Grupo Tecnophone Privacy Policy
Last updated: February 27, 2025
This English version is provided for information purposes only. In the event of any discrepancy, the Spanish version prevails.
Introduction
This document describes the privacy and integrity policies of GRUPO TECNOPHONE S.A. DE C.V. (hereinafter, “GRUPO TECNOPHONE”) that apply to the use and processing of Personal Data obtained and stored through our websites gtecnophone.com and grupotecnophone.com (hereinafter the “Sites”) and through the SMS sending management tool (hereinafter the “Console”).
Our goal is to be transparent about the information we collect from each identified or identifiable individual (hereinafter the “Data Subject”), ensuring that this Personal Data is processed in accordance with Mexico’s 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”), its Regulations and the applicable Privacy Notice Guidelines in Mexico, as well as with the European Union’s General Data Protection Regulation (“GDPR”), where applicable.
It also sets out the procedures and guiding principles for the processing of Personal Data to guarantee the exercise of ARCO rights (Access, Rectification, Cancellation and Opposition) and any other right provided for by applicable law.
Glossary of Terms
Privacy Notice: Electronic document that sets out the principles and procedures for the processing of Personal Data. Database: Organized set of Personal Data relating to an identified or identifiable person. Consent: Expression of the Data Subject’s will for the processing of Personal Data, whether express or implied. Personal Data: Any information concerning an identified or identifiable individual. Processor: Individual or legal entity that, alone or jointly with others, processes Personal Data on behalf of the Controller. GDPR: The European Union’s General Data Protection Regulation. LFPDPPP: Federal Law on the Protection of Personal Data Held by Private Parties, in force in Mexico. Controller: Private individual or legal entity that decides on the processing of Personal Data. Data Subject: The individual to whom the Personal Data belongs. Processing: The collection, use, disclosure or storage of Personal Data by any means. User: Individual or legal entity that accesses gtecnophone.com and/or grupotecnophone.com, and/or uses the Console after contracting GRUPO TECNOPHONE’s services. Console: Tool for sending SMS, creating SMS surveys, segmenting through surveys, SMS chat, and importing segmented databases. Sites: gtecnophone.com and grupotecnophone.com.
Stored Personal Data: Consent, Purpose and Revocation
A) For the Sites (gtecnophone.com and grupotecnophone.com):
When you visit our Sites, GRUPO TECNOPHONE may directly collect the following Personal Data from Data Subjects:
Name
Email address
This Data is collected for the following purposes:
To provide the User with a trial or demo account of the services offered by GRUPO TECNOPHONE.
To establish a communication channel with Users to handle requests for information or support.
B) For the Console:
The Console stores only mobile phone numbers. These numbers cannot, by themselves, be associated with the identity of their Data Subjects or with other types of Personal Data, unless the User decides to add more information. Console Users (GRUPO TECNOPHONE’s Clients) act as Controllers of the Personal Data they choose to store, and it is their responsibility to:
Obtain the express or implied consent of Data Subjects for the processing of their Personal Data (phone numbers).
Ensure they have a permission-based database, or one backed by an Opt-In (express authorization) given by the Data Subject via SMS or another valid means.
Handle any request to revoke consent or object to processing submitted by Data Subjects.
Revocation of Consent:
The Data Subject may revoke the consent given for the processing of their Data through the procedure established by the Console User with whom they have a legal relationship. In addition, for Data collected directly by GRUPO TECNOPHONE, the Data Subject may revoke their consent at any time by sending an email to contacto@gtecnophone.com or by visiting the address indicated in the Contact section.
GRUPO TECNOPHONE’s Obligations
GRUPO TECNOPHONE undertakes to:
Comply with the Personal Data protection principles set out in the LFPDPPP, the GDPR (where applicable) and this Privacy Notice.
Take the necessary measures to ensure that this Privacy Notice is respected by employees, clients and suppliers involved in any stage of the processing of Personal Data.
Keep Data Subjects informed about the Personal Data collected and the purposes for which it is used.
Implement administrative, technical and physical security measures that protect Personal Data against damage, loss, alteration, destruction or unauthorized access.
Require Console Users to have a means of guaranteeing Data Subjects’ consent to the processing of their Personal Data.
Maintain the confidentiality of the Personal Data processed, an obligation that continues even after the relationship with the Data Subject or, where applicable, with the Controller has ended.
Security and Protection of Personal Data
The Personal Data provided by Users of both the Sites and the Console is stored on secure servers located in specialized data centers, with standard encryption measures (128-bit SSL or equivalent) to protect the information in transit. GRUPO TECNOPHONE maintains these protection measures to ensure that Personal Data is accessible only to authorized personnel and for the purposes set out herein. Personal Data will be retained only for the period necessary to fulfill the purposes described, in accordance with applicable legal provisions. Once the purpose has been fulfilled and the legal retention periods have elapsed, the data will be deleted or blocked.
Rights of the Data Subject (ARCO Rights)
Under the LFPDPPP and other applicable regulations, Data Subjects have the following rights (known as ARCO Rights):
Access: To know whether their Personal Data is being processed, as well as the scope and conditions of that processing.
Rectification: To request the correction of their Personal Data when it is inaccurate or incomplete.
Cancellation: To request the deletion of their Personal Data from the Database when they consider it is not necessary for the purposes for which it was collected.
