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PRIVACY POLICY

DATA PULSE ANALYTICS, S.C. 

DATA PULSE ANALYTICS, S.C. makes this comprehensive Privacy Notice available to all individuals whose Personal Data (the “Data Subjects”) it may process, in compliance with the Federal Law on Protection of Personal Data Held by Private Parties (the “Personal Data Law”).

 

We inform you that your Personal Data, including any Sensitive Personal Data you may provide, will be collected by Data Pulse and processed by it and/or its controlling company (if applicable), affiliates and/or subsidiaries (if applicable), and/or third parties (the “Related Parties”) who, due to the nature of their functions, require access to such data. All data will be handled in accordance with the principles of Lawfulness, Consent, Information, Quality, Purpose, Loyalty, Proportionality, and Accountability, as established by the Personal Data Law.

 I. Identity and Address of the Controller

Data Pulse Analytics, S.C., located at Avenida Jazmín No. 4, San José Iturbide, Guanajuato, C.P. 37983, is responsible for processing the Personal Data you provide.

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Contact: Phone: 442 327 508 · Email: info@datapulse.com.mx · Website: https://datapulse.com.mx

 II. Personal Data Subject to Processing

We may collect identification, contact, and financial data (only when essential to fulfill contractual obligations with you). Personal Data may be collected in person, through our website, or via online services.

 

Examples of collected data include: name, address, phone number, RFC, CURP, gender, email, marital status, place of birth, and bank account details (if applicable).

III. Sensitive Personal Data

Data Pulse states that, in order to fulfill the purposes set forth in this Privacy Notice, it does not collect Sensitive Personal Data, including data that may reveal aspects such as racial or ethnic origin, current and future health status, genetic information, religious, philosophical, and moral beliefs, union affiliation, political opinions, sexual orientation, among others.

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For the necessary and ancillary purposes indicated in this Privacy Notice, we may collect your personal data in different ways: when you provide it to us directly and in person; or directly when you visit our website or use our online services.

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The Personal Data we will obtain through the means described above are the following: name, address, telephone number, RFC (Tax Identification Number), CURP (Customer Identification Number), gender, email address, marital status, place of birth, and bank account (if applicable).

IV. Purpose of Processing

​Data Pulse and the Associated Persons will process your Personal Data for the following Main Purposes:

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  • Data Pulse and the Associated Persons will process your Personal Data for the following Main Purposes:

  • The execution of each and every transaction and provision of services to which Data Pulse undertakes to the Data Subject;

  • The execution of acts that Data Pulse is obligated to perform, in accordance with the Law or its Bylaws;

  • The marketing of Data Pulse products or services;

  • To inform the Data Subject of any changes that need to be made to the aforementioned transactions and provision of services;

  • To respond to requests or requirements from the Data Subject, including quotes related to the transactions and services provided by Data Pulse;

  • To share information with the Data Subject about the products and services contracted with Data Pulse;

  • To issue invoices corresponding to the contractual relationship between the Data Subject and Data Pulse;

  • Data Pulse's internal analysis and audits;

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Likewise, the Personal Data obtained from the Data Subject may be used for the following additional purposes:

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  • Sending commercial and/or advertising communications regarding the products and services offered by Data Pulse, as well as for commercial prospecting; and

  • Conducting surveys and analytical processes, as well as market research related to the products and services carried out by Data Pulse.

V. Mechanism to Refuse Secondary Use of Data

The Data Subject shall have the right at all times to object to the use of their Personal Data for additional purposes, without affecting the services or products contracted with Data Pulse.

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If you wish to object to the processing of your Personal Data for the aforementioned additional purposes from the moment this Privacy Notice is made available to you, please state this in the following section: I agree to the processing of my Personal Data for the additional purposes set forth in this Privacy Notice.

VI. Data Transfers

DATA PULSE is not required to transfer the Data Subject's Personal Data. However, please be advised that, in accordance with Article 36 of the Personal Data Law, the transfer of Personal Data is authorized without the need for specific consent in the following cases:

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i. If the transfer is provided for in a law or treaty to which Mexico is a party;

 

ii. When the transfer is necessary for medical prevention or diagnosis, the provision of healthcare, medical treatment, or the management of healthcare services;

 

iii. If the transfer is made to Data Pulse's controlling companies, or to subsidiaries or affiliates under Data Pulse's control, or to a parent company or any company within the same Data Pulse group that operates under the same internal processes or policies;

 

iv. When the transfer is necessary by virtue of a contract entered into or to be entered into, in the interest of the Data Subject, by Data Pulse with a third party;

 

v. If the transfer is necessary or legally required to safeguard the public interest, or the prosecution or administration of justice;

 

vi. When the transfer is necessary for the recognition, exercise, or defense of a right in a judicial proceeding; and

 

vii. If the transfer is necessary for the maintenance or fulfillment of a legal relationship between Data Pulse and the Data Subject.

 

Notwithstanding the foregoing, should Data Pulse need to transfer the Data Subject's Personal Data in any case not provided for in those listed above, we undertake to request your prior written consent for such purpose.

VII. Means and Procedure for the Holder to exercise his ARCO Rights

If the Data Subject wishes to exercise their rights of Access, Rectification, Erasure, or Objection to the processing of their Personal Data, we kindly request that you:

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i. Send an email to info@datapulse.com.mx; or

 

ii. Submit your request in writing to the aforementioned Data Pulse address, Monday through Friday, from 10:00 a.m. to 5:00 p.m.

