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Update date: August 2022.

This Privacy Notice is made known to Users in compliance with the provisions of the Federal Law on Protection of Personal Data in Possession of Individuals ("FLPPDPI").

1. Identity, address and contact information of the controller.
QUALLIX FINANCIAL INSTITUTION, JOINT STOCK COMPANY, MULTI-OBJECT FINANCIAL COMPANY, UNREGULATED ENTITY ("CUALLIX"), with address at Allende number 355 Pte., Colonia Centro, C.P. 64000, Monterrey, Nuevo León, Mexico, will be responsible for data processing of the Users and their use and their protection. This Notice Privacy provides information on how CUALLIX, as well as its related companies, use Users' personal data, and their rights as users of the Site.
CUALLIX has appointed a data protection department ("DDP" as the term is defined below) who will be responsible for the supervision of questions related to this Privacy Notice. In case Users have any questions related to this Notice or if you wish to obtain information about it, you should contact the DDP using the following data:

Av. Allende 355 Pte Centro
Monterrey, NL, México, C.P. 64000,
4 A/A: Office of Personal Data Protection


2. What personal data are collected from Users?
CUALLIX, depending on how Users interact with and on the Site and/or with others Users and/or CUALLIX and/or the Products and Services exclusively for the purposes contained in this Privacy Notice, will collect personal data, within which data may be located personal identification, financial and/or patrimonial data and sensitive personal data (limited exclusively to physical characteristics and biometric information of the User), that will be collected according to the following and your consent will be required as provided the FLPPDPI:
a. When visiting the Site, including through cookies and third-party applications:
• Internet Protocol Directorate ("IP" for short);
• Type of browser and operating system used by the User to access the Site and versions of them;
• Duration of your interaction or session on the Site;
• Language preferences;
• Links they visit and/or information regarding the meaning of the traffic through which they enter or remove Users from the Site;

b. When creating an account, it must be created in accordance with the Terms and Site Conditions:
• Identification data, including without limitation, name and surname, official identification, passport, national military service card, license and/or photograph of the User;
• Contact details, including without limitation, address, proof of address, mail electronic and/or telephone;
• Financial and/or patrimonial information, including without limitation, bank account number, CLABE, beneficiary(s) and financial institution data.

c. When interacting with CUALLIX through KYC Formats:
• Identification data, including without limitation, name and surname, identification officer;
• Contact details, including without limitation, address, proof of address, mail electronic and/or telephone;

d. When interacting with CUALLIX using electronic registers:
• Information related and inherent to emails, telefax, filling of formats or documents, calls and telephone records, audio recordings, /images or videos, VoIP (Voice Over Internet Protocol) audio-visual communications;

Likewise, the User acknowledges and accepts that CUALLIX may collect information from you by any other than those previously established, where such information is recorded in records or public databases, as they may be and including without limitation:
a. Governmental sources;
b. International organizations;
c. Social networks or platforms (e.g. Facebook, Twitter, Instagram, etc.) d. Photos via platforms or search engines (e.g. Google Maps, etc.)
CUALLIX will not disclose the information collected from Users, nor may it sell, market or lease personally identifiable information to third parties; unless otherwise authorized Users. Notwithstanding the foregoing, Users' information may be used for the use patterns research, product and service development, operation of the Site, generation and publication of statistical data, customization of online and targeted marketing.
Sensitive Personal Data. As stated above, CUALLIX may, from time to time, collect information from Users that are, or may become, considered as data sensitive personnel by the FLPPDPI; in which case CUALLIX will only obtain such information when the User voluntarily provides it and will only be used to attend the interaction of Users on the Site and with CUALLIX, and if applicable, comply with the obligations arising from the legal relationship that CUALLIX may have with the User or the User with other User or User with Products and Services.
When the User enters the Site, the Site may be using digital platforms, sites or third party platforms, or technologies such as cookies, Flash cookies, pixels and web bugs or beacons, among others, to satisfy the functionalities of this Privacy Notice. In If you enable the Users on your device a cookie prevention function, some of the services and features of the Site may cease to operate or otherwise operate differently.