Opposition: To object to the processing of their Personal Data for specific purposes, if they do not want it to be used.
These rights may be exercised at any time by sending a written request or an email to contacto@gtecnophone.com, meeting the requirements set out in applicable law (name, address or other means of receiving notifications, documents proving identity or legal representation, a clear description of the Personal Data covered by the request, and any other element that helps locate it). GRUPO TECNOPHONE will respond to such requests within a maximum of 20 (twenty) business days and will implement the decision within an additional 15 (fifteen) business days, if the request is granted.
Exercising ARCO Rights
To exercise ARCO Rights regarding Personal Data processed by GRUPO TECNOPHONE, the Data Subject or their legal representative must:
Submit a request in writing, by phone or by email to contacto@gtecnophone.com;
Provide a name and address or another means of communicating the response;
Prove the Data Subject’s identity or, where applicable, their legal representation;
Clearly describe the Personal Data regarding which any of the rights is to be exercised;
Provide any other element or document that helps locate the Personal Data.
If GRUPO TECNOPHONE is not the direct Controller of the Personal Data, it will inform the Data Subject and forward the available information so the request can be fulfilled.
Use of Cookies and Consent to Their Use
For our Sites and the Console to work properly, we use cookies and similar technologies to collect information that helps us improve your browsing experience. We may use a consent management platform (CookieFirst or another) that asks for your authorization to use and store cookies in your browser. These cookies may collect, among other data:
Anonymized IP address
Browser type and version
Pages visited and browsing time
Approximate location
Date and time of access
The Data Subject may disable or configure cookies at any time through their browser settings. However, doing so may affect the functionality of certain sections of the Sites or the Console. For more information about the use of cookies and how to disable them, you may contact us using the contact details indicated in this Notice.
Processing of Personal Data for Other Purposes
GRUPO TECNOPHONE may also collect and process Personal Data for other purposes in the following cases:
Recruitment Processes: When the Data Subject submits their information to take part in recruitment processes. The data will be retained for a maximum of two years, unless the Data Subject revokes their consent earlier.
Use of Image: If consent is required for marketing or commercial promotion purposes (e.g., use of photographs or videos), the Data Subject will be informed and their consent will be obtained in accordance with applicable law.
Transfer to Third Parties: When it is necessary to communicate Personal Data to suppliers or business partners, the Data Subject’s express authorization will be obtained, unless a legal provision allows it without such consent.
The retention period for Personal Data will depend on the purpose and on the applicable legal obligations.
Transfer of Personal Data to Other Countries
GRUPO TECNOPHONE will not transfer Personal Data to other countries without the Data Subject’s prior consent, unless there is a legal obligation or the conditions provided for in applicable law are met (for example, standard contractual clauses or adequacy decisions by the relevant authority). If an international transfer of Personal Data is necessary, the Data Subject will be informed of the purpose of the transfer, the recipient of the Data and, where applicable, the legal safeguards that apply.
Integrity and Anti-Corruption Policy
In accordance with Mexican anti-corruption legislation, which includes the Federal Anti-Corruption Law on Public Procurement and the National Anti-Corruption System (General Law of the National Anti-Corruption System, General Law of Administrative Responsibilities, and other applicable provisions), GRUPO TECNOPHONE adopts the following guidelines:
Improper Influence: Any act or conduct that seeks to unduly influence public officials, clients, suppliers or other third parties in order to obtain unlawful advantages or undue benefits for GRUPO TECNOPHONE is prohibited.
Bribery and Extortion: No employee, partner or third party may offer, promise, give or request anything of value to obtain improper advantages, whether in the public or private sphere.
Contracting with Public Entities: GRUPO TECNOPHONE will take part in administrative procedures or public tenders transparently and in accordance with the applicable legal provisions, avoiding collusion or fraud.
Red Flags: Any suspicious situation that may involve a breach of anti-corruption legislation must be reported (requests for cash payments, false documentation, disproportionate increases in commissions, among others).
Information Handling: The improper manipulation, alteration or destruction of files or records that may be required by authorities in the course of investigations is prohibited.
Gifts, Travel or Hospitality: Any benefit offered to third parties must be reasonable, justified and transparent, and must not seek to unduly influence decision-making.
Hiring of Public Servants: Any employment or contractual relationship with a public servant will comply with the exceptions provided for by law, avoiding conflicts of interest or undue advantages.
Penalties: Failure to comply with these provisions may result in administrative, civil or criminal penalties, in addition to the corresponding termination of employment or contract.
Changes to the Privacy Notice
GRUPO TECNOPHONE reserves the right to modify, update or expand this Privacy Notice to reflect changes in legal requirements, in our data protection practices or for other legitimate reasons. Changes will be published on the Sites gtecnophone.com and grupotecnophone.com and, where appropriate, Data Subjects will be notified by email before such changes take effect.
Contact
For comments, questions, complaints, claims or the exercise of ARCO rights related to this Privacy Notice, you may contact:
GRUPO TECNOPHONE S.A. DE C.V.
Address: Camino a Minas 10 – Int. 304, Av. Palo Solo, Huixquilucan, Estado de México, C.P. 52778, Mexico
Phone: 5398 9800 – 5290 0160
Email: contacto@gtecnophone.com
Privacy Notice and Personal Data Officer. © 2025 GRUPO TECNOPHONE S.A. DE C.V. All rights reserved.