“REBRIUM”, S.A. DE C.V., better known as PUM!, with its address at Av. Lázaro Cárdenas, número 435, interior 410, Colonia Los Arcángeles, San Pedro Garza García, Nuevo León, México, C.P. 66266, and website https://pum.solutions/, is the Data Controller responsible for the use and protection of your personal data, and in this regard informs you of the following:
Every physical, electronic or other-format document generated by PUM! that is made available to any Data Subject for the purpose of collecting personal data must include the corresponding Privacy Notice prior to the processing of such data.
General Guidelines
Personal data must be collected for specific, explicit and legitimate purposes; accordingly, processing personal data in a manner contrary to the established purposes is strictly prohibited. Personal data means any information concerning an identified or identifiable natural person; and sensitive personal data means personal data that affects the most intimate sphere of the Data Subject, or whose improper use may give rise to discrimination or entail a serious risk to the Data Subject. In particular, data that may reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union membership, political opinions, or sexual preference is considered sensitive. References to personal data in this Policy also include sensitive personal data.
Personal data must be processed in a manner that ensures its appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical measures. Processing means the collection, use, disclosure or storage of personal data by any means. Use encompasses any act of accessing, handling, exploiting, transferring or disposing of personal data.
The personal data collected must be adequate, relevant and accurate. Where necessary, it must be kept up to date.
Personal data collected from Data Subjects shall be confidential, as established in the Information Classification Policy, such that any PUM! executives who may have access to it are required to handle it as this classification requires.
The personal data collected must be limited to the purposes for which it was obtained. Collecting unnecessary data must be avoided; that is, data must not be collected where there are insufficient business or legal reasons to collect it.
Once the purpose for which it was collected has been fulfilled, personal data must be suppressed, that is, eliminated, erased or destroyed.
The PUM! personal data protection officer will implement processes to ensure timely responses to internal inquiries regarding personal data.
The sale to third parties of personal data handled by PUM! is strictly prohibited.
Departments whose personnel have access to personal data handled by PUM! must ensure that such personnel receive adequate training on its protection and handling.
Any breach of this Policy shall be subject to the disciplinary measures set forth in the Employee Confidentiality Agreement.
Transfer of Personal Data
Any executive or department wishing to transfer personal data outside PUM! must seek guidance from the personal data protection officer, who will grant authorization once the requirements established in the Federal Law on the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, LFPDPPP) have been met. Where the data transfer is international, it must be verified whether there are additional laws or regulations that must be complied with.
For what purposes will we use your personal data?
We will use the personal data we collect from you for the following purposes, which are necessary for the service you request:
To confirm and verify your identity.
To provide the requested services of storage and subsequent personal management carried out by you.
In addition, we will use your personal information for the following secondary purposes, which are not necessary for the requested service but which allow and help us to provide you with better service:
Marketing or advertising; and
Commercial prospecting.
If you do not wish your personal data to be used for these secondary purposes, notify PUM! that you withhold your consent, stating the following:
“I do not consent to my personal data being used for the following purposes: (i) Marketing or advertising; and/or (ii) Commercial prospecting.”
Your refusal to allow the use of your personal data for these purposes may not be a reason for us to deny you the services and products you request or contract with us.
What personal data will we use for these purposes?
To carry out the purposes described in this privacy notice, we will use the following personal data:
Identification data;
Contact data;
Data relating to the products, services, goods and services you acquire yourself or through a third party;
Identification and contact data of the persons with whom the Data Subject shares the services and benefits of PUM!;
Name of the Data Subject and their employer;
Identification of the Data Subject;
Address of the Data Subject;
Information on the Data Subject’s vehicle(s).
How can you access, rectify or cancel your personal data, or object to its use?
You have the right to know what personal data we hold about you, what we use it for and the conditions of its use (Access). You also have the right to request the correction of your personal information if it is outdated, inaccurate or incomplete (Rectification); to have it deleted from our records or databases when you consider that it is not being used properly (Cancellation); and to object to the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights (Access, Rectification, Cancellation and Opposition).
