CHAPTER I

IDENTITY AND ADDRESS OF THE DATA CONTROLLER

DTC IMÁGENES INMOBILIARIAS, S.A. DE C.V., hereinafter referred to as “DTC,” is responsible for the processing of personal data collected from its potential clients, prospects, and clients, in accordance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties, its Regulations, and other applicable provisions.

For the purposes of this Privacy Notice, DTC designates as its address for receiving notices and communications the following: Avenida México number 3370, interior number 3R, Colonia Lomas Santa Rita, Postal Code 44678, Guadalajara, Jalisco, Mexico.

This Privacy Notice is made available to the data subjects through DTC’s website and by any other means through which personal data is collected.

CHAPTER II

PERSONAL DATA COLLECTED

DTC collects personal data directly, either in person or electronically, when the data subject requests information regarding the sale of real estate units, expresses interest in a project or development, provides information for commercial follow-up, or enters into purchase and sale agreements.

The personal data that may be collected is classified as follows:

  • Identification data, such as full name, marital status, handwritten signature, and official identification.
  • Contact data, including address, telephone number, and email address.
  • Financial and asset data, such as banking information, tax data, and payment capacity.
  • Employment data, such as occupation, employer, and income.

DTC expressly states that it does not collect sensitive personal data, as defined in Article 3, Section VI, of the Law.

CHAPTER III

PURPOSES OF PROCESSING PERSONAL DATA

The personal data collected will be used for the following purposes:

Primary purposes

These are necessary for the existence, maintenance, and fulfillment of the legal relationship between DTC and the data subject, including:

  • Responding to requests for information related to the sale of real estate units.
  • Identifying and following up with potential clients and prospects.
  • Evaluating the commercial and financial feasibility of real estate transactions.
  • Creating, managing, and safeguarding client records.
  • Entering into, formalizing, and executing purchase and sale agreements and other related legal acts.
  • Complying with legal, tax, and contractual obligations.
  • Carrying out administrative, accounting, and collection activities derived from the transaction.

Secondary purposes

Additionally, personal data may be used to:

  • Send advertising, promotional, or commercial information regarding developments, projects, real estate units, or services offered by DTC.
  • Conduct satisfaction surveys and market studies.

The data subject may object to the processing of their data for these secondary purposes in accordance with the provisions related to ARCO rights.

CHAPTER IV

TRANSFER OF PERSONAL DATA

DTC may transfer the data subject’s personal data without requiring consent when such transfer is necessary to comply with legal or contractual obligations, or when transferred to:

  • Competent authorities, in legally established cases.
  • Notaries public, financial institutions, legal or tax advisors, and third parties involved in the formalization and execution of purchase and sale agreements.
  • Service providers acting on behalf of DTC, subject to confidentiality and data protection obligations.

In other cases, transfers will be carried out with the data subject’s consent, in accordance with applicable legislation.

CHAPTER V

ARCO RIGHTS AND REVOCATION OF CONSENT

The data subject may exercise at any time their rights of Access, Rectification, Cancellation, or Opposition (ARCO), as well as revoke the consent granted for the processing of their personal data.

To do so, the data subject must submit a written request addressed to DTC, either at the address indicated in this Privacy Notice or via email at holdingsdtc@gmail.com, which must include:

  • The name of the data subject and a means to communicate the response.
  • Documents proving their identity.
  • A clear description of the right they wish to exercise.
  • Any other element that facilitates the location of the personal data.

DTC will respond within the timeframes established by law.

CHAPTER VI

USE OF COOKIES AND TRACKING TECHNOLOGIES

DTC’s website may use cookies and other tracking technologies in order to improve the user experience, analyze browsing behavior, and obtain statistical information. The data subject may disable these technologies through their browser settings.

CHAPTER VII

SECURITY MEASURES

DTC has implemented sufficient administrative, technical, and physical security measures to protect personal data against damage, loss, alteration, destruction, or unauthorized use, access, or processing, ensuring its confidentiality and integrity.

CHAPTER VIII

AMENDMENTS TO THE PRIVACY NOTICE

DTC reserves the right to modify or update this Privacy Notice at any time. Any changes will be published on DTC’s website or communicated to the data subject through the contact information provided.

CHAPTER IX

CONSENT

The data subject acknowledges that they have read and understood this Privacy Notice and grants their consent to the processing of their personal data in accordance with the terms set forth herein, unless expressly stated otherwise.

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