IN ACCORDANCE WITH THE PROVISIONS OF THE FEDERAL LAW ON THE PROTECTION OF PERSONAL DATA HELD BY PRIVATE PARTIES AND ITS REGULATIONS (HEREINAFTER “LAW”), THIS PRIVACY NOTICE IS ISSUED IN RELATION TO THE USE OF THE PORTAL IN THE FOLLOWING TERMS:
I. Identification of the Responsible and treatment of your personal data.
BRENNTAG MEXICO, S.A. DE C.V. (hereinafter BRENNTAG MEXICO), which can be contact through its email firstname.lastname@example.org, with offices at Avenida Tejocotes Manzana 4, Lot 8, Bodega G, Postal Code 54763, San Martin Obispo Tepetlixpa Industrial Park, Municipality of Cuautitlán Izcalli, State of Mexico, is responsible for the treatment and protection of personal data provided at THE PORTAL.
The data that you provide will be treated under the principles established in the LAW which are: legality, consent, information, quality, purpose, loyalty, proportionality and responsibility.
The personal data collected, will be used to provide you information related to the products marketed by BRENNTAG MEXICO, based on the request of information made by you via THE PORTAL, as well as to keep up-dated our Databases and comply with the contractual obligations that, eventually, BRENNTAG MEXICO agrees with you.
Additionally, as a secondary purpose and if you do not object to it, the personal data collected by BRENNTAG MEXICO will be used to (i) to inform about new services and / or products related to those already contracted or acquired, (ii) to communicate changes in our services and / or products, (iii) to promote and to advertise our products, (iv) to develop studies and programs that are necessary to determine consumption habits, (v) to perform periodic evaluations of our products and / or services for the purpose of to improve the quality of them.
The refusal to use your personal data for secondary purposes is not and will not be reason for BRENNTAG MEXICO to not respond to the request of information made by you via THE PORTAL.
The personal data will be kept in strict confidentiality, in accordance with the administrative, technical and physical security measures that BRENNTAG MEXICO implements according to its security policies and procedures.
Therefore, and in order to achieve the aforementioned purposes, the following personal contact, financial and patrimonial identification data will be treated.
III. Data provided via THE PORTAL
When registering in THE PORTAL, it will be understood that your information is correct and that it is your responsibility to manage and use both your User and your Password, therefore, BRENNTAG MEXICO is not responsible for any personality impersonation.
IV. Procedure to limit the use or disclosure of your personal data.
We have designated a person in charge of personal data (the "Privacy Officer"), therefore you can limit the use or disclosure of your personal data at the address of BRENNTAG MEXICO indicated above or, by sending an email to email@example.com.
Notwithstanding the foregoing, it is important to note that (i) not in all cases BRENNTAG MEXICO may meet your request or conclude the use of your personal data immediately, by virtue of the Law, and (ii) for certain purposes, the revocation of your consent will imply that we cannot provide the information required by you, provide the services and / or products requested and / or contracted with BRENNTAG MEXICO.
V. Means to revoke the consent for the processing of personal data
By sending an email to firstname.lastname@example.org, you can revoke your consent to the processing of your personal data. If after the revocation you request confirmation of it; BRENNTAG MEXICO, will respond expressly.
VI. Means to exercise ARCO rights
You have the right to: (i) access your personal data in our possession and know the details of their treatment, (ii) rectify them if they are inaccurate or incomplete, (iii) cancel them when you consider that they are not require for any of the purposes indicated in this Privacy Notice, are being used for non-consensual purposes or has terminated the contractual or service relationship, (it should be mentioned that in case of any legal obligation pending settlement, we could continue to treat your data personal until the end of it) or (iv) oppose the treatment of the same for specific purposes, as the law says, (together, the "ARCO Rights").
