SISTEMA DE TRANSFERENCIAS Y PAGOS STP, S.A. DE C.V., INSTITUCIÓN DE FONDOS DE PAGO ELECTRÓNICO ("STP") is a financial institution that complies with and
respects the rights enshrined in the second paragraph of article 16 of the Constitución Política de los Estados Unidos Mexicanos, with respect to the personal data of individuals, and therefore, this document (hereinafter referred to as the "Privacy Notice") is primarily intended to comply with the provisions of the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (hereinafter, the "Law") and the Reglamento de la Ley Federal de Protección de Datos Personales en Posesión de los Particulares (hereinafter, the "Regulations").
In this sense, STP makes available the Privacy Notice in order that the Personal Data Subject (terms defined below) has the possibility to exercise his/her right to informational self-determination.
Likewise, the Employee, by entering and using the website https://stp.mx/ (hereinafter, "STP Website"), declares that he/she accepts the terms and conditions contained in this Privacy Notice, and therefore, expressly grants his/her consent to use electronic means for such purpose, in terms of the provisions of article 1803 of the Código Civil Federal.
Therefore, in the event that, as Data Subject, you do not fully and completely accept the terms and conditions of the Privacy Notice, you must refrain from providing any type of Personal Data to STP, by any means, including the STP Website.
For the purposes of this Privacy Notice, the term "Personal Data", in its singular or plural form, shall mean any information concerning an identified or identifiable natural person; the term "Data Subject", in its singular and plural form, shall mean the natural person to whom the personal data identifies or corresponds; and the term "Employee", in its singular or plural form, shall mean any natural or legal person who has a subordinate work relationship in force with STP through the execution of an individual employment contract.
I. Identity and address of the person in charge.
STP, domiciled at Av. Insurgentes Sur 1425, 10th and 12th floors, Insurgentes Mixcoac, Benito Juárez, C.P. 03920, Mexico City, and identified by the trade name "STP", is responsible for collecting and processing your Personal Data in terms of this Privacy Notice.
II. Personal data that will be processed.
For the purposes specified in this Privacy Notice, STP collects directly from its employees, or indirectly through other sources permitted by law, the following Personal Data: full name, date of birth, marital status, sex, nationality, federal taxpayer registry (RFC), unique population registry code (CURP), social security number (IMSS), email, address, home, office and cell phone numbers, official identification, available schedule, last degree of studies, work and academic background, study certificates, curriculum vitae, work performance, information about previous jobs, name, telephone or cell phone number, e-mail, position, place of work of persons from whom personal and work references may be requested, and of persons designated to be contacted in case of emergency, as well as of your spouse, parents and children, information about family members working at STP, current and previous salary, other income, bank details and INFONAVIT credit information.
These data are treated under strict security measures to ensure their confidentiality.
III. Sensitive personal data that will be processed.
As part of the STP team, the company may collect and process sensitive Personal Data, namely: results of various aptitude and psychometric tests, and results of tests that determine your physical, technical, psychological capabilities, and health status.
Such data are treated under strict security measures to ensure their confidentiality and are not transferred to third parties.
IV. Purposes of the treatment.
Your personal data are necessary for the existence, maintenance and fulfillment of your employment relationship with STP, as well as the compliance of the labor, tax, social security and legal obligations arising therefrom, and that is why STP uses them for the purpose of: (i) carry out the labor relationship and identify the Holder, (ii) verify the information that the Holder has provided, (iii) provide training and/or training, (iv) integrate a labor file, (v) perform its registration and/or removal from payroll and before the Mexican Institute of Social Security, (vi) carry out the granting of labor benefits, (vii) assign the tools and work equipment, (viii) grant the Holder access to the facilities and computer systems, (ix) to contact the persons designated to be contacted in case of emergency, and (x) to comply with legal obligations arising from the employment relationship (hereinafter, "Primary Purposes"), however, they may also be used to (i) invite you to work events and (ii) provide objective references about the Holder's work performance (hereinafter, "Secondary Purposes").
V. Mechanism for the Data Subject to express his/her refusal for secondary purposes.
Likewise, through this Privacy Notice, STP guarantees the right of its Employees to express their refusal to the processing of their personal data in relation to the Secondary Purposes for the legal relationship, for which the Employee must inform STP in writing at the latter's address, It is understood that the signature of the same is a sign of the Employee's consent, without prejudice to his/her right to revoke the consent previously granted or to exercise his/her right to oppose the processing of his/her data in terms of the applicable provisions, rights that in any case will be guaranteed by STP.
VI. Exercise of the Rights of Access, Rectification, Cancellation or Opposition (ARCO Rights).
You will be responsible for the accuracy, veracity, authenticity and validity of your Personal Data. In that sense, you have the right to (i) access the Personal Data collected from you, that is, to know what personal data we have about them, what we use them for and the conditions of use we give them, (ii) to rectify your Personal Data, in case they are outdated, inaccurate or incomplete, (iii) to cancel your Personal Data when, in your opinion, they are not being used in accordance with the principles, duties and obligations set forth in the Law, its Regulations and applicable rules, and it is legally appropriate, and (iv) to oppose the processing of such Personal Data for specific purposes; all of the above in terms of the Law, its Regulations and the applicable provisions on the matter.
