Privacy Policy


Identity and address of the Responsible Party

OPERADORA DE PAGOS MÓVILES DE MÉXICO, S.A. DE C.V. (hereinafter "OPM") with address at Lago Zurich 245, Plaza Carso, Edificio Telcel, Piso 13, Col. Ampliación Granada, Delegación Miguel Hidalgo, C.P. 11529, Ciudad de México, México. This Privacy Policy is primarily intended to comply with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (hereinafter referred to as the "Law").


PURPOSE OF DATA PROCESSING

OPM requests the personal data of its Clients for the following purposes: (i) to identify them, (ii) to enter into Service Provision Agreements for Disbursements, (iii) to inform them about the status of obligations undertaken through the Service Provision, (iv) to make payment requests, (v) to assign or transfer the rights derived from the Service Provision in their favor, (vi) to provide them with information related to the Services, (vii) to offer them the different products and/or services we have available, (viii) to verify and review the data and information provided by the Client, and (ix) for marketing, advertising, and commercial prospecting purposes related to OPM. Clients are also informed that the purposes that gave rise to the existence of the legal relationship are those outlined in subsections (i) and (ii), and those that will serve to maintain and/or fulfill the obligations derived from the legal relationship are contained in subsections (iii), (iv), (v), (vi), (vii), (viii), and (ix).


Through this Privacy Policy, OPM guarantees its Clients the right to express their refusal for the processing of their personal data in relation to the previously stated purposes or any other purpose the Client deems unnecessary for the legal relationship. To do so, the Client must inform OPM of their refusal at the time OPM provides this Privacy Policy, with the understanding that signing the document constitutes the Client's consent. This is without prejudice to the Client's right to revoke previously granted consent or to exercise their right to object to the processing of their data, in accordance with applicable regulations—rights that will always be guaranteed by OPM.


Data Collection

OPM collects its Clients' data (i) in person, and (ii) through any other means permitted by law. The data that OPM collects from its Clients is processed using appropriate technical, administrative, and digital measures to protect their information. The data of OPM's Clients is treated as secret and confidential by OPM, which takes the necessary measures to prevent its alteration, loss, unauthorized processing, or access.


The Client declares that their data is accurate, authentic, and complete, and they take full responsibility for the data provided. Therefore, OPM is released from any related liability. The data that Clients freely and voluntarily provide to OPM includes: identification data, employment data, financial data, and information about their occupation.


By using our services you authorize OPM to process your data in the terms indicated in this privacy policy.


Description of Services

The aforementioned information is provided voluntarily by you, confirming your agreement that it will be used to fulfill the disbursement services detailed in the document that formalizes the legal relationship between you as the Client and OPM as the service provider (hereinafter referred to as the "Services").


Primary purposes

OPM will process your personal data to carry out some or all activities necessary for the development and fulfillment of the contractual and/or commercial relationship established with you, which includes providing the services described in the previous section; any activity aimed at promoting, maintaining, improving, and evaluating the Services; generating statistical reports; using technology to validate data; processing transactions; verifying your identity; identifying potential risks; preventing fraud; and managing the use of the portal.


Secondary Purposes

OPM will process your personal data to carry out any or all secondary purposes such as: evaluating your behavior patterns to inform you of the launch or changes of new products, goods, services and/or promotions of OPM according to your interests, as well as other brands and/or affiliated companies and/or subsidiaries of OPM, or third parties with whom OPM has entered into a contract to improve the Services for your benefit, including sending communications through short messages and other physical and/or electronic means of communication.


If you do not want OPM to process your personal data for any of the purposes described in this section, please send an email to datospersonales@transfer.com You may change your preference at any time.


Transfers

In order to fulfill the obligations arising from the legal relationship with you, as well as the purposes outlined in this Privacy Policy, OPM may share, without requiring your consent, the necessary personal data with competent authorities in legally mandated cases; with affiliated and/or subsidiary companies of OPM; or with third parties with whom OPM has entered into a contract to improve the Services for your benefit. This may include allowing these companies and/or third parties to contact you, directly or indirectly, to address clarifications regarding transactions made, as well as for promotional activities and/or the offering and provision of products and/or services. We inform you that these companies operate under privacy policies that comply with the applicable legal provisions. For the purposes of this Privacy Policy, an "affiliate" refers to any company that, directly or indirectly, through one or more intermediaries, either has control over, is controlled by, or is under shared control with the specified company.


If you do not wish for your personal data to be used for transfers that require your consent, please inform us via email.


Means and procedure to exercise ARCO rights and/or revoke consent for the processing of personal data

You or your legal representative may exercise any of the rights of access, rectification, cancellation, or opposition (hereinafter "ARCO Rights"), as well as revoke your consent for the processing of your personal data by sending an email to datospersonales@transfer.com where your request will be addressed in a timely manner.


In order for your request to be processed, you or your legal representative must properly verify your identity (full name, address or email, documents that prove your identity such as an INE, passport, or professional license). In the case of a legal representative, representation must be proven with a letter of attorney signed before two witnesses or a power of attorney granted before a notary public, along with the legal representative's identification. Additionally, you must provide a clear and precise description of the Personal Data for which you wish to exercise any of the ARCO Rights.


If the information provided is incorrect or insufficient, or if the required supporting documents are not included, within five (5) business days following receipt of the request, OPM may request that you provide the necessary elements or documents to process the request. You will have ten (10) business days to respond to the request, starting from the day after you receive it. If no response is provided within this period, the request will be considered as not submitted.


OPM will inform you of the decision made within a maximum of twenty (20) business days from the date the request was received, and if approved, it will be implemented within the following fifteen (15) business days after the response is communicated. The response will be sent electronically to the email address specified in your request.


Options and means to limit the use or disclosure of your personal data

You may limit the use or disclosure of your personal data by sending your request to datospersonales@transfer.com under the same terms mentioned in the previous section.


Means of communicating changes to the Privacy Policy

OPM reserves the right, at its sole discretion, to change, modify, add, or remove parts of this Privacy Policy at any time. In such a case, OPM will publish these changes on the technology platform and indicate the date of the latest version of the policy. For any questions regarding data privacy, please send an email to datospersonales@transfer.com and we will be happy to assist you.


August 2023