In compliance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties, JLC Industries SA de CV, a commercial entity incorporated under Mexican law, with its tax domicile in Av. San Lorenzo Tezonco No. 201, Col. San Nicolás Tolentino, Iztapalapa Borough, CP 09850, Mexico City, hereinafter “JLC”, hereby informs you of this Privacy Notice.

This Privacy Notice describes the types of personal data that JLC may collect, the means by which it may obtain them, the purposes for which they will be used, the measures implemented to protect them, and the mechanisms available for data subjects to exercise their rights in accordance with applicable law.

This Notice applies to personal data obtained through the JLC website or portal, contact methods, business relationships and, where applicable, through video surveillance systems installed at JLC facilities.

1. COLLECTION AND USE OF PERSONAL DATA

1.1 Personal data provided directly

You can choose whether or not to provide us with your personal data, including, but not limited to:

• Name.
• Home.
• Phone number.
• Email address.
• Information related to the business relationship.
• Information provided voluntarily through forms, contact methods, applications or communications.

If you choose not to provide certain personal data, it may not be possible to process some requests, provide certain services, or establish the corresponding relationship.

Contact

If you contact us through our website or portal, we may request personal information such as your name, email address, and phone number in order to address and follow up on your questions, requests, and comments.

Social networks and other communications

Our website or web portal may contain tools or links related to social networks and other media.

When you voluntarily provide your personal data through these means, such data may be used to respond to communications or requests you have made.

Register of commercial activities

Where appropriate, we may collect information related to business activities, product purchasing preferences, and other data necessary to provide our services and improve the quality of our products.

Contests, raffles and promotions

In the event of holding contests, raffles or other promotions, we may request personal data such as name, email address, home address and telephone number, exclusively for purposes related to said activities.

2. AUTOMATIC COLLECTION OF PERSONAL DATA

When you visit this website or portal, we may automatically collect certain technical information related to navigation.

This information may include:

• IP address.
• Domain name.
• URL.
• HTTP response code.
• Website or portal from which the visit was made.
• Date and duration of the visit.
• Browser type.
• Information related to cookies and similar technologies.

This information may be used to generate general statistics on site usage, improve site performance, detect disruptions, identify potential misuse, and maintain site security.

cookies

Like many companies, we use cookies or similar technologies on our website or web portal.

Cookies are files that can be stored on the user's device when they visit certain pages.

These technologies can be used for:

• Identify if the user has previously visited the site.
• Remembering certain preferences.
• Improve the browsing experience.
• Obtain statistical information about site usage.
• Improve the functionality of the applications available on the site.

The user can configure their browser to reject new cookies, receive notifications when they are used, or disable certain existing cookies.

web beacons

Some pages of the website or web portal may contain web beacons, also known as internet tags, pixel tags, or similar technologies.

These technologies may allow the collection of technical information related to visits to certain pages, such as IP address, URL, time of visit, browser type, and certain information related to cookies.

3. VIDEO SURVEILLANCE

3.1 Video surveillance systems

JLC Industries SA de CV It reports that it has video surveillance systems using closed-circuit television (CCTV) cameras installed in certain areas of its facilities.

Video surveillance systems can capture images of employees, visitors, customers, suppliers, contractors, carriers, and any other person who enters, remains, or passes through areas subject to video surveillance.

The presence of cameras will be indicated by visible signage placed at the entrances and corresponding areas.

3.2 Personal data processed through video surveillance

The following data may be processed primarily through video surveillance systems:

• Image of people.
• Visible physical characteristics.
• Date and time of capture.
• Location or area where the capture took place.
• Information related to the events recorded by the cameras.

The images will be processed exclusively for the purposes established in this Privacy Notice and will be subject to the corresponding administrative, technical and physical security measures.

3.3 Purposes of video surveillance

Images obtained through video surveillance systems may be used for the following purposes:

Main purposes

• Protection of people within the facilities.
• Protection of the facilities.
• Protection of JLC's assets, property and resources.
• Incident prevention.
• Accident prevention.
• Detection of situations that may pose a risk to people or facilities.
• Accident and incident investigation.
• Investigation of theft, damage, unauthorized access or other security-related events.
• Handling internal investigations when appropriate.
• Documentation of facts related to the safety of people, facilities and property.