 

In either case, please send it to the attention of Jonathan Dominguez Aldana, who will be responsible for processing your request. The respective request, in accordance with the "Personal Data Law," must contain the following:

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Name of the Data Subject and address, and another means of communicating the response to their request.

Documents proving the identity or, where applicable, the legal representation of the Data Subject.

 

A clear and precise description of the Personal Data for which you are seeking to exercise any of the rights of Access, Rectification, Erasure, or Objection.

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Any other element or document that facilitates the location of the Personal Data.

In the case of rectification of Personal Data, you must indicate, in addition to what is indicated in the previous points, the modifications to be made and provide the documentation that supports your request (if applicable).

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The response to your request will be sent to you within a maximum of 20 business days from receipt of the respective request, via the email or to the address you provided in your request.

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If the aforementioned request is approved, it will be effective within 15 business days following the date on which the respective response is communicated to you.

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These deadlines may be extended once for an equal period, provided that the circumstances of the case justify it and it is communicated to you within the first 20 business days following receipt of your request.​

The Data Subject has the right to access the Personal Data held in Data Pulse's databases; to the details of their processing; to request rectification if they are inaccurate; and to request their cancellation when, due to a change in the contractual relationship between the Data Subject and Data Pulse, the Data Subject considers them to be excessive or unnecessary to fulfill the primary and secondary purposes mentioned above.

 

If you wish to access your Personal Data, such access may be provided on-site or by providing you with a simple or electronic copy of the Data Subject's Personal Data held in Data Pulse's databases.

 

When the Data Subject intends to rectify the Personal Data held by Data Pulse, it will be necessary to provide us with evidence that confirms the requested rectification.​

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Finally, the Holder is hereby informed that the exercise of ARCO rights may be restricted for reasons of national security, public order, public health and safety, or to protect the rights of third parties, in the cases and to the extent provided for in the applicable laws on the matter, or by means of a duly substantiated and reasoned resolution by the competent authority.

VIII. Mechanisms and Procedure for revoking consent.

The Data Subject may revoke the consent they have given Data Pulse for the processing of their Personal Data and, consequently, request the deletion of said Personal Data from Data Pulse's databases, provided that such revocation is made in writing, in accordance with the terms set forth in the immediately preceding section.

 

However, it is important to note that Data Pulse may not always respond to your request immediately or terminate the use of your Personal Data at the time you request it, particularly in the following cases, provided for in Article 25 of the Personal Data Law:

 

a. When the Personal Data is necessary for the development or fulfillment of a contract entered into between the Data Subject and Data Pulse;

 

b. When the obligation to continue processing arises from a legal provision;

 

c. When the deletion of your Personal Data may hinder judicial or administrative proceedings related to tax obligations, the investigation and prosecution of crimes, or the enforcement of administrative sanctions;

 

d. If the Personal Data is necessary to protect the Data Subject's legally protected interests;

 

e. When the erasure of their Personal Data could prevent an action from being taken based on the public interest; and

 

f. If the Personal Data is necessary to comply with a legal obligation incurred by the Data Subject.

 

Additionally, the Data Subject may object to the processing of their Personal Data in those cases where:

 

i. There is a legitimate reason and their specific situation requires it to avoid harm to the Data Subject, for which reason said legitimate reason must be justified; and

 

ii. If they request that their Personal Data not be processed for any of the purposes set forth in this Privacy Notice.

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The foregoing should be noted, without losing sight of the fact that the right to object does not apply in those cases where the processing of the Data Subject's Personal Data is necessary to comply with a legal obligation imposed on Data Pulse.

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Likewise, it is important to consider that there may also be cases in which revoking your consent would mean that Data Pulse would cease to provide the services requested, restrict their execution, or have to proceed with their termination.

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In any of the cases mentioned herein, the means and procedures for the Data Subject to request revocation of their consent will be the same as those indicated in section VI above, with the understanding that Data Pulse's response will be made in accordance with the timeframes and conditions indicated in the section in question.

IX. Means to limit the use or disclosure of Personal Data

At any time, the Data Subject may object to the processing of his or her Personal Data for the additional purposes mentioned herein, as well as to limit the use and disclosure thereof.

For such purposes, the means and procedures will be the same as those indicated in Section VI above, with the understanding that Data Pulse's response will be made in accordance with the timeframes and conditions indicated in the section in question.

X. Use of Cookies and Similar Technologies 

We use cookies, web beacons, and/or similar technologies to enhance your experience on our website. These tools collect information such as your IP address, browser type, pages visited, and the length of your visit. This information can be used to analyze trends, administer the site, and improve our services. You can disable these technologies in your browser settings, but please be aware that this may affect site functionality.

XI. Privacy Notice Updates

Data Pulse may modify or update this Privacy Notice in those cases where such modification is necessary to address legislative reforms to applicable regulations or to Data Pulse's internal policies, or if it is necessary to meet new requirements for the provision and offering of Data Pulse's services or products.

 

The Data Subject will be informed of any modifications or updates to this Privacy Notice by email to Data Pulse, which will be available to the public through our website https://datapulse.com.mx in the Privacy Notice section. Therefore, we suggest you pay attention to any modifications or updates.

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Notwithstanding the foregoing, the Data Subject may request information at any time by emailing info@datapulse.com.mx

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