VII. Revocation of Consent.
At any time, the Employee may inform STP of its determination to revoke the consent previously granted for the processing of Personal Data in accordance with the purposes described in this Privacy Notice, in order for STP to stop using such data, provided that the consent to be revoked is with respect to Personal Data that is not necessary for the existence, maintenance and fulfillment of the legal relationship with STP, that the law allows it or that it has been expressly agreed between
STP and the Employee. In all cases the revocation of consent shall not have retroactive effects. The means and the procedure to make it effective are mentioned below.
VIII. Means and procedure for the exercise of ARCO Rights. A. ARCO Request Requirements.
In terms of the provisions of the Law, any ARCO Rights Request ("ARCO Request") must comply with the following requirements:
Indicate the name of the Data Subject and his/her address, or other means to communicate the response to his/her request.
Accompany the documents that allow to prove its identity, or in its case, the representation of the Personal Data Holder.
Indicate a clear and precise description of the Personal Data with respect to which you seek to exercise any of the ARCO Rights. In the case of rectification of Personal Data, you must indicate the modifications to be made and provide the documents supporting your request; and
Indicate and/or accompany any other element or document that facilitates the location of the Personal Data.
For the submission of ARCO Requests, the Personal Data Subjects and their representatives may submit a free written document providing all the minimum requirements previously indicated.
B. Means of submitting ARCO requests or revoking consent.
In order to make the submission of ARCO Requests simple, Personal Data Subjects may submit such requests in the following ways:
Directly at the STP office identified at the beginning of this Privacy Notice.
The Personal Data Subject must prove his or her identity by means of a copy of his or her identification document and must show the original for comparison. The following identification documents are accepted by STP: INE credential, passport, military service card and professional license.
If a representative attends, he/she must prove: (i) the identity of the Data Subject, (ii) his/her identity as representative, and (iii) the existence of the representation, by means of a public instrument or power of attorney signed before two witnesses, or through the declaration of the Data Subject in personal appearance.
Acknowledgement of receipt of the ARCO Request will be delivered to the Data Subject or his/her representative, indicating the date of receipt.
By e-mail to the address [email protected], as long as it is possible to reliably identify the Holder by means of authentication mechanisms allowed by the legal provisions on the matter, and accepted by STP. The use of advanced electronic signature or the electronic instrument that substitutes it, shall exempt the presentation of the copy of the identification document. Receipt will be acknowledged by e-mail indicating the date of receipt of the ARCO Request.
C. Deadline for attention to ARCO Requests.
The receipt of an ARCO Request does not imply that it is declared admissible by STP. In the event that the information provided in the ARCO Request is insufficient or erroneous to process it, or if the necessary documents to process it are not provided, STP will require the Personal Data Subject or its representative, within 5 business days following the receipt of the ARCO Request, for a single
time, to provide the necessary elements or documents to process it. The Personal Data Holder or its representative will have 10 business days from the day following receipt of the request to respond.
STP will respond to the ARCO Request with the determination reached, within 20 business days from receipt of the request, or if additional information or documents have been requested, within 20 business days from the day following the presentation of the response to the request.
In case the ARCO Request is granted, STP will make effective the determination reached within a period of 15 business days from the date the response is communicated to the Data Subject or his/her representative. In the case of ARCO Requests regarding the right of access to Personal Data, the delivery of such data will be made prior accreditation of the identity of the Data Subject or his/her representative.
STP may extend the deadlines to respond to an ARCO Request, and/or to make effective its reached determination, only once, for periods equal to those indicated in each case, provided that the area in charge of handling Personal Data matters considers that the circumstances of the case justify it. In such cases, STP will notify the Data Subject or his/her representative, the circumstance(s) that justify the extension, within each of the original deadlines to respond or make effective the determination reached.
Responses to ARCO Requests will be delivered to the Personal Data Subject or his/her representative, by the same means by which the request was submitted, either by e-mail, directly at the STP office where the ARCO Request was submitted, or by Mexican postal mail or e-mail in cases where the ARCO Request was submitted by telephone. The requested information or personal data may be made available to the Personal Data Subject or his/her representative, in simple copies or in electronic file depending on the type and quantity of documents involved in each case.
For the revocation of consent, it will be sufficient for the Data Subject to make his/her request by telephone to the Legal Department of STP, or by e-mail to the address [email protected], proving his/her identity in the terms indicated above for this route. STP will give a positive response and will make such request effective, provided that it is not a personal data necessary for the existence, maintenance and fulfillment of its legal relationship with the Data Subject.