When legally appropriate, the images may be used to assist in investigations or proceedings related to possible illegal acts.

3.4 Handling requests from authorities

When there is a legal requirement or it is appropriate under applicable law, JLC may provide images or recordings to the competent authorities.

The delivery of recordings must be carried out using established internal procedures and, where appropriate, information related to the delivery and the recipient must be recorded.

3.5 Areas subject to video surveillance

The cameras can be found, among other places, in:

• Entrances and exits.
• Pedestrian entrances.
• Vehicle access.
• Receptions.
• Perimeters.
• Courtyards.
• Warehouses.
• Production areas.
• Loading and unloading areas.
• Parking.
• Hallways.
• Circulation areas.
• Other areas that require surveillance for security and protection reasons.

JLC will ensure that video surveillance systems are not installed in bathrooms, changing rooms, showers, or other areas where there is a reasonable expectation of privacy.

3.6 Audio Recording

Audio recording functions, when available on certain equipment, will be subject to review and authorization in accordance with applicable legal provisions and internal policies.

JLC will endeavor to keep audio recording functions disabled when there is no legitimate purpose, justification, and authorization for their use.

3.7 Access to recordings

Access to images and recordings will be restricted to authorized personnel in accordance with their roles and responsibilities.

The recordings must not be used for personal purposes, reproduced, downloaded, copied, disclosed, or shared outside of procedures authorized by JLC.

It is prohibited to use the recordings for personal purposes, publish images on social networks, share them through messaging applications, store them on personal devices or use them for any purpose other than those established in this Notice.

3.8 Preservation of recordings

The recordings will be kept for the period necessary to fulfill the purposes of the processing and in accordance with JLC's internal policies for the retention and disposal of information.

When a recording is related to an accident, incident, theft, damage, internal investigation, procedure or authority request, it may be kept for the time necessary to address the situation, in accordance with applicable legal provisions.

Once the corresponding purpose has been fulfilled and when there is no legal obligation or cause that justifies their preservation, the recordings will be deleted or subject to the corresponding disposal mechanism.

3.9 Evidence

When a recording is needed to document an accident, incident, theft, damage, investigation or possible illegal act, JLC may extract and safeguard it in accordance with established internal procedures.

In these cases, efforts will be made to maintain control over:

• Recording identification.
• Date and time.
• Reason for extraction.
• Person who performed the extraction.
• Location of the original file.
• Copies generated.
• Persons authorized to access the evidence.
• Deliveries made to third parties or authorities.

4. GENERAL PURPOSES OF THE PROCESSING OF PERSONAL DATA

The personal data obtained by JLC may be processed for the following purposes:

• Provide the required products and services.
• Attend to requests and inquiries.
• Follow up on communications.
• Inform about changes or new products or services related to those contracted or acquired.
• To fulfill obligations contracted with clients and suppliers.
• Evaluate the quality of services.
• Conduct internal studies on consumption habits.
• Maintain and improve the operation of the website.
• Protect people.
• Protect facilities, property and assets.
• Prevent and investigate incidents.
• Attend to internal investigations.
• Fulfill legal obligations.
• Respond to requests from competent authorities when appropriate.

JLC will process personal data only for the purposes that are applicable according to the relationship it maintains with each data subject.

5. HOW WE SHARE PERSONAL DATA

JLC does not sell personal data.

We may share personal data with affiliated companies, service providers and third parties when necessary to provide the corresponding services or comply with legal obligations.

Suppliers who have access to personal data must only receive the information necessary to perform the contracted activities and will be subject to the corresponding confidentiality and data protection obligations.

In matters of video surveillance, certain providers responsible for the operation, maintenance, support or administration of CCTV systems may have access to the images when necessary to provide the contracted services.

