Comprehensive Privacy Notice

Akampa Comprehensive Privacy Notice

Last updated: May 30, 2021.

In accordance with the provisions set forth in the Federal Law on the Protection of Personal Data Held by Private Parties (hereinafter, the “Law”), its Regulations (the “Regulations”) and the Privacy Notice Guidelines (“Privacy Notice Guidelines”) (the “Guidelines”), this Privacy Notice for the AKAMPA platform (the “Privacy Notice”) is issued under the following terms:

I.— DATA CONTROLLER

AKAMPA, a company in the process of incorporation, with registered address at Desierto de los Leones 1414 #35, Col. Tetelpan, Del. Álvaro Obregón, ZIP Code 01700, is the entity responsible for the collection, disclosure, storage, use, handling, transfer, and/or disposal of personal data (the “Processing”) in accordance with the Law and its Regulations.

II.— PERSONAL DATA TO BE COLLECTED

AKAMPA may collect various types of personal data from members who are granted access to the AKAMPA platform (any of whom is a “Data Subject”), as necessary for Processing, either personally and/or directly from the Data Subject, or even indirectly.

AKAMPA hereby informs you that the categories of personal data it may collect are as follows:

a) General identification data: Name, current address (including legal relationship to said address), date and country of birth, tax identification number or similar, applicable tax regime, sex or gender with which the data subject identifies, nationality, marital status, and languages spoken.

b) Contact information: Phone number provided and email address.

c) Professional or business information: Occupation, place of work, and information about the Data Subject already known to the Company or provided by the Data Subject to the Company in the course of their employment relationship with the Company.

d) Financial and asset information: Credit or debit cards, bank identification number (CLABE) or equivalent for making payments via digital platforms.

e) Legal information: Personal data that the Company may be required to collect in accordance with applicable law.

f) Other information: categories of products or locations visited by the data subject, products, IP address, date, time, and location when accessing the platform, as well as information provided by the Data Subject during the course of their use of the AKAMPA platform.

In cases where the Data Subject discloses personal data of third parties to the Company, the Data Subject represents and warrants that they are duly authorized by the relevant third party to disclose such personal data and/or that, by disclosing such personal data to the Company, they are not in breach of any legal and/or contractual provision.

AKAMPA may collect any other personal data of any nature that: (i) the Data Subject voluntarily provides to AKAMPA by any means, including electronic or other means; and/or (ii) is contained in supporting documentation provided via printed, electronic, or optical media or through any other technology of any kind.

Personal data may be collected:

I. In person: When the Data Subject provides personal data to become a member of the platform.

II. Directly: When the Data Subject provides their personal data through the platform or by phone, email, or any other printed, electronic, or optical medium, or through any other technology of any kind, to carry out specific transactions.

III. Indirectly: From any other source of information regarding the Data Subject, provided that such information is voluntarily provided.

III. PURPOSES OF PERSONAL DATA PROCESSING

A) Primary or Necessary Purposes:

The processing of the data subject’s personal data—whether collected by the Company or otherwise provided to it—serves the following primary or necessary purposes:

I. To create and update the data subject’s user profile and account for use of the AKAMPA platform.

II. To authenticate the data subject when logging into the AKAMPA platform.

III. To record usage preferences and registration information.

IV. To measure the data subject’s learning effectiveness and training progress.

V. To compile and publish rankings on the AKAMPA platform.

VI. To draw inferences about the data subject’s skills, interests, and preferences in order to personalize their use and experience based on their particular situation for partner providers and consumers from the general public.

VII. To enforce and monitor compliance with the platform’s terms of use, as well as to ensure its proper use.

VIII. To protect the rights, property, and security of AKAMPA and any other affiliated company, as well as the property rights or security of the Data Subject or others.

IX. To distribute information and training content on all aspects of the reservations and sales team’s preparation, providing an innovative and engaging training solution.

X. To enable interaction at the end of each training session through quizzes and learning assessments, and to earn badges upon successfully completing certain training modules.

XI. To provide updates and news regarding AKAMPA.

XII. To allow users to explore various topics related to ecotourism or any other type of outdoor activity.

XIII. To allow users to post comments, interact with colleagues, and share content related to AKAMPA and the services provided on the platform.

XIV. To direct communications to specific users of the AKAMPA platform.

B) Secondary or Non-Essential Purposes:

The processing of the Data Subject’s personal data—whether collected by the Company or otherwise provided to it—serves the following secondary or non-essential purposes:

I. Statistical purposes:

In compliance with the Federal Law on the Protection of Personal Data Held by Private Parties, if the Data Subject does not wish to have their personal data processed for any or all of the secondary or non-necessary purposes described above, they have the option to exercise their ARCO rights; The Data Subject may express such refusal at any time by sending an email to the following address: akampamx@gmail.com, along with a copy of their identification, in accordance with Chapter V of this Notice.

