INTEGRAL PRIVACY NOTICE FOR CUSTOMERS
(REAL OR POTENTIAL) OF INSTAPOUCH, SAPI DE CV

In accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (the "Law"), its Regulations (the "Regulations") and the Guidelines of the Privacy Notice (the "Guidelines"), it is issued this Privacy Notice in the following terms:

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I. RESPONSIBLE FOR PERSONAL DATA

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The person responsible for the treatment of obtaining, disclosure, storage, use, handling, exploitation, transfer and / or disposition of personal data (the "Treatment") is INSTAPOUCH, SAPI DE CV ("Instapouch"), in relation to the services manufacturing of flexible packaging solutions digitally printed, preformed or in roll, which Instapouch offers, with address at Filiberto Gómez 62, Interior 101, Centro Industrial, Tlalnepantla, Estado de México, 54030.

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II. PERSONAL DATA TO COLLECT

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Instapouch may collect various personal data from its real individuals (“Clients”), prospects from individuals (“Prospects”), and other individuals (any of the above a “Holder”), as required for the purposes of Treatment, whether obtained personally or directly from the Owner or indirectly.

Instapouch informs that the categories of personal data that it may collect are the following:

  1. In the case of Clients or Prospects:

    1. General identification data: Name, current address, sex, marital status, country, place and date of birth, key of the Federal Taxpayer Registry or tax identification number, regime and / or tax address for billing purposes.

    2. Contact information: Contact phones (home, office and / or cell phone) with country and area codes and extensions, and email.

    3. Professional or business information: occupation, name of and position in the company where you work or, where appropriate, the company owned by the Owner, industry to which said company belongs, as well as the address and telephone number of said company.

    4. Financial and patrimonial data: account numbers, CLABE and credit or debit cards, including Holder information, number, expiration date and security code. This personal data will only be obtained in the event that the Owner wishes to make the corresponding payment directly to Instapouch and, therefore, provides said data to Instapouch. In the event that the owner makes any payment through third-party platforms such as PayPal or PayU Latam, Instapouch will not collect financial and equity data from the Owner.

    5. Others: username and password for access and use of the site www.instapouch.com .

    6. Legal information: Any information that Instapouch is obliged to collect in accordance with the applicable legal provisions in force.

    In the event that you voluntarily provide personal data of third parties to Instapouch, you declare that you are authorized by the corresponding third party to provide Instapouch with such data and / or that by sharing them with Instapouch you do not breach any legal obligation or provision.

  2. In the case of legal representatives or attorneys: In the case of legal representatives or attorneys who are natural persons, Instapouch may collect their name, official identification, functions or positions (if applicable), email, telephone (s) and that information contained in the vouchers you provide to Instapouch. Instapouch may collect a copy of the vouchers related to the aforementioned personal data, as required for the purposes of the Treatment. In addition, Instapouch may collect any other personal data of any nature (i) that the Holder freely provides Instapouch by any means, including electronic or other means, and / or (ii) any personal data contained in the supporting documentation. , whether through printed, electronic, optical or any other technology or nature, that the Owner provides to Instapouch. Personal data may be collected through different sources, including:

    1. Personally: When the Owner of the information provides his data in any of the Instapouch offices.

    2. Direct: When the Owner of the information provides their data through any Internet page or Instapouch telephone center or authorized by Instapouch, by email, or by any other electronic, optical, sound, visual or technological means.

    3. Indirect: From any other source of information available or that is permitted by current legislation.

    The information collected may be combined to assist Instapouch for Treatment purposes.

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III. PURPOSES TO WHICH THE PROCESSING OF PERSONAL DATA WILL BE SUBJECT

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The Treatment of personal data collected by or otherwise provided to Instapouch, has the following main or necessary purposes:

  1. Main or necessary purposes


    • In the case of the Client or Prospect:

      1. During the service request process:

        • The identification and knowledge of the Client or Prospect

        • The price of the services that Instapouch offers

        • Processing, monitoring and, where appropriate, approval of service requests and financial capacity assessment to determine if you are eligible for Instapouch to provide services to you

        • Registration or cancellation in Instapouch directories, databases and systems for the purposes of the services offered by Instapouch, before and after acceptance of the service request