3. What are Users' personal data used for?
The collection and processing of Users' personal data is carried out for the following primary and secondary functionalities, which CUALLIX considers necessary for the existence, maintenance and fulfillment of the legal relationship they might sustain with the Users, the Site and its business activities:
a. Primary purposes:
i. Verify and confirm identity, contact information and financial situation and/or patrimonial of the Users;
ii. Manage and operate the Products and Services that Users request or contract with CUALLIX or other Users through the Site or other platforms operated by CUALLIX;
iii. Protect the Site, platforms operated by and CUALLIX system from any fraud or ruse;
iv. Provide and improve service to the User;
v. Comply with the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin;
vi. Communicate with Users by any means;
vii. Receive complaints, and follow up requests;
viii. Process payments, including deposits, withdrawals and conversions made by Users to through the Site, the platforms operated by CUALLIX, and the Products and Services;
ix. Comply with any local, state, and federal laws or regulations;
x. Carry out the regular commercial activities of CUALLIX and any other activities similar or similar to the above;
xi. Perform risk profiles based on the methodology established by CUALLIX, which is briefly referred to as Annex 1 of this Privacy Notice.

b. Secondary purposes:
i. Conduct surveys of services that allow CUALLIX to improve its products, services, platforms, and content;
ii. Send notifications, notices, promotional messages or communications for marketing, advertising or telemarketing;
iii. Conduct surveys, statistics; market research; consumer habits records through automatic data, interest and behavior capture tools.
When indicated by the User in accordance with the procedure established herein, CUALLIX will proceed to unsubscribe the User from their database to send information about Products and CUALLIX services, through which the User will receive advertising messages, same as the User may request to stop receiving at any time, using the mechanism included in such couriers.


4. Transfers of personal data.
CUALLIX may send all or part of the Users' personal data to Providers of Services that support CUALLIX in some process. Such Service Providers include: (i) technology companies providing various telecommunications or infrastructure services, (ii) undertaking providing marketing and market research services and (iii) providers of services of any other nature. In all these cases, CUALLIX ensures that these companies assume contractual obligations that allow Users' personal data to be is protected, in addition to the knowledge of the Service Providers, the obligations under the FLPPDPI.


5. To whom can CUALLIX transfer your personal data?
CUALLIX may transfer Users' personal data to other companies in the corporate group to which it belongs, to the persons authorised by the FLPPDPI and to the competent authorities, in certain for the purposes set out in this Privacy Notice. These transfers include: the following:
• CUALLIX may transmit Users' personal data to other companies in the same group company. Therefore, the data can be transferred to its subsidiaries, which can located in Mexico or other countries. CUALLIX subsidiaries that may receive or to consult the personal data of Users have implemented measures and policies for the protection of their personal data; these policies are consistent with those of CUALLIX and intend to comply with the provisions of the laws of each applicable country.
• Likewise, CUALLIX may transfer the personal data of Users of the Site to authorities administrative or judicial, when the transfer is necessary or legally required for the safeguarding a public interest, protecting the rights of CUALLIX, protecting rights of third parties or for the procurement or administration of justice.
• Also, occasionally, CUALLIX may be a party to any corporate transaction (including mergers, divisions, sales of assets or shares, corporate restructuring, among others transactions). Whereas Users are usually one of the assets to be considered as part of the transaction, CUALLIX may communicate the Users' personal data to third parties on the context of such transactions. Such third parties include, inter alia, the potential acquirers of assets and advisers (legal, accounting or financial, between others) involved in the transaction. Only personal data shall be communicated to them third parties to the extent that such communication is necessary to assess or complete the transaction or where the transfer is necessary as a result of the transaction.
• In other cases, where the law permits this transfer without the prior consent of the holder, in terms of Articles 10 and 37 of the FLPPDPI.

All previous transfers (and referrals included in clause 4 above) may be national or international; they are all necessary for the maintenance or compliance with the commercial relationship with the Users and, therefore, no User’s consent to perform them.


6. Collaborators in matters of Personal Data.
a. IT Service Providers: CUALLIX uses a number of trusted collaborators to provide IT and system management services for both your activities with Users as for their internal management and IT systems.
b. Payment providers and processing partners: To ensure a secure payment process and effective online, through billing or money transfers.
c. Cloud storage partners: CUALLIX stores both its own and its Users in secure data warehouse centres.
d. Partners and agencies for fraud detection and prevention: Work together with CUALLIX to ensure that it does not suffer any fraud.
e. Business partners: To offer ads, promotions and advertising campaigns personalized, whether you are interacting with CUALLIX through the Site or through social networks, as in any other occasion.
f. Social Media Contributors: To have a presence and allow Users to interact with CUALLIX on the platforms you use.
g. Survey, questionnaire and product review providers: Help CUALLIX ensure who receive all important feedback about the Users' experience in the Site and with CUALLIX.
h. Tax and customs authorities, regulators and other competent authorities: Request reporting of processing and processing activities in certain circumstances.
i. Professional advisors: Including lawyers, bankers, auditors and insurers; offer CUALLIX consultancy services, banking, legal assistance, insurance and accounting.


