INTEGRAL PRIVACY NOTICE
SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE (SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE)
Insaite Sociedad Anónima Promotora de Inversión de Capital Variable, with commercial name Insaite (hereinafter Insaite), with address at Boulevard Manuel Ávila Camacho 156, piso 3, oficina 302, colonia Reforma Social, Código Postal 11650, alcaldía Miguel Hidalgo, Ciudad de México, México, is responsible for the treatment of your personal data, for which reason it makes available to you the Integral Privacy Notice, at the website https://www.insaite. io/, where you can find out how we treat your personal and patrimonial data; control and prevention measures taken to ensure that your information is secure and remains confidential, as well as the procedures to exercise your rights of access, rectification, cancellation and opposition (hereinafter “ARCO rights”) to your personal data, in terms of the Federal Law for the Protection of Personal Data in Possession of Private Parties (hereinafter “LFPDPPP”) and the Regulation of the Federal Law for the Protection of Personal Data in Possession of Private Parties (hereinafter the “Regulation”).
RESPONSIBLE
The person responsible for the handling and administration of personal data is Insaite, who can be contacted by email at insaite@insaite.io, through our website https://www.insaite.io/, or directly at our offices located at Boulevard Manuel Avila Camacho 156, 3rd floor, office 302, colonia Reforma Social, Zip Code 11650, alcaldía Miguel Hidalgo, Mexico City, Mexico.
DEFINITIONS
For the purposes of this PRIVACY NOTICE, the following terms shall have the meanings indicated in this document, whether they are written in singular or plural:
Personal Data: Any information concerning an identified or identifiable natural person.
Sensitive Personal Data: Those personal data that affect the intimate sphere of the holder, or whose improper use may give rise to any type of discrimination or entail a serious risk for the holder. Data that may reveal personal aspects of the holder, such as racial, ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union membership, political opinions, sexual preference or financial situation are considered within this category.
ARCO Rights: The right of the holder of the personal data to request access, rectification, cancellation or opposition to the data controller with respect to such data, in accordance with the provisions of the LFPDPPP and its Regulation.
Dissociation: The procedure by means of which personal data cannot be associated with the holder or allow, due to its structure, content or degree of disaggregation, the identification of the holder.
Processor: The individual or legal entity that alone or jointly with other individuals or legal entities processes personal data on behalf of and under the instruction of the data controller, in accordance with the processes, terms and conditions indicated by the data controller.
LFPDPPP: Federal Law for the Protection of Personal Data in Possession of Individuals.
Regulation: Regulation of the LFPDPPP Federal Law for the Protection of Personal Data in Possession of Individuals.
Responsible: It is Insaite, and its subsidiaries and branches, acting individually or jointly with other entities of the same Business Group collects personal data for processing in accordance with the purposes stated in this PRIVACY NOTICE.
What is personal data?
It is any information concerning an identified or identifiable natural person, such as name, address, academic background, gender, marital status, financial information and any other information related to the owner of such data.
What are ARCO rights?
These are the rights that the holder of the personal information has, which allow him/her to access, rectify, cancel and oppose the processing of his/her personal data. This right is yours and you can exercise them at the time you decide. Insaite S.A.P.I. de C.V., offers you the procedures to exercise them effectively.
Why do we collect personal data?
Insaite is a company incorporated under the laws of the United Mexican States, which provides platform services, methodology, use cases of our technology and related content. Therefore, the personal data that is collected has the exclusive purpose of complying with the purpose of this company.
What personal data do we collect?
The information that is collected is that which is considered necessary to provide the service described in the conditions and terms of use, and that namely is:
PERSONAL INFORMATION:
- Full name
- Your full name
- Address including zip code
- Date of birth
- Cell phone number
- Landline phone
- RFC
- Unique population registry number
- Marital status
- Copy of official identification
- Employment data
Where do we collect your personal data?
The personal information we have was provided by or on behalf of the owner of the same, by electronic means on our website https://www.insaite.io/, at the time of requesting a study to obtain financing. Also, personal data could be collected through our email insaite@insaite.io, directly in person or in writing at our offices located at Boulevard Manuel Avila Camacho 156, 3rd floor, office 302, colonia Reforma Social, Zip Code 11650, alcaldía Miguel Hidalgo, Mexico City, Mexico.
What is the purpose of the personal data we collect?
The personal data we collect from you will be used to be able to provide our services and to comply with the terms and conditions of service, being the following:
A) MAIN PURPOSE
The identity of the owner and the veracity of the information you provide as your own.
To process the requests you make through our electronic media.
Create your profile as a user of our electronic media.
