Owner may register himself/herself in the User’s Public Registry (Registro Público de Usuarios) in accordance with the Defense and Protection of Financial Services Users Law in order to limit the use and disclosure of his/her Personal Data The register UPR (REUS) for its Spanish initials), allows the Owner to register in a data base in order to limit the promotional calls in particular numbers (landline and cellphone), work, or e-mail, seeking to keep his/her information safe and avoiding the inconvenience caused by the calls of sending of information. The Owner may register in the UPR in the following website: condusef.gob.mx/reus

Amendments to the Privacy Policy

This Privacy Policy is located in the Responsible’s website, at: www.venturacp.mx (the “Address”). Likewise, any amendments made to this Privacy Policy will be published at the Address.

When starting a legal relationship with the Responsible, the Owner agrees that his/her Personal Data are processed, used and/or destined to the purposes abovementioned and/or in accordance to this Privacy Policy.