2. Definitions 1. General
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PRIVACY NOTICE regarding personal information collected by ETON, S.C. and SERVICIOS ETON, S.A. DE C.V. (hereinafter collectively known as “ETON SCHOOL”). 1. General 1.1. ETON SCHOOL is a company committed to respecting individuals’ rights regarding personal information, as stipulated in article 16, Paragraph II, of the Political Constitution of the Mexican United States, as well as in the provisions of the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions (Ley Federal de Protección de Datos Personales en Posesión de los Particulares), the corresponding regulations, and other applicable law. Therefore, such entity makes this Privacy Notice available so that the individual whose information is guarded (THE RIGHT HOLDER) will be able to exercise his right to informational self-determination. 1.2. The ETON SCHOOL Privacy Notice is available to the RIGHT HOLDERS in the Human Capital Department within the institution’s facilities, which are located on Av. Santa Lucía No. 220, colonia Prados de la Montaña, alcaldía Cuajimalpa de Morelos, CP 05619, Mexico City, Mexico. It can also be found on the following websites: www.eton.edu.mx, in the “Becoming Part of Eton” section, and https://eo.eton.edu.mx/staff/. According to article 9 of the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions, ETON SCHOOL gets express, written, and signed consent from the RIGHT HOLDER using the form at the foot of this document before handling any personal information, including sensitive personal information. This way, the RIGHT HOLDER declares that he or she understands and accepts this Notice’s terms and conditions, and grants express, written, and signed consent for the handling of his or her personal information. 1.3. If THE RIGHT HOLDER does not accept the terms and conditions of this Privacy Notice in full, he or she shall refrain from sharing any information with ETON SCHOOL through any means. The parties hereby declare that, as there is no dolus, mala fides, or anything else that could affect or void the validity of this document, they are both bound by the following: 2. Definitions 2.1. Personal information. Any information related to an individual that is, or can be, identified. 2.2. Sensitive personal information. Personal information that may affect the private life of the RIGHT HOLDER or that could cause discrimination or lead to risk for said RIGHT HOLDER in case of misuse. Sensitive personal information, in general, is considered that which could disclose aspects such as ethnic or racial origin, current or future state of health, genetic information, religious, philosophical, and moral beliefs, union affiliation, political opinions, and sexual orientation. 2.3. RIGHT HOLDER. The individual (RIGHT HOLDER) identified by the personal information. 2.4. Handler. An individual or private entity (ETON SCHOOL) that has the right to decide how to manage the personal information. 2.5. Individual in charge. An individual or private entity that, individually or with others, manages personal information on behalf of the handler. 2.6. Management. Collection, use (including access, handling, usage, transfer, and disposition of personal information), disclosure, or storage of personal information by any means. 2.6.1. Transfer. Any information communicated to an individual other than the handler or individual in charge of the management. 2.6.2. Relay. The communication of personal information between the handler and the individual in charge, in Mexico or abroad. 2.7. Third party. A national or foreign individual or entity other than the handler or individual in charge of the information. 2.8. ARCO rights. The right to Access, Rectify, Cancel, and Oppose. 2.9. Tacit consent. It will be assumed that the RIGHT HOLDER has agreed to the management of his or her information when said individual does not express his or her opposition at the time of receiving the Privacy Notice. 2.10. Primary purposes. The main purposes for which the personal information is requested, which create the relationship between ETON SCHOOL and the RIGHT HOLDER. 2.11. Secondary purposes. The purposes that are not essential for the relationship between ETON SCHOOL and the RIGHT HOLDER, but that contribute to the corporate purposes of ETON SCHOOL. 