        • Creation or modification of user, account and password; as well as, where appropriate, unsubscribe from said user, account and password;

        • Risk assessment and analysis;

        • Contact, rectification and updating of your information

        • Integration of files

        • Administration of the possible legal relationship with the Owner

        • Allow the Owner access to the online platform (s) and Instapouch applications to generate their username and password, consult, quote and request services, electronic invoicing, and other functionalities offered through said platform (s). ) and applications

        • In your case, give attention to the claims presented before the Federal Consumer Prosecutor ("PROFECO") and / or other competent authorities

        • Compliance with the laws and regulations applicable to Instapouch

      2. Services request approved

        • Provision of services in accordance with the Instapouch Terms and Conditions, and related documentation

        • The origin, existence and maintenance of the legal relationship between the Holder and Instapouch, and the fulfillment of the corresponding obligations

        • Registration or cancellation in Instapouch directories, databases and systems for the purposes of the services offered by Instapouch, before and after acceptance of the service request

        • Creation or modification of user, account and password; as well as, where appropriate, unsubscribe from said user, account and password;

        • Shipping and delivery of the products requested by the Owner

        • Monitoring and risk analysis

        • Collection and billing

        • Customer services

        • Administration of the legal relationship with the Owner

        • Attend and process payments, in case the Holder has decided to make the corresponding payment directly to Instapouch and not through third-party platforms such as PayPal or PayU Latam.

        • Refunds of balances in favor or unrecognized charges

        • Carrying out procedures before local and federal authorities

        • Follow-up and verification of the information that was provided by the Holder to Instapouch for the purposes of requesting services

        • Collection and judicial and / or extrajudicial recovery management of the consideration for the services and their accessories

        • Allow the Owner access to the online platform (s) and Instapouch applications to generate their username and password, consult, quote and request services, electronic invoicing, and other functionalities offered through said platform (s). ) and applications

        • Pay attention to claims filed with PROFECO and / or other competent authorities

    • In the case of legal representatives or attorneys who are natural persons, only to prove the representation of the person being represented, the scope of the powers and the identity of the representative, as well as for the origin, maintenance, administration and termination of the relationship between the person I represent and Instapouch.

  2. Additional or secondary purposes As additional or secondary purposes that are not necessary are the information on products, services or events, including advertising, newsletters and surveys, improvements in service processes, as well as the recognition and attention.

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If the Owner does not want their personal data to be processed for any or all of the additional or secondary purposes, the Owner may at any time express such refusal by sending an email to the address ventas@folmex.com.mx

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The Treatment may also consist of purposes that are compatible with all of the above, without for this, when necessary, requiring the consent of the Owner again, and subject to the limitations established in the applicable regulations.

In the event that it does not express its refusal, at any time the Holder may exercise his right of revocation of consent or opposition in terms of this Privacy Notice, the Law and its Regulations.

As options and means that Instapouch makes available to the Owner to limit the use and disclosure of their personal data, other than the exercise of rights of access, rectification, cancellation and opposition or the revocation of consent, Instapouch informs that it has enabled a list of Applicable exclusion with respect to the aforementioned additional or secondary purposes, in which the Owner who so requests will be registered by sending an email to the address ventas@folmex.com.mx or in writing through the other means of contact enabled by Instapouch .

The Treatment may also consist of purposes that are strictly compatible or analogous to the above, without for this, when necessary, requiring the consent of the Owner again, and subject to the limitations established in the applicable regulations.

In any case, the Treatment will be the one that is indispensable, necessary, adequate and relevant in relation to the purposes provided in this Privacy Notice, as well as for the different purposes that are strictly compatible.

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IV. TRANSFERS OF PERSONAL DATA

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  1. Main and necessary transfers Instapouch may carry out the following national and / or international transfers of personal data to the extent that it is necessary for the purposes of the specific purpose of the Treatment and, where appropriate, for the origin, existence and maintenance of the legal relationship. :

    1. Regarding Prospects:

      1. Service providers.
        Personal data may be disclosed to third-party service providers and business partners for the purposes of processing your service request.

