HiTO, S.A.P.I. de C.V., better known as HiTO, with address at ‘Jaime Balmes 8 oficina 104, Colonia Los Morales Polanco, Alcaldía Miguel Hidalgo, Ciudad de México, México, C.P. 11510’, and website www.hito.com.mx, is responsible for the use and protection of your Personal Data, and in this regard, we provide the following information:

PERSONAL DATA PURPOSE

I. PRIMARY PURPOSES

HiTO uses Personal Data exclusively in the execution of its corporate purpose. The Personal Data that HiTO collects will be used within the framework of the applicable laws, as well as the corporate purpose of the company, among which are: the provision of technological systems services, consulting, administration, marketing and other related services, to strengthen and optimize the origination and management of mortgage loans, and to promote the development of its Securitization, Primary Servicing and Master Servicing Operations.

Additionally, Personal Data provided by its Holder will be used by HiTO to: (i) provide services related to HiTO's function, (ii) inform about new products or services, strictly related to the product or service contracted with HiTO, (iii) comply with obligations contracted with our clients, (iv) confirm their identity, (v) understand and attend their commercial needs (vi) elaborate legal instruments in accordance with HiTO's purpose and activities (vii) comply with applicable legal requirements (viii) verify the information provided (ix) keep a record of the contractual relationship to follow up on contracted services and future contracts (x) inform about changes in HiTO's products or services.

Your Personal Data will be treated based on the principles of legality, consent, information, quality, purpose, loyalty, proportionality, and responsibility in terms of the current legislation.

II. SECONDARY PURPOSES

HiTO may use your personal data to inform you about new products or services, send offer notifications, notices and/or promotional messages; commercial communications, quality assessment of the services currently being offered and, in general, for any activity aimed at promoting, maintaining, improving, and evaluating its products and services.

III. MEANS BY WHICH HITO MAY COLLECT DATA FROM ITS HOLDERS:

HiTO, striving for the welfare of our customers and the best protection of their Personal Data, informs Data Holders the means by which we may collect their Personal Data, which may be done in the following ways: a) provided to us directly; b) visiting our websites, c) using our online services, d) obtaining information through other sources that are permitted by law; and e) when it is provided by the Responsible and/or Person in Charge of the data provided for the provision of a service, in the understanding that HiTO will use it exclusively in its capacity as Service Provider, Primary Servicer, Structuring or Master Servicer within the services provided by HiTO, as Client or as Service Provider, for which it will assume the corresponding obligations in terms of the Law of the matter.

IV. PERSONAL DATA THAT HITO MAY REQUIRE FROM ITS HOLDER

In order to carry out the purposes described in this privacy notice, we will use the following types of Personal Data:

• Identification and contact
• Labor
• Financial
• Migratory

We may also ask you for sensitive personal data in case it is necessary to be able to provide you with the services you request. We commit, if applicable, that such data will be treated under the strictest security measures to guarantee its confidentiality.

V. TRANSFERS

HiTO will not transfer Personal Data to third parties without your consent, except for the exceptions foreseen in article 37 of the Law, as well as the terms established by the Federal Law for the Protection of Personal Data in Possession of Private Parties.

En cualquier caso, ya sea que la transferencia sea nacional o internacional, HITO se asegurará de entregar al receptor el presente aviso de privacidad y de que éste asuma, por lo menos, las mismas obligaciones a las que nosotros nos encontramos sujetos. Esto, mediante cláusulas contractuales u otros instrumentos jurídicos celebrados entre HITO y los receptores de los datos.

Le informamos que para las transferencias requerimos obtener su consentimiento. Si usted no manifiesta su oposición para dichas transferencias, entenderemos que nos lo ha otorgado.

VI. OPPOSITION

The holder has the right to object to the use of their personal data for the purposes contained in this Comprehensive Privacy Notice. In case the holder wishes to do so, they must exercise their ARCO rights in accordance with the procedure described in section VII herein; within 5 working days, following the date in which this Privacy Notice has been made available to them by reading it on the website www.hito.com.mx in order to prevent their personal data from being processed for the purposes described.

Otherwise, it will be understood that the holder consents to the processing of his personal data for all the purposes listed above, perceiving that the above is without prejudice to the provisions of Article 26 of the Law and other applicable provisions.