- For the exercise of your ARCO Rights, the owner of the personal data must submit an application (the "ARCO Application"), to BRENNTAG MEXICO, S.A. de C.V., to the attention of the Privacy Officer, through the means of contact indicated in this Privacy Notice, accompanied by the following information and documentation:
i. Name, address and email of the owner, to be able to communicate the response to the ARCO Request;
ii. A copy of the documents proving the identity of the owner (voter's credential, passport or any other official identification) or, if applicable, the documents proving their legal representation, whose original must be submitted in order to receive the response from BRENNTAG MEXICO;
iii. A clear and precise description of the personal data with respect to which you seek to exercise any of the ARCO Rights;
iv. Any document or information that facilitates the location of your personal data, and;
v. In case of requesting a rectification of your personal data, you must also indicate the modifications to be made and provide the documentation to support your request.
The Privacy Officer will respond to your ARCO Application and the reasons for its decision by email, within a maximum period of 20 (twenty) working days from the day your ARCO Application was received.
- In the event that the ARCO Request is answered in an affirmative or appropriate manner, the requested changes will be made within a maximum period of 15 (fifteen) business days.
BRENNTAG MEXICO may notify you within the periods referred to in this paragraph of the extension of the same, only once, for a period equal to the original.
In the event of legal or natural incapacity, as is the case of minors or disabled persons under the legal guardianship of a third party, they may exercise their rights of Access, Rectification, Cancellation and Opposition in the terms described above, through the legal guardian, prior identification and accreditation of who holds as a tutor.
- BRENNTAG MEXICO may deny access (the "Refusal"), in the cases ordered by law, and will inform to you about the reason for such decision.
The Refusal may be partial, in such case, BRENNTAG MEXICO will make the access, rectification, cancellation or opposition regarding the respective part.
- The exercise of ARCO Rights will be free, notwithstanding the foregoing, you must cover the justified shipping costs or the cost of reproduction in copies or other formats and, where appropriate, the cost of document certification.
VII. Changes or modifications to the Privacy Notice
BRENNTAG MEXICO reserves the right to make modifications or updates to this Privacy Notice at any time, with the understanding that any modification to it will be made known to you through the publication of a notice on THE PORTAL, so that, we recommend to review it frequently.
In the event of a breach of security in any phase of the processing of personal data, which significantly affects your economic or moral rights, the Privacy Officer will immediately notify you by email of the security breach event, so that you can take the necessary measures to defend your rights.
If you do not have email address, the notification will be published on the BRENNTAG MEXICO website https://integridad-brenntagla.com/.
VIII. Transfers of your personal data.
- We inform you that BRENNTAG MEXICO may transfer your personal data without your consent in the cases mentioned in article 37 of the Federal Law on Protection of Personal Data held by Private Parties, specifically with:
a. Brenntag Latin America Inc. in Houston, Texas, in the United States of America (USA), which is a company part of the same group of BRENNTAG MEXICO, as well as with other affiliates and subsidiaries, with the purpose of carrying out diverse revisions and activities related to the products and / or services requested and / or contracted.
b. Applicable and auxiliary authorities.
c. Other transmissions provided for in the LAW.
- In addition, BRENNTAG MEXICO may share your personal data with (i) legal, accounting and administrative advisors and external auditors, (ii) any type of software and any computer infrastructure that serves to keep your data updated and protected, (iii) suppliers responsible of the safeguard of documents and information in electronic file (iv) bondholders and customs agencies, (v) legal services providers to defend BRENNTAG MEXICO in any legal controversy that may arise.
If there is no express opposition on your part regarding the transfer of your personnel data according to the aforementioned form and terms, it will be understood that you have given your consent in a tacit way to do so.
The third recipients of personal data assume the same obligations as BRENNTAG MEXICO, in accordance with what is described in this Privacy Notice. If the processing of personal data is different to the purposes described in this Privacy Notice, the Third Parties or Persons in Charge will assume the responsibility of handling personal data.
As long as you do not oppose to the processing of your personal data, you will be considered to be granting your tacit consent, even for the aforementioned secondary purposes.
It is recommended to consult the Privacy Notice at least semiannually, to be updated in the conditions and terms thereof, which is available at THE PORTAL
Last Update: July 3, 2019