3. Identity and Domicile of the Individual in Charge of Managing Personal Information 3.1. The entities in charge of managing the RIGHT HOLDERS’ personal information are ETON, S.C. and SERVICIOS ETON, S.A. DE C.V. (hereinafter collectively known as, “ETON SCHOOL”), who will respect the provisions of this Privacy Notice (hereinafter the “Notice” or the “Privacy Notice,” interchangeably), which is made available according to the provisions of the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions (hereinafter the “Act” or “FAPPIGIPI,” interchangeably), and applied to the personal information of individuals such as employees and prospective employees. ETON SCHOOL manages this information due to the working relationship that is established with said RIGHT HOLDERS in order to impart the educational services the institution provides in all grades and levels, including Early Childhood, Elementary, Middle School and High School, as well as the consultancy services in commercial and educational areas provided by ETON SCHOOL to Mexican customers. 3.2. For effects of this Notice, the domicile of ETON SCHOOL is Av. Santa Lucía No. 220, colonia Prados de la Montaña, alcaldía Cuajimalpa de Morelos, CP 05619, Mexico City, Mexico. 4. Personal Information Subject to Management 4.1. THE RIGHT HOLDER acknowledges and agrees that ETON SCHOOL will manage the following personal information either directly or through individuals in charge, considering the relationship held with each RIGHT HOLDER: 4.1.1. Prospective employees. General: full name, date and place of birth, age, gender, nationality, marital status, profession, official photo ID, images or photographs, voice, signature, domicile (street, exterior and interior number, district, city, state, municipality, zip code), landline and mobile phone numbers, email, TIN, and Single Population Record Number (CURP). Academic: educational level, schools, period of studies, degrees earned, and professional training courses. Family information: name, age, schooling, phone number, and profession of parents, siblings, children, and/or spouses. Professional experience: company name, period of employment, address, phone number, position, reason for leaving, and name of direct supervisor. Personal and professional references: name, address, phone number, and profession. ETON SCHOOL hereby declares that it will be able to manage the RIGHT HOLDER – Prospective employee’s sensitive personal information, such as past and present health information, in order to evaluate their eligibility for employment, and, per article 9 of the FAPPIGIPI, the RIGHT HOLDER – Prospective employee will be required to give his or her explicit, written, and signed consent using the corresponding forms in order to authorize such management. Copies of the following documents: official photo ID, birth certificate, curriculum vitae, TIN card, Single Population Record Number (CURP), proof of residence, social security, proof of studies, professional license, front page of a bank account statement, Infonavit credit letter (if applicable), and immigration document (for foreigners). 4.1.2. Employees. General: full name, date and place of birth, age, gender, nationality, marital status, profession, official photo ID, images or photographs, voice, finger print, signature, domicile (street, exterior and interior number, district, city, state, municipality, zip code), landline and mobile phone numbers, email, social security number, TIN, and Single Population Record Number (CURP). Academic: educational level, schools, period of studies, degrees earned, and professional training courses. Family information: name, age, schooling, phone number, and profession of parents, siblings, children, and/or spouses, as well as family contact information in case of emergency. Professional experience: company name, period of employment, address, phone number, position, reason for leaving, and name of direct supervisor. Personal and professional references: name, address, phone number, and profession. ETON SCHOOL hereby declares that it will be able to manage the RIGHT HOLDER – Employee’s sensitive personal information, such as past and present health information, in order to evaluate whether his or her physical condition allows him or her to perform his or her duties, and, per article 9 of the FAPPIGIPI, the RIGHT HOLDER – Employee will be required to give his or her explicit, written, and signed consent using the corresponding forms in order to authorize such management. Copies of the following documents: official photo ID, birth certificate, curriculum vitae, TIN card, Single Population Record Number (CURP), social security number, proof of residence, proof of studies, professional license, front page of a bank account statement, Infonavit credit letter (if applicable), and immigration document (for foreigners). 4.2. The RIGHT HOLDER hereby agrees, per article 8 of the of the FAPPIGIPI, that ETON SCHOOL will manage his or her personal information, including financial and asset information listed in this clause, in order to comply with the purposes stated in this Privacy Notice. 4.3. The RIGHT HOLDER hereby agrees,