VII. EXERCISE ARCO RIGHTS

You have the right to know what personal data we have collected from you, what we use it for and the terms and conditions of its use (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate, or incomplete (Rectification); that we remove it from our records or databases when you consider that it is not being used properly (Cancellation); as well as to oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

To exercise any of the ARCO rights, you must submit the respective request through the following means:

a) Physical request submitted at our domicile and addressed to the attention of HiTO's Legal Department, accompanied by the following documentation:

1. Client's and/or legal representative's identification data. In the case of the legal representative, they must carry a document that proves their identity.
2. A clear and precise description of the personal data with respect to which you seek to exercise your ARCO rights, as well as the right or rights you wish to exercise. Your request must be signed at the end of the document and must have your initials at the bottom of each page.
3. Address to hear and receive HiTO's reply and, if applicable, future communications and/or notifications, or your request for our reply and/or future notifications or replies to be sent by e-mail, providing the respective e-mail address.
4. A copy of the client’s and/or its legal representative’s valid official identification.

b) Request via e-mail, sending the notification to the e-mail address [email protected], along with the following information and documentation:

1. Client's and/or its legal representative's identification data. In the case of the legal representative, they must include the document that proves their identity. The documents may be scanned and attached to the e-mail to verify their veracity.
2. A clear and precise description of the personal data that you seek to exercise your ARCO rights, as well as the right or rights you wish to exercise, which may be expressed in the text of your email or in an attached scanned document, properly signed at the end of the letter and must have your initials at the bottom of each of the pages.
3. Explicitly specify the desire to receive HiTO's reply to your request by e-mail, indicating the corresponding e-mail address.
4. Copy of the client's and/or legal representative's valid official identification. The documents may be scanned and attached to the email to verify their veracity.

Once the request to exercise your ARCO Rights are at HiTO's disposal, regardless of whether it is received by e-mail or delivered to our offices, we will issue the respective reply within 20 business days of receipt. We will inform the data holder through the chosen means of contact.

Once HiTO's reply is received, the Holder will have a period of 20 business days to issue its reply, in the event that the customer is dissatisfied, they may contact HiTO immediately through the means indicated; HiTO being at their disposal to address any concerns. In case of not responding to HiTO's answer within the indicated term, HiTO will understand in good faith that the Holder agrees with the answer.

If the request to exercise the ARCO Rights is about the exercise of access, HiTO will make the information or personal data available to the Holder through simple copies and/or electronic documents.

HiTO may deny the exercise of ARCO Rights by the clients, in the cases allowed by the Law and its Regulations, so it must inform the clients the reason for such decision. The refusal may be partial, in which case HiTO will carry out the access, rectification, cancellation or opposition in the applicable part.

VIII. REVOCATION OF CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA

You may, at any time revoke your consent to the processing of your personal data. However, it is important to note that we will not be able to meet your request or terminate the use immediately for all cases, since it is possible that for some legal obligation, we may need to continue processing your personal data.

This request can be processed according to the procedure provided in the previous section (numeral Vll), that is, through a letter addressed to the Legal Department of HiTO, submitted directly to our offices or by sending such request to the email address [email protected], once it is received by HiTO, we will issue a reply within 10 business days., once it is received by HiTO, we will issue a reply within 10 business days.

IX. OPTIONS TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL DATA

You, as the Personal Data Holder, may limit the use or disclosure of your personal data according to the procedure provided in the previous section (numeral Vll), that is, through a letter addressed to HiTO's Legal Department, submitted to our offices or by sending a request to the e-mail address [email protected], once it is received by HiTO, we will issue a reply within 10 business days., once it is received by HiTO, we will issue a reply within 10 business days.

X. CHANGES TO THE PRIVACY NOTICE

This privacy notice may be modified, changed, or updated due to new legal requirements; our own needs for products or services we offer; our privacy practices; changes in our business model, or for other reasons.

We are committed to keep you informed about the changes that this privacy notice may undergo, through the internet portal www.hito.com.mx, where we will publish the updated privacy notice, which will contain the date of the most recent version of the document.

XI. USE OF COOKIES, WEB BEACONS AND OTHER SIMILAR TECHNOLOGIES

We inform you that on our website www.hito.com.mx, we use cookies, web beacons or other technologies, through which it is possible to monitor your behavior as an Internet user on our website, as well as to provide you with a better service and experience when browsing our website; but we do NOT collect personal data through said cookies or beacons.

XII. SAFETY MEASURES IMPLEMENTED AT HITO FOR THE PROTECTION OF PERSONAL DATA

For the protection of your Personal Data, HiTO maintains security measures of an administrative, physical, and technological nature as required by law and other applicable provisions, in order to prevent loss, misuse or alteration of your information.

Fecha de última actualización:

23 de abril de 2024.