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Comprehensive Privacy Policy

To comply with the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter the “Law”), its Regulations and other applicable legal provisions, this Privacy Notice is made known to you, in order to inform you of the information that we will collect from you, the purposes thereof and other obligations contemplated in the Law, its Regulations and other applicable legal provisions.You are informed that you have the right to self-determine the legal treatment and control of the information you provide us, so that the data is used for the purpose for which it was intended, preserving its confidentiality and privacy.

Responsible for the Processing of your Personal Data.
POLIBIT, SAPI DE CV
, commercially known as “PoliBit” (hereinafter “PoliBit”), with address at Calle San Juan Capistrano, number 107, Fraccionamiento Nuevo Bernardez, in the City of Guadalupe, Zacatecas, Mexico, CP 98610, is responsible for the treatment of your personal data collected by PoliBit, whether through any electronic means, paper format, electronic format of the application or website of www.polibit.io, telephone or other means that has the purpose of obtaining personal data , as well as safeguarding the privacy of the data that you provide us as a client or potential client, informing you that your information will be processed exclusively for the purposes indicated in this Privacy Notice, in accordance with the provisions of the Law.

Department of Personal Data Protection:
Address: Calle San Juan Capistrano, number 107, Fraccionamiento Nuevo Bernardez, in the City of Guadalupe, Zacatecas, Mexico, CP 98610
Email:admin@polibit.io Telephone: +52 4924910708

NON-sensitive Personal Data that is collected.
The personal data that PoliBit will request or may request from its Users are:Contact information: full name, telephone number (home or cell phone), email, address, proof of address. Client identification data: Official identification with photo, Tax Identification (Federal Taxpayer Registry or equivalent in case the User is a Foreigner), tax address, name(s) and surname, date of birth, sex.
Financial Information: data related to payment, such as investment amount per project and accumulated, payment method such as bank accounts and debit or credit card information at the time of payment for the services and products offered.In terms of article 8 of the Law, for the purposes of the aforementioned personal data, it will be understood that you tacitly consent to the processing of your personal data, when this privacy notice having been made available to you, you do not express your opposition.

Sensitive Personal Data.
We inform you that PoliBit will not collect any sensitive data from you.

Purposes for which your Personal Data is collected and used.
In terms of the applicable legal provisions, the processing of personal data collected will be used for data verification, creation of internal dashboards of the platform, creation of trends based on the information collected to attract new projects and profiling of clients, as well as to analyze and improve the platform, optimize and create new features of the Website, as well as to hire theservicesthat PoliBit offers, as well as carrying out all kinds of legal acts in terms of our corporate purpose.

Transfer of Personal Data within PoliBit.
PoliBit may share the personal data provided by you with the different corporate departments of the company, as well as the different subsidiary, affiliated and controlling companies of PoliBit, whether they are located within the Mexican Republic or abroad, with the purpose of fulfilling the purposes set forth in this Privacy Notice as well as to comply with contractual obligations that may be had with you, as owner of the corresponding personal data. Likewise, PoliBit may share the information provided by you with any personal data manager that it may designate, in accordance with article 49 of the Regulations of the Law.

Transfer of Personal Data with Third Parties.
PoliBit may share some of your personal data with other companies, for data verification purposes, as well as the transfer of data consisting of certain financial information with third parties.Likewise, the transfer of your data may be carried out with SumSub, as well as with automatic billing providers, the National Banking and Securities Commission when requested, Real Estate Developers and the electronic signature platform commercially known as DocuSign, as well as with a payment gateway and fraud engine services.

Obtaining Personal Data and source thereof.
To carry out the collection of personal data, PoliBit is governed by the principles of legality, quality, consent, information, purpose, loyalty, proportionality and responsibility established in the Law. We collect the data of the owner in person or through means electronics, Website, email, parcels, telephone, among others, to guarantee their reliability. Additionally, PoliBit may obtain information through lawful means established by Law, among others, telephone directory, public databases such as the Public Registry of Property and Commerce or any other agency or public source of information. In addition to what is indicated, for the purposes indicated in this Privacy Notice, personal data may be collected in different ways: when you provide it to us directly; when you visit our application or website or use our online services, and when we obtain information through other sources that are permitted by Law.Any information concerning an identified or identifiable natural person that is provided on our Internet page may also be collected.

Limitation of the use or disclosure of your Personal Data.
In order for you to limit the use and disclosure of the data collected by PoliBit, we put the following means at your disposal: (i) the registration of the data in the Public Registry, which is in charge of the Federal Consumer Prosecutor's Office ( PROFECO), with the purpose that your personal data is not used to receive advertising or promotions from goods and services companies. For more information about this registry you can consult the PROFECO Internet portal, or contact it; (ii) Your registration on an exclusion list, so that your personal data is not processed for marketing, advertising or commercial prospecting purposes by PoliBit.