Send and receive communications through our electronic media related to our Services.
Share with third parties with whom Insaite maintains a relationship, either nationally or internationally, for the sole purpose of providing you with a better service. These third parties have personal data protection mechanisms that comply with international provisions and are homologous to those used by Insaite.
B) SECONDARY PURPOSE
To prevent illegal or prohibited activities, and to enforce our terms and conditions.
To personalize, measure and improve our services, content and advertising.
To inform you of service updates.
To give you visibility to your activity on our electronic media.
To monitor the quality of our electronic media, to evaluate and improve our Electronic Media, to send you our newsletter and offers.
By granting your consent for the processing of your personal data, you authorize the responsible to use them for sending advertising information by the means that the responsible has at its disposal, such as email, cell phone (SMS message, MMS) social networks, or any other similar means of electronic communication that may be developed, as well as the sending and collection of information through quality surveys.
In case you do not want your data to be used for these secondary purposes, through the email insaite@insaite.io you can oppose its use, according to the procedure described below to exercise your ARCO rights, which will be appropriate to not be necessary to comply with the terms and conditions of service. You will have the option, each time you receive our newsletter and offers, to unsubscribe from it by following the process established at the bottom of the email through which such material is sent to you. The refusal to use your personal data for secondary purposes may not be a reason for us to deny you the services and products you request or contract with Insaite.
Why do we collect your personal data?
They are necessary for Insaite, to develop all necessary activities, direct and indirect, to provide a complete, transparent, efficient and effective service according to the terms and conditions of service.
For what purposes is the data shared with third parties?
We inform you that Insaite belongs to Grupo Rubik, which is composed by Clicknbox and Rubik, both constituted as Sociedad Anónima Promotora de Inversión de Capital Variable (S.A.P.I de C.V.); likewise, it is possible that Insaite may share your personal data with third parties. ); likewise, it is possible that we share your data with our strategic partners, commercially called Innohub Group, which is composed of the following companies: Innohub, Lendinc, Avanttia, Elitechlab and Envioclick, all incorporated as a Sociedad Anónima Promotora de Inversión de Capital Variable (S.A.P.I de C.V.); with which Insaite shares your data, except those relating to your address, assets and economic situation, in order to offer you the services it provides. You may object to your data being shared with these companies, through the procedure described below to exercise your ARCO rights.
What is the nature of the third parties with whom the personal data will be shared?
Third parties other than those mentioned in the previous section, with whom the information is shared, will be only with those who by their nature are necessary to achieve the provision of the service that Insaite offers, such as:
Controlling companies, subsidiaries or affiliates under the common control of Insaite, as well as our parent company or any company of our corporate group that operates under the same processes and internal policies, namely Grupo Rubik formed by Clicknbox and Rubik, all incorporated as Sociedad Anónima Promotora de Inversión de Capital Variable (S.A.P.I de C.V.).
If requested, in terms of the applicable legislation.
Corporations or companies in charge of fraud investigations and collection of payments.
With companies that have been merged or spun-off by the company in question.
How does Insaite guarantee that third parties will protect personal data?
In the case of third parties that are authorities, they must be constrained in their actions to the legislation applicable to them. As far as private entities are concerned, Insaite has signed agreements and contracts with them, so that your personal data will be treated in the same terms as stated in this Privacy Notice.
Express consent to transfer information to third parties
By contracting Insaite’s services and accepting its terms and conditions, you are expressly agreeing that your personal data, except address, those referring to economic and patrimonial situation, will be shared with Rubik, Clicknbox, Innohub, Lendinc, Avanttia, Elitechlab and Envioclick, all constituted as a Sociedad Anónima Promotora de Inversión de Capital Variable (S.A.P.I de C.V.), only to receive offers of their services. You may object through the procedure established to exercise your ARCO rights.
Use of cookies, web beacons and similar technologies
Insaite uses remote or local mechanisms of electronic communication, optical or other technology that allow us to collect personal data related to your activity in the Electronic Media and Services. Therefore, when you access our website https://www.insaite.io/ and use the services we provide, cookies, web beacons and similar technologies will be used.
However, you have the option to block them.
To do this, you should know that a cookie is a piece of information that our web server can send to your computer when you visit our electronic media, whose purpose is to expedite the start of a new session; save the user’s configuration of the site and/or its applications; expedite the inter-action with the contents; improve the user experience of the site and/or its applications by storing your preferences in the access device, eliminating the need to repeatedly specify the same information and only show personalized content and advertising according to your preferences on your subsequent visits, as well as facilitating the Responsible for the analysis of such information with the aim of improving the performance of the site and/or its applications.
