Intellectual Property and Copyright

TOROTO, S.A.P.I. DE C.V.

This document constitutes the Privacy Notice for the purposes of the Federal Act on the Protection of Personal Data Held by Individuals (hereinafter, the “Act”), its Regulations, as well as the Guidelines of the Privacy Notice (hereinafter, the “Legislation”). Therefore, this Privacy Notice (hereinafter, the “Notice”) applies to personal information collected about the Data Subject by Toroto, S.A.P.I. de C.V. (hereinafter, “Toroto”). For the purposes of this Notice, the terms used that are not defined therein shall have the meaning given in the Legislation.

Identity and address of the Responsible

Toroto, a company incorporated in accordance with the laws of the United Mexican States, with address at Tabasco 166, Colonia Roma Norte, Mexico City, is responsible for the collection, use, storage and disclosure of the personal data of the Owners, as established in this Notice, ensuring in its capacity as responsible the appropriate use, protection and confidentiality of the same, observing at all times the established principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility in the Legislation.

Personal data

In order to provide you with the services and products you request or contract with Toroto, we require identification and contact data, including full name, address (s), cell phone number, landline and alternative telephone number, email, unique population registration code (CURP), place and date of birth, sex, marital status, nationality, tax address, digital autograph signature, RFC, voter ID number, social security number, employment information including type of employment, employer and employment number, information patrimonial and/or financial, geolocation and employment information. In addition, we may collect sensitive data classified as biometric, such as fingerprint, facial and iris recognition and the following data of the company you represent: company name, address, RFC; identification and contact data, verification through social networks, equity and/or financial data, data on current debts, income and expenses, type and type of business.

Information about the devices or computers from which the Platform is accessed and other automatically captured data (such as type or version of the browser or operating system, settings, connection data, information about some downloaded applications and parameters), IP address used when connecting to our services or browsing the Platform, certain information about the activity of users and visitors within our website and apps, the URL from which they come or what URL they access next (whether or not they are in our website). The pages visited, interactions with those pages, searches carried out, publications, purchases or sales, ratings and answers entered, complaints made and received, messages in forums, and other information can also be stored and kept.

Personal Data may be collected in person or through our website https://toroto.com/ (the “Site”), our computer application (the “App”) or by any other electronic, telephone, video or technological means (the “Electronic Media” and together with the Site and the App, the “Platform”), including landing pages, hyperlinks or plug-ins within the Platform and, where appropriate, through agents, promoters, commissioners, suppliers or business partners when (without limitation) the Owner: (i) registers to make use of any of the services available on the Platform, (ii) use the Platform, (iii) send questions, inquiries or comments or contact the Platform; (iv) request information or materials; and/or (v) provide information to the Platform in any way (chats, forums, uploads, etc.).

Purposes

Toroto will use your data for the following purposes:

Compliance with the contractual relationship derived from the request and/or contracting of our Services.
Identify the person who contracts with any Toronto Service.
Identification or verification of identity based on biometric data.
Verify and validate the information provided by the customer.
Manage, operate and follow up on the services and products requested or contracted.
Perform operations, provide services and hold events in accordance with the law and corporate bylaws.
Generate files for customer monitoring.
Process requests made through the Platform.
Comply with knowledge of the customer (KYC) provisions and money laundering prevention
Report changes or new related products or services.
Evaluate the quality of the service.
Validate financial conditions of people with debts or arrears.
Promotion of products, services, benefits, discounts, promotions, contests and market research.
Respond to inquiries, complaints or complaints.
Prepare statistics for research purposes.
In the event of a merger, acquisition or restructuring.
Link between accounts and users in fraud prevention efforts.

Secondary Purposes:

Send newsletters, marketing information and commercial prospecting.
Conduct business intelligence and market research.
Monitor and improve the Platform.

If you do not want your data to be processed for secondary purposes, you can object at any time by writing to hola@toroto.mx.

Transfer of Personal Data

Toroto may transfer your personal data, inside and outside the country, to:

Affiliated, parent or subsidiary companies.
Companies with which you have business relationships.
National and international authorities.
Financial institutions and credit bureaus.
Legal and financial advisors.
Technology providers.
Other users and/or visitors to the Platform.

These transfers may be made without your consent in accordance with Article 37 of the Act.

ARCO Rights

You can exercise your rights of Access, Rectification, Cancellation or Opposition (ARCO) by sending an email to hola@toroto.mx or in writing with acknowledgment of receipt. The request must contain:

(i) Full name, address and means of contact.
(ii) Identity documents.
(iii) Clear description of the data you want to exercise your rights over.
(iv) In case of rectification, indicate modifications and supporting documents.

Toroto will respond within 20 business days and, if appropriate, will take effect within 15 days. In case of incomplete information, the applicant may be requested within 5 days.

Revocation

The Owner may revoke their consent at any time following the same procedure as ARCO rights, unless this prevents them from complying with obligations deriving from a current legal relationship.

Restriction of Use or Disclosure of Personal Data

You can request the limitation of the use or disclosure of your data for marketing or advertising purposes by sending an email to hola@toroto.mx or by signing up to our exclusion list.

Toroto is not responsible for the use that any user or third party makes of the information published on the Platform.

Amendments to the Privacy Notice

This Notice may be modified due to regulatory, business model, privacy or other causes. Changes will be notified through the Portal or directly. The Owner will have 5 days to express their disagreement; otherwise, it will be considered accepted.

By using electronic media and providing your data, you acknowledge and accept this Notice. If you consider your right to data protection violated, you can go to the National Institute for Transparency, Access to Information and Protection of Personal Data (INAI).