      2. Auditors and advisers.
        Personal data may be communicated or consulted by Instapouch's external auditors and advisers, insofar as it is strictly necessary to comply with the obligations imposed by the financial, criminal and fiscal legal provisions.

    2. In the case of Clients:

      1. Service providers. Personal data may be communicated to third-party service providers and / or business partners for the fulfillment of the obligations acquired by Instapouch with the Holder or by the latter, including third-party messaging service providers to send the products derived from the services. requested by the Client, as well as providers of the electronic invoicing service for such purposes.

      2. Banking institutions and payment processors. Only in the event that the Holder has decided to make the corresponding payment directly to Instapouch and not through third-party platforms such as PayPal or PayU Latam, personal data may be communicated to banking institutions, credit card companies and payment processing, in order to make the corresponding charges and chargebacks, or clarify improper charges or not correctly applied and, in general, for the fulfillment of the payment obligations by Instapouch and / or the Holder.

      3. Judicial and extrajudicial collection. In the event of non-compliance with the obligations of the Client towards Instapouch, Instapouch may share personal data with collection agencies or law firms to carry out collection procedures, whether by email, telephone, personally or by letter, and, where appropriate, through the judicial channel. In case of judicial collection, personal data will also be shared with the judicial authorities for the purposes of the corresponding judicial process. In case of sale or transfer of portfolio, Instapouch may transfer personal data with the corresponding buyer or assignee.

    3. In the case of legal representatives or attorneys:

      1. Service providers.
        Personal data may be communicated to third-party service providers and / or business partners for the fulfillment of the obligations acquired by Instapouch with the person whom the Holder represents, including third-party messaging service providers for the shipment of products derived from the services requested by the person whom the Holder represents.

      2. Judicial and extrajudicial collection.
        In case of breach of the obligations in charge of the person whom the Holder represents against Instapouch, Instapouch may share personal data with collection agencies or law firms to carry out collection procedures, either by email, by phone, in person or by letter, and, where appropriate, through the courts. In case of judicial collection, personal data will also be shared with the judicial authorities for the purposes of the corresponding judicial process. In case of sale or transfer of portfolio, Instapouch may transfer personal data with the corresponding buyer or assignee.

    4. In any case, personal data can be transferred, to the extent necessary, to:

      1. Competent authorities that must know about the operations or activities between the Holder and Instapouch, such as the Ministry of Finance and Public Credit, the Tax Administration Service, PROFECO, and the National Institute of Transparency, Access to Information and Data Protection Personal, among other authorities.

      2. Companies of the business group of which Instapouch is a part.
        In order for Instapouch to process service requests, manage and comply with the obligations assumed towards the Client or Prospect, as well as manage and process the information of the corresponding legal representatives or attorneys, personal data may be transferred to companies. that are part of the business group of which Instapouch is part. Instapouch informs you that the business group of which Instapouch is part has policies, codes and binding internal privacy and data protection regulations that meet the highest national and international standards.

      3. Corporate transactions.
        When personal data requires to be transferred to a third party in the context of a corporate transaction (including mergers, acquisitions, among others), the companies that could receive your information are potential acquirers and advisers (legal, accounting or financial, among others). ) involved in the transaction. Instapouch will only share your personal data to said third parties to the extent that such communication is necessary to evaluate or complete the transaction, with the understanding that said persons will assume the same obligations and / or responsibilities of Instapouch in accordance with this Privacy Notice and will treat said data in accordance with the instructions of Instapouch and only for this purpose.

        In any case, the recipients of personal data will assume the same obligations and / or responsibilities of Instapouch, with the scope and to the extent that it is strictly necessary for the purposes of the specific Treatment and in accordance with what is described in this Privacy Notice.

        Likewise, Instapouch may transfer personal data without requiring the express consent of the Owner, in the cases contemplated by article 37 of the LFPDPPP.

      4. Secondary and unnecessary transfers
        Instapouch may carry out the transfer of personal data to the extent necessary or convenient, in each case, to companies related to Instapouch and its business partners for purposes of advertising and marketing, data analysis, and statistical reports.