IX. Limiting the use or disclosure of your personal information.
When the processing of Personal Data does not refer to those necessary to comply with a legal or contractual obligation (compliance with the legal obligations arising from the legal relationship existing between the Employee and STP), the Employee shall have the right to request STP to limit the use and/or disclosure of his/her Personal Data by means of the request that STP will provide him/her, so that in case it is appropriate STP will register the Employee's personal data in the exclusion lists within a term of 20 (twenty) business days from the submission of the respective request. For further information, please send an e-mail to the following address: [email protected].
X. Cookies and Web Beacons.
STP acknowledges that it is possible that the STP Site or any of the platforms or digital applications used by STP may make use of Cookies or Web beacons in connection with certain features or functions.
For the purposes of this Notice, Cookies are understood as the data file that is stored in the hard disk of a user's computer equipment or electronic communications device when browsing a specific
Internet site, which allows the exchange of status information between such site and the user's browser, and the status information may reveal means of session identification, authentication or user preferences, as well as any other data stored by the browser with respect to the Internet site; and by Web beacons, the visible or hidden image inserted within a website or e-mail, which is used to monitor the user's behavior in these media, and through these it is possible to obtain information such as the IP address of origin, browser used, operating system, time at which the page was accessed, and in the case of e-mail, the association of the above data with the addressee.
Notwithstanding the foregoing, the Employee may deactivate Cookies and Web beacons in his/her browser, delete them or manage their use through the configuration of his/her browser at any time, in the understanding that such actions could cause a deficiency in the performance and/or operation of the STP Site or any of the platforms or digital applications used by the latter to offer its services and/or products, derived from the fact that certain functionalities are only available through the use of Cookies or Web beacons.
XI. Transfer of Personal Data by STP.
STP uses the Personal Data of its Employees exclusively for the purposes indicated in this Privacy Notice and keeps it for the time indicated by the legal provisions. STP only shares and/or transfers the Personal Data of its Employees with third parties (i) with its affiliated companies, being one of these, Servicio de Transmisión de Pagos, S.A. de C.V. or any other that within its shareholding structure, has one or more shareholders in common with STP, for the purpose of complying with the Purpose of Data Processing section of this Notice or to offer them any product and/or services, (ii) for consultation and verification of the data and information provided by the Employee, (iii) when so required by law or by order of a competent authority duly founded and motivated, and (iv) in the cases indicated in article 37 of the Law. Apart from the aforementioned cases, the Employee trusts that his/her Personal Data will not be transferred to third parties without his/her express consent.
In any case, STP guarantees that the purposes of the processing of the Employee's Personal Data will be respected by the third party recipients when any of the aforementioned transfers take place. The third parties receiving the Employee's personal data may be companies engaged in or having a similar line of business to that of STP, financial institutions (national or foreign), and individuals and legal entities that provide services to STP.
The purposes of the aforementioned transfers will pursue (i) compliance with the provisions regarding Personal Data by STP, (ii) the maintenance and/or compliance with the obligations and rights contracted through the contracts entered into with the Employees, (iii) the guarantee of any right derived from the contracts entered into by STP, (iv) protection of the rights of the Employees and (v) advertising and promotion of the financial products and/or services offered by STP or its affiliated companies to the Employees.
In this act, the Employee hereby agrees that STP may carry out the transfers in the aforementioned cases, to the aforementioned third party recipients and for the aforementioned purposes, and therefore, he/she signs this Privacy Notice with full knowledge and consent.
XII. COMMUNICATION OF MODIFICATIONS.
This Privacy Notice may be modified at such time and in such manner as STP may determine, in accordance with the regulations on the protection of personal data that may be issued, STP's own needs by virtue of STP's privacy practices, and therefore, any update, change and/or total or partial modification to this Privacy Notice shall be made known to the Employee directly at STP's domicile, as well as through our website https://stp.mx/, informing of the modification through a pop-up, so that the Employee may be able to exercise his/her ARCO rights.
XIII. INFORMATION ABOUT INAI.
If the Employee considers that his/her right to the protection of his/her Personal Data has been violated by any conduct or omission on the part of STP, or presumes any violation of the provisions of the Law, its Regulations and other applicable regulations, he/she may file a complaint with the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI). For further information, the Employee should visit its official website www.inai.org.mx.
XIV. CONSENTFORTHEPROCESSINGOFSENSITIVEDATA.
I expressly authorize that my sensitive Personal Data, such as the results of different aptitude and psychometric tests, and the results of tests that determine my physical, technical and psychological capabilities, and my state of health, be processed by STP in accordance with the provisions of this Privacy Notice, and for such purpose, I grant my consent, which I acknowledge may be given by physical means, through a handwritten signature, or by using electronic means, through the use of electronic signature, or any authentication mechanism, in terms of the provisions of articles 1803 of the Código Civil Federal and 9 of the Law.
Full Name and Signature:
_____________________________
Date: _______________________