In the event that the Data Subject does not express such refusal, the Data Subject may, at any time, exercise their right to revoke consent and/or their right to object in accordance with this Privacy Notice, the Law, and its Regulations.

The right to revoke consent is strictly personal; therefore, it may only be exercised by the Data Subject with a copy of their identification attached; otherwise, such a request will not be considered valid.

As an alternative to limiting the use and disclosure of the Data Subject’s personal data—other than through the exercise of the right of access, rectification, cancellation, and objection to the processing of personal data, or the right to revoke consent— AKAMPA informs the Data Subject that they may also opt out of secondary or non-essential purposes mentioned above by sending an email to the following email address: akampamx@gmail.com or by written notice delivered to the Company at the address listed in this Privacy Notice.

The processing of personal data may also involve purposes that are compatible, analogous, or similar to those mentioned above, without the need to obtain the Data Subject’s consent again and subject to the provisions of applicable laws. In any case, the processing of personal data will be limited to what is necessary, appropriate, and relevant for the purposes set forth in this Privacy Notice, as well as any other compatible or similar purpose.

IV.— TRANSFERS OF PERSONAL DATA

A) Primary and Necessary Transfers:

AKAMPA may carry out the following domestic and/or international transfers of the Data Subject’s personal data as necessary for its processing and, where applicable, to conduct AKAMPA’s day-to-day business, maintain relationships with data subjects, and acquire future customers.

1. To each and every person, worker, employee, collaborator, employer, official, individual, entity, and/or company that is part of AKAMPA or is currently in a professional relationship with AKAMPA.

2. To the Company’s service providers to fulfill the Company’s obligations to the Data Subject.

3. To other third parties for the purpose of enforcing or monitoring compliance with AKAMPA’s terms of use, as well as protecting your property rights or safety or those of others.

4. To the competent authorities that need to be informed of the activities between the Data Subject and the Company, in order to comply with applicable legal provisions and requirements.

All recipients of personal data shall assume the same obligations and responsibilities as AKAMPA, to the extent possible and in accordance with Article 37 of the Law.

B) Secondary or Non-Essential Transfers:

As secondary or non-essential transfers, AKAMPA may transfer the Data Subject’s personal data to its commercial and business partners for marketing, advertising, offers, and promotions related to AKAMPA’s services or products.

If the Data Subject does not wish to have their personal data processed for any or all of the secondary or non-necessary purposes indicated above, the Data Subject may express such objection at any time by sending an email to the following email address: akampamx@gmail.com

If the Data Subject does not express such objection, the Data Subject may, at any time, exercise their right to revoke consent and/or their right to object in accordance with this Privacy Notice, the Law, and its Regulations.

The right to revoke consent is strictly personal; therefore, it may only be exercised by the Data Subject, who must attach a copy of their identification; otherwise, the request will not be considered valid.

V. MEANS AND PROCEDURES FOR EXERCISING THE RIGHTS OF ACCESS, CORRECTION, DELETION, AND OBJECTION REGARDING THE DATA SUBJECT’S PERSONAL DATA

In accordance with the Law and subject to any other applicable legislation, the Data Subject may exercise any of their rights of access, rectification, erasure, and objection to the processing of personal data, for which they must follow the procedure below:

2. Once AKAMPA receives the corresponding request, an acknowledgment of receipt indicating the date of receipt will be sent to the Data Subject. If the request does not fully comply with all applicable legal requirements and any of the requirements mentioned above, AKAMPA may ask the Data Subject to complete the missing requirements within five (5) business days from the date of receipt of the corresponding request, and the Data Subject will have ten (10) business days from the date the Company requests that they complete and correct the relevant requirements; provided that, if not corrected within the aforementioned period, the request will be considered not filed with the Company for all legal purposes.

3. If the request is received by AKAMPA on a non-business day, the request shall be deemed received by AKAMPA on the immediately following business day.

4. The Data Subject’s request will be addressed via email within twenty (20) business days from the date the request was duly and correctly submitted to AKAMPA in accordance with the preceding paragraphs. The request may also be addressed through any other public or private means provided for in the documents governing the relationship between AKAMPA and the Data Subject or as is customary between them. This period may be extended for an additional twenty (20) days when justified and the Data Subject is notified in accordance with the provisions of Article 97 of the Regulations.