You can delete, block or receive a warning about cookies in the most common Internet browsers. If you want to do this, you should consult your browser instructions or help screen to learn more. However, cookies will allow you to take advantage of the most beneficial features that our Electronic Media offer you.
What about sensitive data?
We do not collect sensitive data, so there is no reason for you to provide such data.
How can you limit the use or disclosure of your personal data?
You can stop receiving e-mails, electronic newsletters, promotional information by telephone or mail, to do so you must follow the procedure indicated in this notice.
How do we protect your data?
At the moment of contracting a service through Electronic Means, you will be asked for, among others, bank data and the data previously indicated, for which you will be directed to a Web page that offers security and confidentiality of the data you provide, for this, they have a secure server under the SSL protocol (Secure Socket Layer) in such a way that the information you send is transmitted encrypted to ensure its protection.
To verify that you are in a protected environment, make sure that an “s” appears in the navigation bar “https”://.
Furthermore, Insaite assures you that we will use your email address with your consent only for the purposes mentioned in the Terms and Conditions. We do not rent or sell your e-mail address to third parties, and we will do our best to prevent your e-mail address from being recorded by web-crawlers or web spiders. If you believe that your e-mail address has been recorded in this way please e-mail us at insaite@insaite.io immediately.
In which cases will your consent not be necessary to process your personal data?
According to the cases provided for in the LFPDPPP, when:
(a) It is provided for in a LFPDPPP.
b) The Personal Data are contained in publicly available sources.
c) The Personal Data are subject to a prior Dissociation procedure,
d) It has the purpose of fulfilling obligations arising from a legal relationship between the owner and the controller.
e) There is an emergency situation that may potentially harm an individual’s person or property.
f) They are indispensable for medical care, prevention, diagnosis, provision of health care, medical treatment or management of health services, as long as the Data Subject is not in a position to grant consent, under the terms established by the General Health LFPDPPP and other applicable legal provisions and that such data processing is carried out by a person subject to professional secrecy or equivalent obligation, or
g) A resolution is issued by a competent authority.
How can you exercise your ARCO rights: access or rectify your personal data; or cancel or oppose its use?
You have the right to access your personal data in our possession and the details of their treatment, as well as to rectify them in case 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 and according to the conditions and terms of use, they are being used for non-consented purposes or the contractual or service relationship has ended, or to oppose the treatment of them for specific purposes. This derived from your ARCO rights.
The mechanisms implemented for you to exercise your ARCO rights will be through the respective request, following the procedures described below.
How can you revoke your consent to the processing of your data?
At any time, you may revoke the consent you have given us for the processing of your personal data for the different purposes that have been indicated throughout this notice, so that we stop using them in those terms. To do so, it is necessary that you submit your request through the procedure described above. In case of requesting the cancellation of your personal data for use in accordance with the Main Purposes, it would result in not being able to continue with the services you contracted with Insaite.
Modifications to the privacy notice
We reserve the right to make changes or updates to this privacy notice at any time, in order to comply with new legislation, internal policies or new requirements for the provision or offering of our services. These modifications will be available to the public through our website https://www.insaite.io/ [privacy notice section]; likewise, you will be notified via e-mail, so that you may consult the updates.
Likewise, the Data Subject is informed that he/she has the right to object to the processing of his/her Personal Data in case he/she does not agree with the modifications that this PRIVACY NOTICE may present, for such purpose, he/she shall follow the procedure to exercise his/her ARCO rights as indicated below.
To whom can you submit your complaints and claims for improper processing of your personal data?
If you believe that your right to protection of personal data has been injured by any conduct of our employees or our actions or responses, you presume that in the processing of your personal data there is any violation of the provisions of the LFPDPPP, let us know immediately through the mail insaite@insaite.io. Having done the above and considering that it was not properly addressed, you may go to the National Institute of Transparency, Access to Information and Protection of Personal Data, in order to exercise their rights through the means available on its website www.inai.org.mx
Procedure to exercise your ARCO rights
You are the owner of your personal data and it is our responsibility to give the treatment you want to them, as long as it does not affect the provision of the service you have agreed with Insaite. To do this, we offer you the following procedure to specify what treatment you want to be given to your personal data, also, this is the mechanism by which you can exercise your ARCO rights.
You must send a digitized signed letter (scanned) to the e-mail insaite@insaite.io, which must contain the following information:
Addressed as follows: “INSAITE, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE, through the Legal area, with address at Boulevard Manuel Ávila Camacho 156, piso 3, oficina 302, colonia Reforma Social, Código Postal 11650, alcaldía Miguel Hidalgo, Ciudad de México, México.