        If the Owner does not want their personal data to be transferred for any or all of the additional or secondary purposes, the Owner may at any time express such refusal by sending an email to the email address ventas@folmex.com.mx

        In the event that it does not express its refusal, the Holder may exercise his right of revocation of consent or opposition in terms of this Privacy Notice, the Law and its Regulations.

        In any case, the recipients of personal data will assume the same obligations and / or responsibilities of Instapouch, with the scope and to the extent that it is strictly necessary for the purposes of the specific Treatment and in accordance with what is described in this Privacy Notice.

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V. MEANS AND PROCEDURES FOR THE EXERCISE OF THE RIGHTS OF THE HOLDER

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The Holder of personal data or his legal representative may exercise his rights of access, rectification, cancellation and opposition (subject in any case to the provisions of the applicable regulations), as well as to express his refusal to process his personal data for purposes that are not necessary or main indicated in this Privacy Notice, by sending an email to the email address ventas@folmex.com.mx , or by written request addressed to the same person, to the Instapouch address located in Filiberto Gómez 62, Interior 101, Centro Industrial, Tlalnepantla, Estado de México, 54030, from Monday to Friday, from 10:00 a.m. to 6:00 p.m., in the understanding that in any case said Holder must provide his name, address or email, the legal or commercial or other relationship that you have or have had with Instapouch, information and a copy of the identification that allows you to identify fehacien The Holder or, where appropriate, the representatives or legal representatives, including that which is necessary to prove their personality, indicate clearly and precisely what personal data is the subject of the request, what right (s) you wish to exercise to your personal data and any other particularity that you consider necessary or convenient. In the case of requests for rectification of personal data, the Holder must indicate, in addition to what was previously indicated, the modifications to be made and provide the documentation that supports the origin of your request.

If the request does not meet the above requirements, Instapouch may request the Holder to complete said requirements within a period of 5 (five) business days following receipt of the request, and the Holder will have 10 (ten) business days. to complete said request, with the understanding that if it is not fulfilled by the Holder, the request of the latter will be considered as not filed.

Instapouch will proceed, through the personal data office, to communicate to the Holder, within a maximum period of 20 (twenty) business days that the request is duly completed and delivered to Instapouch, the determination adopted related to such request by email , telephone or address provided by the Owner of personal data, or any other means of public or private communication provided in the documents. If the request is appropriate, Instapouch will carry out the actions related to it within 15 (fifteen) business days after the response is communicated to the Holder or, where appropriate, to his representative or legal representative, in the understanding of Instapouch may only be denied in cases that the Law or its Regulations allow, and will subsequently notify the Holder thereof through the aforementioned means.

To limit the use and disclosure of your personal data, other than the exercise of the rights of access, rectification, cancellation and opposition or the revocation of consent, Instapouch informs that it has enabled an applicable exclusion list with respect to the aforementioned additional or secondary purposes, In which the Holder who so requests will be registered by sending an email to the address ventas@folmex.com.mx or in writing through the other means of contact enabled by Instapouch.

In your case, for the revocation of consent to the treatment of your personal data by the Owner, he must follow the same procedures and use the same means established in this Privacy Notice to exercise the rights of access, rectification, cancellation and opposition, subject in any case to the provisions of the applicable regulations. All of the above, with the understanding that (i) it is important that the Owner considers that Instapouch will not be able to attend to your request or terminate the use immediately, as it is possible that due to some legal or contractual obligation with the Holder, Instapouch needs to continue processing personal data; (ii) for certain purposes, the revocation of your consent will imply that Instapouch cannot continue providing the requested service, or the conclusion of the relationship with Instapouch and at all times the origin of the request will be subject to what is established by the applicable regulations; and (iii) in the event that the revocation of the consent that, where appropriate, has been given by the Owner with respect to the data object of the request and that give or have originated and are necessary for the maintenance of the legal relationship that is appropriate , where appropriate, exists between Instapouch and the Holder, such revocation could imply the termination of said relationship between Instapouch and the Holder.

If the Holder does not express his opposition according to the procedure established in this Privacy Notice so that his personal data is processed for the purposes and / or transfer of personal data indicated in this Privacy Notice, when such consent is required according to Law and its Regulation, it will be understood that you have given your consent for it. The refusal to use your personal data for additional or secondary purposes may not be a reason for Instapouch to deny the services and products that the Owner (in the case of Clients or Prospects) requests or contracts with Instapouch.

