Privacy Policy

Legal notice

Pursuant to the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties (the “LFPDPPP”), its regulations (the “Regulations”), and other applicable provisions, Grupo Patrimonial Progreso Firme SAPI de CV (hereinafter, the “Data Controller” or “FINSOF”, interchangeably), with its registered address for all applicable purposes related to this Privacy Notice and other associated matters at Avenida Circunvalación Jorge Álvarez del Castillo, Number 1471, Country Club neighborhood, Zip Code 44610, Guadalajara, Jalisco, informs you that during the processing of the personal data you provide, we will implement all necessary measures to comply with the principles of legality, quality, consent, information, purpose, loyalty, proportionality, and responsibility established by the LFPDPPP and its Regulations.

Definitions

Personal Data: Any information concerning an identified or identifiable natural person.
Applicable Law: Refers to the Federal Law on the Protection of Personal Data Held by Private Parties, its regulations, and any other legal provisions governing the collection, storage, and transmission of personal data.
Data Controller: For the purposes of this Privacy Notice, the entity responsible for the processing, use, and protection of your personal data is Grupo Patrimonial Progreso Firme SAPI de CV (FINSOF).
Platform: The set of information systems (applications, website, etc.) through which FINSOF provides its services.
Data Subject: The natural person to whom the personal data belongs (hereinafter “You”).

PERSONAL DATA COLLECTED AND SUBJECT TO PROCESSING

The personal data that you freely and voluntarily provide to FINSOF by any means made available to you, or obtained from publicly accessible sources or any other lawful means (hereinafter collectively “Personal Data”), taking into account your rights under the Law and the Regulations, may include:

Personal Data: Full name, address, phone numbers, photograph, Federal Taxpayer Registry (RFC), Voter ID (INE), Unique Population Registry Code (CURP), gender, nationality, place and date of birth, education level, email address, driver’s license number, academic and professional background, work experience, marital status, general information of family members (parents, siblings, spouses, children), data regarding current and past employment, third-party personal references, and other identification data, physical characteristics, biometric data (such as fingerprints, facial image), academic data, employment data, legal data, immigration data, and other similar data exclusively within this category.

The personal data of third parties that you provide to FINSOF for the fulfillment of the identified purposes or for secondary purposes (e.g., family members or beneficiaries) must be provided after you have informed them about the existence of the processing of their personal data and the contents of this Privacy Notice.

Financial and/or Asset Data: Bank accounts and/or transactions, asset relationships, gross and/or net income, bank account number(s), and CLABE number(s) for electronic transfers, and other similar data exclusively within this category.

Sensitive Data: For consultation and verification purposes, and to ensure that the personal data you voluntarily provide is correct and up to date, FINSOF may collect information from personal and employment references and from other sources such as phone or employment directories, job boards, publicly available databases, among others.

PURPOSES OF THE PROCESSING

The Personal Data processed in accordance with this Privacy Notice will be used solely to comply, first and foremost, with the purposes inherent to negotiating and, if applicable, formalizing the commercial relationship with you, as well as the planning and execution of business and commercial activities with third parties or designated processors who are provided this Privacy Notice for compliance purposes; and secondly, with purposes not necessarily related to any labor relationship we may hold with you. These purposes are divided as follows:

Primary or Necessary Purposes

Management, control, administration, and updating of information related to FINSOF’s clients and their legal representatives (in the case of legal entities), necessary to enter into and confirm operations, to contract services with FINSOF, and to ensure the safety and confidentiality of transactions.
Analysis of the personal, professional, and financial background of FINSOF’s clients in accordance with applicable legislation.
Management, control, and administration of communications between FINSOF and its clients.
Monitoring, control, and audit evaluations to ensure compliance with national and international legal obligations and treaties to which Mexico is a party.
Ensuring compliance with confidentiality, integrity, and transparency obligations, as well as legal provisions related to anti-money laundering and counter-terrorism financing, through the implementation of technical and administrative procedures.
Customer service and follow-up on complaints and/or requests through the communication channels established by FINSOF.
Statistical and historical record-keeping of clients and their legal representatives.

Secondary or Non-Essential Purposes

Sending communications about promotions, new products and/or services offered by FINSOF.
Sending commercial and marketing information (by electronic or physical means) about products and/or services offered or produced by third parties.
Promotion, distribution, marketing, and sales of products and/or services provided by FINSOF’s business partners.

If you do not agree with these secondary purposes, you will have a period of five (5) calendar days from the date this Privacy Notice is made available to you to notify us of your refusal by email to our Data Protection Office, whose contact details are provided below.

You retain your right to revoke consent or express opposition at any time, provided this is done prior to the use or sharing of your data.

TRANSFER OF PERSONAL DATA

Your personal data may be transferred within the national territory or abroad to the following categories of recipients for the purposes described below:

Public Entities: Federal, state, or municipal governments; commissions; institutes; and/or regulatory agencies for compliance with reporting, transparency, and anti-money laundering obligations; as well as for compliance with judicial or administrative requirements issued by competent authorities.
Foreign Authorities or Organizations: To comply with requirements or requests enforceable in Mexican territory or pursuant to international treaties to which Mexico is a party.
Financial Entities: For compliance with legal, transparency, and anti-money laundering obligations.
Third Parties (Business Partners): Exclusively for the provision of products and/or services additional to your contract.

REVOCATION OF CONSENT

You may revoke your consent for the processing of your personal data at any time by sending an email to our Data Protection Office, clearly stating the specific data, purpose, and activity you do not authorize, as long as such data is still in our databases or under our reasonable control.

The procedure for revoking consent will be the same as that established for exercising ARCO rights (Access, Rectification, Cancellation, and Opposition).

LIMITATIONS ON THE USE AND DISCLOSURE OF PERSONAL DATA

You may limit the use or disclosure of your personal data by submitting a request to our Data Protection Office. The identity verification requirements and the procedure to handle your request will be the same as those set forth for exercising your ARCO rights.

MODIFICATIONS OR UPDATES TO THIS PRIVACY NOTICE

FINSOF may modify, update, extend, or otherwise change the content and scope of this Privacy Notice at any time and at its full discretion.

For your protection and information, we strongly recommend that you regularly review the content of this Privacy Notice or contact us at contacto@finsof.mx with any questions or requests.

This Privacy Notice complies with the requirements established by the Federal Law on the Protection of Personal Data Held by Private Parties, its Regulations, the Privacy Notice Guidelines, and other applicable legal provisions.

Date of last update: April 25, 2025

Consent Statements

I hereby express my consent for the processing of the Personal Data provided to FINSOF to fulfill the Primary or Necessary Purposes set forth in this Privacy Notice. I acknowledge that I have no objection to the transfer of my Personal Data to the third parties listed herein.

I hereby give my consent for the Personal Data provided to FINSOF to be used for the Secondary or Non-Essential Purposes outlined in this Privacy Notice. I acknowledge that I have no objection to the transfer of my Personal Data to the third parties listed herein.

I give my consent for the Personal Data provided to FINSOF to be used to contact me personally, by phone or email, for commercial prospecting purposes exclusively by FINSOF and/or its parent companies, affiliates, and/or subsidiaries. I acknowledge that I have no objection to the transfer of my Personal Data to the third parties listed herein.

I acknowledge that I have read and understood the scope and meaning of this Privacy Notice and hereby give my consent, as well as to the mechanisms provided by the Data Protection Law, its Regulations, the Guidelines, and this Notice for the exercise of my rights of access, rectification, cancellation, and opposition, and to limit the use, transfer, and disclosure of my Personal Data by FINSOF