Way to access or rectify your personal data or cancel or oppose its use (ARCO Rights).You have the right to access your personal data that we have and the details of its processing, as well as to rectify them if they are inaccurate or incomplete; cancel them when you consider that they are not required for any of the purposes indicated in this Privacy Notice, they are being used for non-consensual purposes or the contractual or service relationship has ended, or oppose their processing for specific purposes.The mechanisms that have been implemented for the exercise of said ARCO rights are through the presentation of the written request by email, addressed to the Department of Personal Data Protection with the following informationa).- Full name of the owner.b).- Address of the owner of the personal data or email address, through which the response to your request can be sent.c).- Official documents that prove identity.d).- For legal entities, it is necessary to attach the documents that prove the legal existence of the company, as well as those that contain the powers and faculties of the legal representative, as well as the official identification of the legal representative.e).- Clear and precise description of the personal data, with respect to which you seek to exercise any of your rights.f).- Any other element or document that facilitates the location of personal data, as well as any other document required by current legislation at the time of submitting the application.The request will be resolved within a period of 20 (twenty) business days following the date of receipt of the request. However, PoliBit will at all times have the right to extend the aforementioned term on a single occasion for an equal period, as long as it is justified and the circumstances of the case so warrant.The exercise of the rights of access, rectification, cancellation or opposition may be denied in the following cases:When the applicant is not the owner or legal representative of the legal entity and/or does not prove the legal existence of the person he represents or his powers and faculties are not sufficient to exercise the rights in question.When the applicant's personal data is not found in PoliBit's databases.When the rights of a third party are violated.When there is a legal impediment or resolution of a judicial or administrative authority.When the rectification, cancellation or opposition has been previously made so that the request lacks substance.Additionally, PoliBit will not be obliged to cancel your personal data, when it comes to any of the following cases:That refers to the parties of a private, social or administrative contract and are necessary for its development and fulfillment.When they must be treated by legal provision.When judicial or administrative actions linked to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions are hindered.When necessary to protect the legally protected interests of the owner.Are necessary to carry out an action based on the public interest.They are necessary to comply with an obligation legally acquired by the owner, andAre subject to treatment for prevention or for medical diagnosis or management of health services, provided that said treatment is carried out by a health professional subject to a duty of secrecy.

Revocation of your consent for the processing of your data.
At any time, you may revoke the consent you have given us for the processing of your personal data, so that we stop using it. To do this, it is necessary to make a request to the Department of Personal Data Protection that must contain the following information:a).- Full name of the owner.b).- Address of the owner of the personal data or email address, through which the response to your request can be sent.c).- In the case of natural persons, official documents that prove identity.d).- For legal entities, it is necessary to attach the documents that prove the legal existence of the company, as well as those that contain the powers and faculties of the legal representative, as well as the official identification of the legal representative.e).- Expressly indicate the request to revoke consent for the processing of personal data, expressing the reasons why you wish to do so.Within a maximum period of 20 (twenty) business days, your request will be attended to and we will inform you of its origin through the means indicated in your request.It is worth mentioning that, notwithstanding your request, PoliBit will retain the right to process certain information as permitted or required by Law.

Blocking and Deletion of Personal Data.
You are informed that once the purpose(s) of the processing have been fulfilled and when there is no legal, administrative or regulatory provision that establishes otherwise, the data will be canceled after blocking them, for their subsequent deletion.

Security and Storage.
PoliBit undertakes to implement technological and administrative security measures to protect your personal data from unauthorized processing, whether on its own or by hiring a third party for this purpose. To do this, the information provided will be kept in databases that have the highest technology in security and encryption to prevent information leaks.

Modifications to the privacy notice.
PoliBit reserves the right to make modifications or updates to this Privacy Notice at any time, to address legislative developments, internal policies or new requirements for the provision or offering of our services or products.It will be understood that you accept the modifications made to the Privacy Notice when you continue to use the Services provided by PoliBit, including those provided through the use of its applications or internet pages.

Use of cookies and web beacons on the Website.Cookies are text files that are automatically downloaded and stored on the hard drive of the user's computer when browsing a specific Internet page, which allow the Internet server to remember some data about this user, including their preferences for viewing the pages on that server, name and password.For their part, web beacons are images inserted into an Internet page or email, which can be used to monitor the behavior of a visitor, such as storing information about the user's IP address, duration of interaction time on said page and the type of browser used, among others.We inform you that our Website may use cookies and web beacons to obtain personal information from you. In that sense, these cookies and other technologies can be disabled.

Legal Provisions.This Privacy Notice complies with all current provisions established in the Law, its Regulations and other applicable legal provisions.

AS I NAVIGATE THROUGH THE SITE I EXPRESSLY CONSENT THAT ALL MY PERSONAL DATA BE PROCESSED IN ACCORDANCE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE, INCLUDING, WITHOUT LIMITATION, THE TRANSFER OF THE SAME IN ACCORDANCE WITH WHAT IS ESTABLISHED HERE.

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