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SAW. POLICY FOR TRACKING TECHNOLOGIES ON WEB PAGES

In the event that the Owner accesses and uses the site www.instapouch.com and / or any of the Internet pages of Instapouch or its affiliates, Instapouch informs you that they use cookies1, web beacons2 or other technologies, through which is possible to monitor the behavior of the Owner as an internet user. The personal data that Instapouch collects through these technologies, regardless of whether the owner is a Client or Prospect or not, will be used for the purposes of providing the owner with a better service and experience when browsing this website. All this process is carried out without Instapouch having knowledge of the name of the user and Holder or of any other information that allows identifying him. While the user visits the Instapouch website, he does so anonymously, unless the user himself expressly decides to identify himself with Instapouch.

The personal data we obtain from these tracking technologies are as follows:

  • Identifiers, username and passwords of a session

  • User preferred language

  • Region in which the user is located

  • User browser type

  • User operating system type

  • Date and time of the beginning and end of a user session

  • Web pages visited by a user

  • Searches made by a user

  • Advertising reviewed by a user

  • Lists and consumption habits on shopping pages

These technologies may be disabled in the configuration or settings section of your browser, unless they are necessary for technical reasons.

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VII. CHANGES TO THE PRIVACY NOTICE

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This Privacy Notice may be modified or updated as a consequence of new legal requirements; of our own needs for the products or services we offer; of our privacy practices; of changes in our business model, or for other reasons in terms of the applicable regulations.

1 Cookies means that data file that is stored on the hard drive of a user's computer or electronic communications device when browsing a specific internet site, which allows the exchange of status information between said site and the browser of the user. The status information may reveal means of session identification, authentication or user preferences, as well as any data stored by the browser regarding the website;

2 Web beacons means that visible or hidden image inserted within a website or email, which is used to monitor user behavior in these media. Through these, information such as the source IP address, browser used, operating system, when the page was accessed, and in the case of email, the association of the above data with the recipient can be obtained.

Any change to this Privacy Notice will be informed to the Holder through a notification published on the Instapouch website ( www.instapouch.com ) or sent by any of the following means:

1. Email, telephone or address provided by the Owner of personal data.

2. Any other means of public or private communication provided in the documents and the practice of the relationship between the Owner and Instapouch.

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VIII. HOLDER'S CONSENT

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The use of the website www.instapouch.com implies acceptance of the Website Tracking Technologies Policy contained in this Privacy Notice. These technologies may be disabled in the configuration or settings section of your browser, unless they are necessary for technical reasons. In the event that the owner wishes to exercise, with respect to the personal data indicated in said Policy, any of their rights of access, rectification, cancellation and / or opposition, limit the use or disclosure of their personal data or revoke their consent, the owner You must follow the procedure in section "V. Means and Procedures for the Exercise of Rights of the Holder ”established in this Privacy Notice.

The registration of any holder as a User of the Instapouch website, as well as the completion of any service request by a Holder to Instapouch will mean that the Holder has read and understood this Privacy Notice, and granted his consent for the Treatment of your personal data for the main or necessary purposes and transfers established in this Privacy Notice, as appropriate to the type of Owner in question and as indicated in said Notice.

Regarding those personal data for the purposes and secondary or unnecessary transfers established in this Privacy Notice, if the Owner does not express his opposition in accordance with the process established in this Privacy Notice so that his personal data is processed for said purposes and / or secondary or unnecessary transfers, it will be understood that you have given your consent for it. Refusal to use your personal data for secondary or unnecessary purposes may not be a reason for us to deny the services and products that the Owner requests or contracts with Instapouch. In the event that the Owner wishes to exercise any of his rights of access, rectification, cancellation and / or opposition, limit the use or disclosure of his personal data or revoke his consent, the Owner must follow the procedure in section "V. Means and Procedures for the Exercise of Rights of the Holder ”established in this Privacy Notice.

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© 2018-2019 Instapouch SAPI de CV
All rights reserved

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  • Maximum printing width 28.3 inches.

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