Full name. In case of being a legal entity or acting on behalf of an individual, you must attach the necessary documentation to prove your representation.
Contact information (email and telephone)
Indicate in a clear and precise manner the treatment you wish to give to your personal data, which could be access, rectification, cancellation or opposition in its treatment, as well as indicate which is the precise personal data to which the request refers to be applied.
The letter must contain your handwritten signature or scanned fingerprint, which must be attached to your email in .pdf or .jpg format.
Digitalized official identification or present it directly at the offices.
Indicate the means by which you wish your request to be attended.
You can also do it by mail, sending your letter in a sealed envelope. Addressed to the address located at Boulevard Manuel Ávila Camacho 156, 3rd floor, office 302, colonia Reforma Social, Zip Code 11650, alcaldía Miguel Hidalgo, Mexico City, Mexico. In case you wish to receive the response by the same means, you must cover the postal service expenses.
Once we receive your response, within three business days you will receive acknowledgment of receipt of your request, informing you that we will proceed to process it, or require further information if necessary to address the right you have exercised.
After fifteen (15) working days from the date you send your request, you will receive a response indicating whether your request was approved, and if so, the measures to be taken; in the event that the request has not been authorized, you will be informed of the reasons for this. It may extend this period up to 15 (fifteen) more working days, when the case warrants it, prior notification of such situation to the Data Subject.
The delivery of Personal Data will be free of charge upon proof of identity before the Controller. By exception, in those cases in which derived from the particular request of the Data Controller, justified shipping costs are generated to the Data Controller; and if applicable, reproduction costs or costs for the generation of copies or other formats that have as a reason to meet the request of the Data Controller, the Data Controller shall pay, in those cases in which it warrants it, such costs to the Data Controller, situation that will be informed to the Data Controller by the Data Controller prior to the delivery of the data.
How can you revoke your consent for the use of your personal data?
You may revoke the consent, if any, you have given us for the processing of your personal data described in this privacy notice. However, it is important to note that not in all cases we will be able to meet your request or terminate the use immediately, since it is possible that for some legal obligation we require to continue processing your personal data. For this purpose, we provide you with the following procedure:
You must send digitized signed writing (scanned) to the email insaite@insaite.io, which must contain the following information:
Addressed as follows: “INSAITE, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE, through the Legal Area with address at Boulevard Manuel Ávila Camacho 156, piso 3, oficina 302, colonia Reforma Social, Código Postal 11650, alcaldía Miguel Hidalgo, Ciudad de México, México.
Full name. In case of being a legal entity or acting on behalf of an individual, you must attach the necessary documentation to prove your representation.
Contact information (e-mail and telephone)
Clearly and precisely indicate the revocation of your consent, indicating the use of your data that you consented to and that you wish to revoke.
The letter must contain your handwritten signature or scanned fingerprint, which must be attached to your email in .pdf or .jpg format.
Digitalized official identification or present it directly at the offices.
Indicate the means by which you wish your request to be attended.
You can also do it by mail, sending your letter in a sealed envelope. Addressed as follows: “INSAITE, SOCIEDAD ANÓNIMA PROMOTORA DE INVERSIÓN DE CAPITAL VARIABLE, through the Legal Area, with address at Boulevard Manuel Ávila Camacho 156, piso 3, oficina 302, colonia Reforma Social, Código Postal 11650, alcaldía Miguel Hidalgo, Ciudad de México, México. In case you wish to receive the response by the same means, you must cover the postal service expenses.
Once we receive your response, within three business days you will receive acknowledgment of receipt of your request, informing you that we will proceed to process it, or require further information if necessary to address the right you have exercised.
After fifteen business days from the date you submit your request, you will receive a response indicating whether your request has been approved and, if so, the action to be taken; if the request has not been approved, you will be informed of the reasons why.
How can you limit the use or disclosure of your personal information?
In order for you to limit the use and disclosure of your personal information, we offer you the following means: Proceed to register in the Public Registry to Avoid Advertising, which is in charge of the Federal Consumer Protection Agency, so that your personal information will not be used to receive advertising or promotions of goods or services companies. For more information about this registry, you can consult the PROFECO’s website, or contact it directly. Likewise, in each email that is sent to you will appear the option to limit or exclude the use of information.
Acceptance and understanding of the notice
This notice is subject to the terms and conditions set forth on the Insaite website, which constitutes a legal agreement between you as the user and owner of your personal data with Insaite.
Date Updated
This notice was last updated on November 01, 2023.