We may also disclose personal data:

1. When a legal provision so establishes.
2. When there is a requirement from a competent authority.

III. When it is necessary to attend to a procedure or investigation in accordance with applicable legislation.

1. When necessary to protect the rights, property or safety of JLC, its employees, customers, suppliers or third parties.
2. In all other cases permitted by applicable law.

In the event of a sale, merger, acquisition, reorganization or transfer of assets, personal data may be transferred when legally appropriate and when appropriate measures are taken to protect it.

6. LINKS TO OTHER SITES

For your convenience and information, our website or portal may offer links to other sites, applications, or social networks.

These sites operate independently and may have their own privacy notices.

JLC will not be responsible for the content, maintenance, availability, or privacy practices of sites that are not directly managed by JLC.

7. HOW WE PROTECT PERSONAL DATA

JLC implements reasonable administrative, technical, and physical measures to protect personal data against damage, loss, alteration, destruction, unauthorized access, processing, or disclosure.

These measures may include:

• Access controls.
• Users and permissions.
• Information systems protection.
• Controls over storage.
• Restrictions on access to information.
• Physical security measures.
• Technological security measures.
• Confidentiality obligations.

Video surveillance systems will implement controls to limit access to recordings exclusively to authorized personnel.

8. ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION

The owner of the personal data may exercise their rights BOW:

1. Access

To know what personal data is processed by JLC, as well as the conditions and purposes of its processing.

1. Rectification

Request the correction of personal data when it is inaccurate or incomplete.

1. Cancellation

Request the deletion of your personal data when appropriate under applicable law.

1. Opposition

To object to the processing of your personal data when there is a legitimate reason to do so.

To exercise ARCO rights, the holder must submit the corresponding request through the contact means indicated in the section “JLC Contact” of this Notice.

Applications will be processed in accordance with the requirements, procedures and deadlines established by applicable legislation.

9. LIMITATION ON THE USE OR DISCLOSURE OF PERSONAL DATA

The data subject may request mechanisms to limit the use or disclosure of their personal data.

To do so, you can contact JLC through the contact methods indicated in this Notice.

JLC will analyze and address requests in accordance with applicable law.

10. SENSITIVE PERSONAL DATA

JLC will avoid requesting and processing sensitive personal data unless there is a legitimate purpose and the requirements established by applicable legislation are met.

Sensitive personal data are those that affect the most intimate sphere of their owner or whose misuse may generate discrimination or represent a serious risk for them.

Among others, data that reveals racial or ethnic origin, health status, genetic information, religious, philosophical or moral beliefs, trade union membership, political opinions or sexual preferences may be considered sensitive.

11. PERSONAL DATA COLLECTED THROUGH THE WEBSITE

Personal data voluntarily provided through the website may be used for:

• Handle requests.
• Answer questions and comments.
• Follow up on communications.
• To provide products and services.
• Fulfill commercial obligations.
• Improve the quality of services.
• Carry out promotional activities when appropriate.

If the user chooses not to provide certain personal data, they may not be able to access certain services or functionalities of the site.

12. UPDATES TO OUR PRIVACY NOTICE

JLC may periodically update this Privacy Notice to reflect changes in:

• Applicable legislation.
• Internal processes.
• Services.
• Information systems.
• Safety practices.
• Video surveillance systems.
• Purposes of the treatment.

The modifications will be published on our website, in the section corresponding to the Privacy Notice:

https://clarasol.mx/aviso-de-privacidad/

13. ADS, CHAT ROOMS, BLOGS AND OTHER FORUMS

Personal data that users voluntarily publish in public areas of the site, such as advertisements, chat rooms, blogs, or other forums, may be visible to third parties.

Users should exercise caution when providing personal information in such spaces.

14. JLC CONTACT

If you have any questions related to this Privacy Notice, the processing of your personal data, video surveillance systems, or the exercise of your ARCO rights, you can contact us through:

JLC Industries SA de CV

Email:
contacto@clarasol.com

Phone:
55-5612-1225

Business hours:
8:00 a.m. to 6:30 p.m. on working days.

Home:

Av. San Lorenzo Tezonco No. 201
Col. San Nicolás Tolentino
Iztapalapa Mayor's Office
CP 09850
Mexico City.