Comprehensive Privacy Notice:
COVID 19 MONITORING
To prevent COVID-19 contagion and dissemination, and as part of the safety and disease prevention measures in favor of the employees of Bello, Gallardo, Bonequi y García, S.C. and its visitors, we have implemented an information and monitoring process, as well as a Supervision Filter according to the “Strategy for the reopening of social, educational and economic activities” of the Federal Government, the “Recommendations for a healthy return to work as part of the employment support policy for COVID-19” of the Mexican Social Security Institute, the “Technical Guidelines for Health Safety in the Work Environment” of the Ministry of Health, and the “General Guidelines for closed public spaces in COVID-19” of the Ministry of Health.
A. Identity and Domicile of the Data Controller.
Pursuant of the provisions of the Federal Law on Protection of Personal Data Held by Individuals (the "LFPD"), and the remaining applicable provisions, Bello, Gallardo, Bonequi y García, S.C. (hereinafter and indistinctly, "BGBG" or the "Data Controller"), with domicile for service of process in Agustín Manuel Chávez, número 1-001, Centro de Ciudad de Santa Fe, Zip Code: 01210, Mexico City, Mexico, informs that:
B. Personal Data Gathered and Submitted to Processing.
To carry out the purposes described in this privacy notice, we will collect the following personal data:
- Identification data;
- Sensitive personal data (health data).
For the purposes described in this Notice, we must process sensitive personal data related to your health condition. This sensitive personal data will be provided directly by you and, in the case of your body temperature, this information will be obtained by electronic means.
C. Processing Purposes.
BGBG will process your personal data for the following primary purposes:
- Adopt safety and disease prevention actions in BGBG facilities in favor of our employees and visitors.
- Implement a monitoring process and a supervision filter to prevent the contagion and dissemination of COVID-19, according to the "Strategy for the reopening of social, educational, and economic activities" of the Mexican Federal Government; the "Recommendations for a healthy return to work as part of the policy to support employment due to COVID-19" of the Mexican Social Security Institute; the "Technical Guidelines for Sanitary Safety in the Work Environment" of the Ministry of Health; and the "General Guidelines for the Mitigation and Prevention of COVID-19 in Enclosed Public Spaces" issued by the Ministry of Health.
- Instruct our employees and visitors to adopt additional measures to prevent the spread of diseases, including masks and hydroalcoholic gel.
- If necessary, and under objective criteria related to COVID-19 symptoms, refer our employees and visitors to medical services for further assessment.
We will not use your personal data for secondary purposes.
D. Personal Data Transfers.
Your personal data may be shared within the territory of Mexico, in the following cases, to the following recipients and for the following purposes:
- Judicial or administrative authorities, for compliance with obligations under the General Health Law or in agreements issued for compliance with the General Health Law during the health emergency declared on March 30, 2020.
The above data transfers do not require your consent to be carried out.
E. ARCO rights exercise
In all legally proceeding cases, you may exercise your rights to Access, Rectify, Cancel, and Oppose (ARCO) through the procedures that we have implemented.
The relevant request must comply with the requirements established in the current legislation by writing to our Personal Data Area through the email datospersonales@bgbg.mx. The request must contain and be accompanied by the following:
- Your name and domicile or another means to communicate to you the response to your request;
- The documents proving your identity or the legal representation, as applicable;
- The clear and precise description of the personal data from which the intention is to exercise some of the ARCO Rights; and
- Any other element or document that facilitates the localization of your personal data.
BGBG will inform you of the decision taken within a maximum period of 20 (twenty) business days from the date it receives the relevant request. If the request is applicable, it will be effective within 15 (fifteen) business days from the date on which BGBG communicates the response. If the information provided in your application is incorrect or insufficient, or if you do not provide the necessary documents to prove your identity or legal representation, BGBG will require you to rectify the deficiencies in order to process your request. In these cases, you will have 10 (ten) business days to respond to the request for rectification, counted from the day after you have received this request. The request will be deemed as not filed if you do not respond within that period.
You may obtain the requested information or personal data through uncertified copies, electronic documents in conventional formats (Word, PDF, etc.), or through any legitimate means guaranteeing and accrediting the effective exercise of the requested right.
The use of electronic means for the exercise of ARCO Rights authorizes BGBG to answer the relevant request through the same means unless the owner clearly and expressly points out another means.
F. Consent revocation.
You may revoke your consent to the processing of your personal data, without any retroactive effect, in all cases where such revocation does not result in the impossibility of fulfilling obligations arising from a legal relationship with BGBG or the compliance with legal provisions applicable to the health emergency declared on March 30, 2020.
The procedure for the revocation of consent will be the same as the procedure established in the section above for the exercise of ARCO rights, if applicable.
H. Amendments or Updates to this Comprehensive Privacy Notice.
BGBG may amend, update, extend, or otherwise change the content and scope of this Comprehensive Privacy Notice at any time and under its complete discretion. In such cases, BGBG will post those changes on the website www.bgbg.mx, section "Privacy Notices".
G. Limitations on Disclosure of Your Personal Data.
The processing of your personal data for the purposes set out in this privacy notice entails a legal limitation on the use or disclosure of this information to what is strictly necessary to fulfill these purposes. BGBG may not use or disclose your personal data for any other purpose.
Notwithstanding the foregoing, you may request a limitation on the use or disclosure of your personal data by expressly requesting this in writing. The requirements and the procedure of attention will be the same as those defined for the exercise of ARCO rights established in this privacy notice.
Last update: June 8, 2020.