5. If the Data Subject’s request is admissible under the Law and any other applicable legislation, the Company shall take the necessary actions regarding such request within fifteen (15) business days from the date the Company responds to the request. This period may be extended for an additional fifteen (15) days when justified and the Data Subject is notified in accordance with the provisions of Article 97 of the Regulation, on the understanding that the Company may refuse to take any action related to the relevant request only to the extent permitted by the Law and the Regulations and shall then notify the Data Subject through the aforementioned means. If the request is admissible, as provided in Articles 32, 33, 34, and 35 of the Law, the personal data will be provided free of charge via the email address provided by the Data Subject to the Company, to the extent technically feasible to comply with the request. If the Data Subject so requests or, depending on the circumstances of the case, it is deemed necessary to provide the information by a means other than email, the Data Subject shall pay the applicable and justified shipping costs, as well as any other expenses arising from the copies or other formats generated.

6. To exercise the right to revoke consent for the processing of the Data Subject’s personal data, the Data Subject must follow the same procedures and use the same methods established in this Privacy Notice for exercising the rights of access, rectification, erasure, and objection to the processing of personal data, subject to the provisions of applicable law; provided that it is important for the Data Subject to note that the Company may not be able to respond to their request or cease using their personal data immediately, given that, due to a legal or contractual obligation to the Data Subject, the Company may be required to continue processing their personal data; Furthermore, the Data Subject should be aware that, for certain purposes, the revocation of their consent may mean that the Company can no longer provide the requested service and that, in any case, the admissibility of the Data Subject’s request will be subject to applicable legal provisions.

7. If the Data Subject does not object to the purposes of processing and/or transfers of personal data set forth in this Privacy Notice, in accordance with the procedure set forth in this Privacy Notice, when such consent is required under the Law, its Regulations, and/or the Guidelines, it shall be understood for all legal purposes that the Data Subject has granted consent to such Processing.

Continued use of the AKAMPA platform constitutes acceptance of any amendments to this Privacy Notice, unless applicable laws require otherwise. The Data Subject’s refusal to consent to the processing of personal data for the additional or unnecessary purposes and transfers set forth above shall not be grounds for AKAMPA to deny access to and/or use of the platform.

The right to revoke consent is strictly personal and may therefore only be exercised by the data subject; otherwise, such a request will not be considered valid.

VI.—AMENDMENTS TO THE PRIVACY NOTICE.

This Privacy Notice may be modified or updated as a result of new legal requirements, AKAMPA’s own needs and/or privacy practices, changes to its business model, or any other applicable cause under the relevant applicable legal provisions. Any changes to this Privacy Notice will be published on the following website: akampa.mx, or will be notified via email or to the address provided by the data subject. Continued use of the AKAMPA platform constitutes acceptance of any amendments to this Privacy Notice unless otherwise required by applicable legal provisions.

VII.— CONSENT OF DATA SUBJECTS

By using and/or creating an account on the AKAMPA platform, the Data Subject declares that they have read and understood this entire Privacy Notice and, therefore, grants their express consent to the processing of their personal data for the purposes, including relevant transfers, set forth in this Privacy Notice. If the Data Subject does not object to the processing of personal data for the secondary or non-necessary purposes and/or transfers set forth in this Privacy Notice, it will be understood that the Data Subject has granted their consent in this regard.

The Data Subject’s refusal to allow the processing of personal data for the additional or non-necessary purposes and transfers set forth above shall not constitute grounds for AKAMPA to deny access to the AKAMPA platform. In the event that the Data Subject wishes to exercise any of their rights of access, rectification, erasure, and/or objection to the processing of personal data, to limit the use or disclosure thereof, or to revoke their consent thereto, the Data Subject must refer to Section “V. Means and Procedures for Exercising the Rights of Access, Rectification, Deletion, and Objection to the Data Subject’s Personal Data.”

The Data Subject’s continued use of the AKAMPA platform constitutes acceptance of and consent to any amendments to this Privacy Notice, unless otherwise required by applicable legal provisions.

At Akampa.mx, we use “cookies.” Cookies are small data files stored on the hard drive of your computer or the electronic communication device you use when browsing our Website. These data files enable the exchange of status information between our Website and the browser you use. “Status information” may include session identifiers, authentication credentials, or your user preferences, as well as any other data stored by the browser regarding the website.

Cookies allow us to track a user’s online behavior. We use the information obtained through cookies to help us optimize your shopping experience. Through the use of cookies, we can, for example, customize our homepage for you so that our pages display more effectively based on your browser type. Cookies also allow us to offer you personalized recommendations regarding products or services, as well as emails.

Cookies are not spyware, and Akampa.mx does not collect data from multiple sites or share with third parties the information we obtain through cookies.

Like most websites, our servers log your IP address, the URL from which you accessed our website, your browser type, and the date and time of your purchases and other activities. We use this information for system administration, troubleshooting technical issues, fraud investigation, and to communicate with you.

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If at any time you decide to withdraw your consent to the use of cookies, this means that no new cookies will be added. However, you will need to delete the existing cookies from your browser. To do so, consult the help section or the official website of your browser.