PRIVACY NOTICE

Last updated: August 2017.

VICASOEN, S.A.P.I. DE C.V. (Hereinafter referred to as " Cultura Colectiva" or "us"), with address at Calle Durango #169, 3rd. floor, Col. Roma Norte, Del. Cuauhtémoc, C.P. 06700, Mexico City, is the data controller responsible for the processing of your personal data, which is collected through the website www.culturacolectiva.com (the "Website") and as described hereunder.

In Cultura Colectiva we understand the importance of protecting the privacy of our Users, with whom we interact day by day ("data subjects", "subjects", "users" or "you"). This Privacy Notice contains important information for the Users of our Website and explains how we obtain, use and share your personal data and the rights you have regarding your personal data. In Cultura Colectiva, we are committed to processing your personal data in accordance with the principles of lawfulness, quality, consent, information, purpose, loyalty, proportionality and responsibility established in the Federal Law on the Protection of Personal Data held by Private Parties (the "Law").

PERSONAL DATA

The personal data that can be collected and processed by Cultura Colectiva is:

a. Identification data: Information that allows us to differentiate you from other individuals, specifically: name, age and gender.

b. Contact information: Information that allows us to keep in touch with you, in particular, your email address.

c. Electronic Records: This refers to certain information that is obtained when you access our Website and includes: data that is obtained through cookies on our Website, such as your IP address, user preferences, type of browser, activity on the site, and pages previously visited.

Please note that Cultura Colectiva does not collect sensitive personal data.

MEANS THROUGH WHICH WE COLLECT YOUR PERSONAL DATA

We collect your data directly from you, when you provide it through our Website, namely, when you complete our form to sign up for our "Newsletter".

USE OF YOUR PERSONAL DATA

Your personal data will be used to send you the "Newsletter", information of interest about our services or products and keep in contact with you.

OBTAINING DATA THROUGH COOKIES AND OTHER TECHNOLOGIES

Be informed that our Website uses cookies and/or similar technologies. A cookie is a data file that is stored on the hard drive of your computer or the electronic communications device that you use when navigating on our website, which allows you to exchange status information between our Website and your browser. The status information may reveal session identification means, authentication or user preferences, as well as any data stored by the browser regarding the Internet Site. The data obtained by this means allows us to offer you a better service through our Website. Most web browsers allow you to manage your cookie preferences. To block cookies, you can adjust your browser to reject cookies or delete certain cookies. In general, you should also be able to manage similar technologies in the same way you manage cookies - using your browser preferences.

Cultura Colectiva works with Google Analytics, DoubleClick and other service providers that use technology to help us deliver our own content, deliver targeted advertising, and obtain anonymous or dissociated metrics and site analysis. In the contracts we execute with service providers, we ask that these companies use the information they obtain only to provide the services we require. While these companies use some anonymous information about you to display ads, we contractually prohibit them from obtaining personal information about you. You have the option to request to be disqualified from Google Analytics for display advertising and to customize Google Display Network ads here.

TRANSFERS OF PERSONAL DATA

Cultura Colectiva informs you that your personal data may be shared inside or outside the country with the following:

• Transfers of personal data to our affiliates. Since Cultura Colectiva is part of an international group, your personal data may be transferred to other companies within the group, which may be in another country, in order to fulfill the purposes described herein.

• Transfers of personal data to third partie. . Your personal data may be communicated or transferred to a third party when we have your consent or when your consent is not necessary in terms of article 37 of the Law. You specifically agree that your data may be transferred to third parties in the following cases: (i) when Cultura Colectiva must transfer the data to competent authorities, in charge of the administration of justice, when asked by such authorities to do so; (ii) where the data requires to be transferred to a third party in the context of a corporate transaction (including, among others, mergers and acquisitions).

EXERCISE OF ARCO RIGHTS AND REVOCATION OF CONSENT

You have the right to request Cultura Colectiva access to your personal data, to rectify it when it is inaccurate or outdated; request that it is canceled, when it is no longer necessary for the purpose for which you provided it; object to the processing for specific purposes (known as "ARCO Rights") and/or revoke the consent you previously granted to us for processing it. Please consider that your ARCO Rights are subject to the limitations established by applicable laws and that in some cases your application may not be appropriate. In order to exercise these rights or ask any questions or complaints regarding the processing of your personal data, please contact our Personal Data Department ("DDP"). Please direct your request to: [email protected], in attention to the "Department of Personal Data". Your requests will be evaluated in the terms established in the Law. For access, rectification, cancellation and objection requests it will be necessary to provide the following information: (i) name of the data subject and address or other means to communicate the response to the request; (ii) documents proving the identity or, where applicable, legal representation of the data subject; (iii) a clear and precise description of the personal data in respect of which one wishes to exercise any of the rights, and (iv) any other element or document that facilitates the location of the personal data. Our obligation to give access to the personal data shall be deemed fulfilled when the personal data is made available to the data subject or when issuing copies or electronic documents, whichever is easier.

OPTIONS AND MEANS TO LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL DATA

In general, when we collect personal data from you for a purpose that we believe is not necessary or essential in the context of our relationship, we will make available a mechanism that allows you to express your refusal to process your data for that purpose. If you want to know other options that are available for you to limit the use or disclosure of your personal data, please send us an email to [email protected].

SECURITY MEASURES

Cultura Colectiva has implemented and maintains administrative, physical, and technical security measures to protect your personal data from damage, loss, alteration, destruction or unauthorized use, access or processing.

MODIFICATIONS TO THIS PRIVACY NOTICE

Cultura Colectiva reserves the right to modify or update this Privacy Notice at any time, in which case an updated privacy notice will be posted on our Website, or the modified version will be sent to you via email or other means of communication we may have with you. The publication of our Privacy Notice will note the date in which it was last updated. If you do not agree with the modifications made to the Privacy Notice, please contact us at [email protected] and refrain from using our Website. The continued use of our Website represents your consent and agreement with the current Privacy Notice. Cultura Colectiva invites you to periodically review its Privacy Notice.

Note: This Privacy Notice is provided for the convenience of our English-speaking users. If there are doubts or concerns regarding any term or clause included herein, the Spanish version shall prevail.