7. What are the rights of Users?
In accordance with the FLPPDPI, Users enjoy the rights of Access, Rectification, Cancellation and Opposition to Treatment (the "ARCO rights"); also count on the right to revoke at any time the consent granted for the processing of your data to the extent permitted by law. For the exercise of your rights ARCO or your right of revocation or to make any doubt or complaint regarding the processing of your data the User must contact the Personal Data Department ("DDP"). Of the in the same way, at any time may modify the personal data that have been provided from each User’s account settings on the Site.
User requests will be evaluated under the terms set forth in the FLPPDPI and other obligations applicable to CUALLIX. Therefore, the User shall make his requests in accordance with format found for that purpose on the Site.
The foregoing, on the understanding that the application form shall include:
a. Identification data and contact details of the User; or, where applicable, documents evidence the personality of his legal representative and the identification and contact details of the same;
b. The clear and precise description of the data for which one of the ARCO rights; y
c. Any other applicable information or document;


8. What options does CUALLIX offer to limit the use or disclosure of the personal data of Users?
CUALLIX gives Users the ability to make decisions about how CUALLIX uses their data for which, CUALLIX offers the User various means to inform himself about its decision.
If the User does not wish to receive advertising messages from CUALLIX or cancel his subscription to databases, the User may: (i) request to unsubscribe from the lists of CUALLIX mail using the mechanism established in the respective emails; and/or (ii) may contact the DDP.


9. Security of your personal information.
CUALLIX has adopted physical, organizational, and technical security measures to protect Users' personal data against loss, use or unauthorized access, in compliance as provided by the FLPPDPI.


10. Changes to the Privacy Notice.
CUALLIX reserves the right to make changes or updates at any time to present Privacy Notice. The modified notice will be posted in visible places on the Site or will be sent to the User through the email provided, in case of having contact information. Users may verify that the Privacy Notice has been modified under that CUALLIX will always notice the date of its latest update. In case CUALLIX make any substantial changes in the processing of Users' personal data, which modifications will be made known to them through a notification to the mails Users, when contact details are available, or by announcing these changes in the Site. Any changes to the Privacy Notice will take effect within 15 (fifteen) calendar days of their respective publication. If the User does not agree with the modifications, he may contact to DDP.


11. Miscellaneous.
Notwithstanding any provision to the contrary contained herein and any other document relating to or relating to CUALLIX or the Site, access to the Site or the products and services of CUALLIX by any platform or means establishes the express and flat consent of this Privacy Notice.
Terms written in capital letters at the beginning that are not defined within this Privacy Notice will be defined by the Terms and Conditions of Use of the Site.

Annex 1
Table of Risk Profiles

Note: Moral Persons will be considered as Level 4 for information and analysis requirements.

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"Cuallet" is an application for web and smartphones owned by Payllix S.A of C.V., through which you can manage different financial products and services, national and international, credit products granted by Financiera Cuallix S.A de C.V SOFOM ENR and/or Financiera de México Múltiple S.A of C.V SOFOM ENR and savings and investment products granted by Caja Bugambilia S.C of C.V.

American Express is a brand of American Express®. Cards are issued by Financiera Cuallix S.A de C.V SOFOM E.N.R under license from American Express. The authorization to carry out resource raising operations is supported in the permits of Bugambilia Ahorro Productivo S.C. de A.P. de R.L. de C.V. and are supervised by the Fideicomiso del Fondo de Supervision Auxiliar de Sociedades Cooperativas de Ahorro y Prestamo y de Protección a sus Ahorradores (FOCOOP). It is known that neither the Federal Government nor any other entity of the Public Administration can take responsibility or guarantee the resources of the users who are used in transactions concluded with "Cuallet", nor will they assume any responsibility for the obligations contracted by "Cuallet" or by any with respect to the operations they perform.