A. Identity and domicile of the data controller.
In accordance with the Federal Law on Protection of Personal Data Held by Private Parties (hereinafter referred to as LFPD) and in accordance with applicable provisions, Palace Elite Memberships, S.A. de C.V. (hereinafter and indistinctively referred to as “Palace Elite®” or as “Data Controller”) having corporate domicile for hearing and being served notices at Carretera Cancún Puerto Morelos Km 21, Manzana 01, Lote 1 – 11, Edificio A, Supermanzana 47, Municipio Benito Juárez, Cancún, Quintana Roo, C.P. 77506, expressly informs:

B. Personal data collected and subjected to processing.
In order to fulfill the purposes described in this Privacy Notice, we collected the following personal data: 1) Image, 2) Voice

C. Processing of sensitive personal data.
Palace Elite © does not collect any sensitive personal data for any of the purposes listed below.

D. Processing purposes.
1. Initial and necessary purposes: 1. Safety of affiliates and employees of Palace Elite ©. 2. Verification of agreements concluded between you and Palace Elite©. 3. Generation of electronic evidence. 2. Additional purposes: None.

E. Transfer of personal data.
Your personal information may be shared and processed by other parties than the Controller under the following conditions: 1. Government authority, organizations or entities; for the establishment, exercise or defense of a right in administrative or legal proceedings. Pursuant to article 37 of the LFPD your consent is not required to perform the sharing of information indicated above.

F. Exercise of ARCO rights.
Under all legal circumstances you may exercise your right to access, modify, cancel and oppose information (ARCO rights) using the legal processes we have set up. Your request shall comply with requirements set forth on the effective legislation, by means of a document addressed to our Chief Privacy Officer, whose domicile is Carretera Cancún Puerto Morelos Km 21, Manzana 01, Lote 1 – 11, Edificio A, Supermanzana 47, Municipio Benito Juárez, Cancún, Quintana Roo, C.P. 77506. Information requests should contain the following: I. Your name and address or other means of contacting you with a response. II. Valid identification documents or power of attorney, as the case may be. III. A clear and precise description of the personal information on which you wish to exercise your ARCO Rights; and IV. Any other element or document that could facilitate locating your personal information. Controller will answer you with a decision within twenty business days counted from the date on which your request is received. If the request is admissible it will be put into effect within fifteen business days following the date on which Controller advises you of a decision. In the event that the information you provide is incorrect or insufficient, or if you fail to send the necessary identity documents or power of attorney, Controller will ask that you correct such deficiencies within five business days after receiving your request, and you will have ten business days to comply counted from the day after you receive such notice. The process will be terminated if you do not answer within the required time. You can request personal information through authorized restricted access to the databanks (access) containing your personal information, or by any other legal method that guarantees and records the exercise of a requested right. Alternatively, the Data Subject may address his request through the address, fulfilling all the aforementioned requirements, establishing as Subject of the communication "ARCO Rights and/or Revocation of the consent”. The terms for the proceeding shall be the same as the ones mentioned in the foregoing paragraph. The use of the electronic means for the enforcement of the ARCO rights authorizes data subject to reply the relevant request through the same means, unless data subject himself expressly and clearly indicates otherwise.

G. Revoking consent.
You may revoke consent to have your personal information processed, non retroactively, in all cases in which said revocation does not make it impossible to fulfill any obligations arising from the legal relation in effect between you and Controller. The process for revoking consent will be the same as the one set in the immediately preceding section on how to exercise your ARCO rights.

H. Limitations on disclosure of your personal information.
You may limit the use or disclosure of your personal information by sending a written notice to our Personal Information Department. Identification requirements and the process for attending your request remain the same as those indicated in the section "Exercise of ARCO Rights" of this Privacy Notice. Controller has the means and procedures necessary to ensure that some of your information is listed in a personal information exclusion list and may do so when you expressly request such listing. Controller will then provide the petitioner with letter confirming their inclusion in the exclusion list.

I. Modifications or updates to this General Privacy Notice.
Controller may modify, update, expand or change the content and scope of this General Privacy Notice in any way and at any time at its complete discretion. In such cases, Palace Elite ® will publish any changes on its website in the “Privacy Notices” section.

Last Updated: April 15th, 2019