To exercise any of your ARCO rights, you must submit the respective request through the following means:
By calling 8112443704 or sending an email to info@pum.solutions
For information on the procedure and requirements for exercising ARCO rights, we make the following means available to you:
By calling 8112443704 or sending an email to info@pum.solutions
The contact details of the person or personal data department in charge of processing ARCO rights requests are as follows:
Personal data department: Departamento ARCO PUM!;
Address: Av. Lázaro Cárdenas, número 435, interior 410, Colonia Los Arcángeles, San Pedro Garza García, Nuevo León, México, C.P. 66266;
Email: info@pum.solutions
d) Telephone number: 8112443704.
You may revoke your consent to the use of your personal data.
You may revoke any consent you have given us for the processing of your personal data. However, please bear in mind that we will not be able to fulfill your request or cease the use immediately in all cases, since we may need to continue processing your personal data due to a legal obligation. Likewise, you should consider that, for certain purposes, revoking your consent will mean that we can no longer provide you with the service that PUM! offers you, or the termination of your relationship with us.
To revoke your consent, you must submit your request through the following means:
By calling 8112443704 or sending an email to info@pum.solutions
Regarding the procedure and requirements for revoking your consent, we inform you of the following:
By what means may the Data Subject and, where applicable, their representative prove their identity, as well as the representative’s authority?
By calling 8112443704 or sending an email to info@pum.solutions
What information and/or documentation must the request contain?
Valid official identification.
Within how many days will we respond to your request?
5 days.
By what means will we communicate our response to your request?
By email.
How can you limit the use or disclosure of your personal information?
So that you may limit the use and disclosure of your personal information, we offer you the following means:
By calling 8112443704 or sending an email to info@pum.solutions.
How can you find out about changes to this privacy notice?
This privacy notice may be subject to modifications, changes or updates arising from new legal requirements; from our own needs in connection with the products or services we offer; from our privacy practices; from changes in our business model; or from other causes.
We undertake to keep you informed of any changes to this privacy notice through:
Publication on the website https://pum.solutions/
The procedure through which notifications of changes or updates to this privacy notice will be made is as follows:
The privacy notice will be kept up to date on the company’s website https://pum.solutions/
Cookies
Our platforms do not use cookies. Every user who accesses them must complete an authentication process.
Mobile Applications
The use of the mobile applications, which rely on the information captured and managed on our platforms, is governed by the same guidelines set out in this privacy notice.
Exceptions
Depending on the business needs of PUM!, local circumstances, laws and regulations, it may occasionally be necessary to make an exception to this policy or to any other PUM! policy. If an exception is required, PUM! management will determine an acceptable alternative approach.
PUM! undertakes not to transfer or disclose your personal information to third parties for purposes other than those mentioned in this privacy notice without your consent, except as provided in the LFPDPPP and its Regulations, and to carry out any such transfer under the terms set forth in those laws. If you do not express your objection to the transfer of your personal data, you will be deemed to have given your consent.
Data Management
PUM! stores and deletes personal and sensitive data in a manner that reasonably safeguards the confidentiality of the data, based on policies and procedures aligned with the ISO 27001 standard; protects the data through internal mechanisms against unauthorized use or disclosure; and properly secures or destroys the data.
Compliance
Any violation of this policy or of any other PUM! policy or procedure may result in disciplinary action, including termination of employment of its employees. PUM! reserves the right to notify the appropriate law enforcement authorities of any illegal activity and to cooperate in any investigation of such activity. PUM! does not consider conduct in violation of this policy to be within the scope of an employee’s or contractor’s work.
Any employee or contractor who is asked to carry out an activity that he or she believes violates this policy must submit a written or verbal complaint to their supervisor or to any other PUM! supervisor as soon as possible.
The disciplinary process should also be used as a deterrent to prevent employees and contractors from violating the organization’s security policies and procedures, as well as any other security breach.
If you have any concerns regarding the processing of personal data, you may contact the National Institute for Transparency, Access to Information and Personal Data Protection (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales, INAI) at www.inai.org.mx