PRIVACY POLICY FOR THE CMR.WS WEBSITE
In effect since September 28, 2011.
Information from the Manager
Since its customers are the top priority, CMR is most concerned with the personal information provided by them via the CMR.WS website or the websites of its affiliates or subsidiaries (hereinafter jointly referred to as the “Websites†or “Websiteâ€), or via any of the other means by which CMR obtains personal information. CMR is strongly committed to protecting your privacy and complying with all the pertinent rules for the protection and privacy of your information. This Privacy Policy (hereinafter, the “Policyâ€) explains how we process your personal information. Throughout this policy, the terms “personal dataâ€, “data†and “personal information†refer to any information concerning an identified or identifiable individual. The term “CMR†refers to CMR, S.A.B. de C.V., including its affiliates and subsidiaries (“weâ€, “our†and other similar terms also refer CMR). If you have been linked to this Policy through another website, that means that the site through which you entered belongs to an affiliate, subsidiary or company in the same group as CMR, and therefore this Policy for handling personal information applies.
We can provide additional privacy information as regards specific personal data used in our services, through other related policies, statements or links. The terms of such related policies, statements or links take precedence over this Policy should a conflict arise.
In view of the above and in accordance with articles 8, 15, 16, 33, 36 and others related to the Federal Law for the Protection of Personal Data in the Possession of Private Parties (also referred to in this Policy as the “Lawâ€) and its Regulation, we inform you that CMR is responsible for the protection of personal data that you provide us, and thus we have implemented the necessary security measures to keep your personal information confidential and secure from any attempt at infringement at all times.
In addition, we inform you that our legal domicile is located at:
Havre No. 30, Colonia Juárez
Delegación Cuauhtémoc
C.P. 06600, México, Distrito Federal
In using this Website or that of any of CMR’s affiliates or subsidiaries or on sending any type of personal data to CMR, you accept the processing of your personal data as it is explained in this Policy. Should you not accept this Policy, please do not provide your personal data nor use this or any other Website related to CMR, as the same rules apply to all of them; nor should you provide your personal data to CMR or any of its subsidiaries or affiliates.
Sites Included in This Privacy Policy: CMR is a Mexican company, which  legal entities, commercial procedures, administrative structures and technical systems applied in Mexico. This Policy applies to all the websites owned by CMR, as well as those belonging to the affiliates and subsidiaries under CMR’s full ownership, unless a CMR website has a specific privacy statement referring to a particular program or service, in which case that specific privacy statement would apply instead of this one.
Policy.
Purpose of the Privacy Policy: It is important you know that the Federal Law for  Protection of Personal Data in the Possession of Private Parties and its Regulation safeguards your personal information from non-authorized uses without your consent.
The document herein is thus meant to inform you of what data we collect from you, for what and how we use it, possible transfers to third parties, purposes of the handling of your information and your ARCO rights (to be defined below), and also covers withholding permission to use your data, which you may implement  CMR to have full control and discretion over your personal information. We therefore recommend that you read the following information carefully:
This Policy has been made available to you so that you, as owner of the provided personal information, are aware of how it is handled, as well as the information needed to exercise your rights of access, correction, cancellation and objection (hereinafter “ARCO rightsâ€) and to withhold permission to handle your  Your rights are described as follows:
ARCO (acronym of terms in Spanish):
Access: Right to access any of your personal data in CMR’s possession, except in  cases mentioned in the Law.
Correction: Right to correct your personal information if imprecise or incomplete.
Cancellation: Right to cancel your personal data at any time, except in those cases mentioned in the Law.
Objection: Right to object to the specific handling of your personal information at any time and with legitimate cause.
Revocation: Right at any time to withhold consent to specific handling of your data. This Policy is applicable to owners of personal data, whether obtained directly, indirectly or personally by CMR via reservation processes, contracts for services, requests for information or recruitment processes, as well as by completion of  different forms available on its website, or any other relevant means, that make reference to this Policy.
Ways of Obtaining Your Information: CMR obtains, stores and handles your personal information in accordance with current or future legal relations that it has with you, as well as through the various activities related to CMR services and those of its affiliates and subsidiaries. CMR may obtain your personal data when you send a physical form to one of our employees or authorized agents, when you or your legal representative transmits it to us via either technological means or correspondences designed for that purpose, or indirectly via public or third-party databases.
The Information That We Collect
The personal information that CMR obtains directly, indirectly or personally from  users, customers, associates, managers, suppliers, candidates and/or any person involved in the services that we offer, may be classified in the following ways:
1. Identification: Landline telephone number, cellular phone number, email address, ID number, home address, date of birth, gender, Mexican Federal Tax ID Number (RFC), Mexican Population Registration Code (CURP) and service password.
2. Work-related: position, section or department, occupation, work address, work email, work landline number, work cellular phone number, references, past and present performance and activities.
3. Academic: Details of bachelor’s, master’s and doctoral degrees, diploma courses, educational institutions, majors, starting and ending dates of studies, status of studies,computer knowledge and language skills.
4. Assets and finances: bank card number and bank account IDs.
5. Sensitive: past or present health.
Sensitive data
CMR does not request sensitive personal data (as it is defined in the Law) on its Websites. In cases where personal data of a sensitive nature is collected by CMR-authorized personnel, prior written permission by the owner is requested.
Protection
CMR has implemented technological solutions to protect the personal data that we handle. However, and despite employing ever more secure tools, protection of private information sent over the Internet can not be 100% guaranteed, so that once it is received, we do everything possible to safeguard the data. To ensure that the personal data is handled in accordance with what has been established in the Law and its Regulation, CMR adheres to the following principles:
1.- The purpose for handling your personal information is communicated, and only the data that is needed to accomplish such purposes is collected, while your data will not be used for purposes other than those set forth in this Policy.
2.- You will be provided with sufficient tools to verify that your personal information is correct and kept up-to-date. If for reasons related to compliance with a contractual relationship we must keep your data, they will be stored in accordance with what has been established in this Policy, applicable Law and its Regulation.
3.- Security measures have been implemented to guarantee the protection of your personal data. Uses We Make of Your Personal Information: The information collected by CMR or its affiliates and subsidiaries to better understand your needs and interests helps us to provide a more personalized and coherent experience. For example, CMR may use your information to:
• Help you to complete a transaction or order;
• Prevent or detect security threats, fraudulent conduct or other malicious activities;
• Communicate with you about our products and services;
• Update you on our services and features;
• Provide personalized promotional offers;
• Select content to be communicated to you;
• Evaluate the performance of marketing initiatives, advertisements and Websites
managed by CMR or other companies for CMR;
• Allow you to participate in contests and surveys; and
• Contact you regarding CMR services.
In addition, CMR handles your personal information for the following purposes:
1. For the initiation, performance, maintenance, negotiation and termination of legal relations between CMR and yourself;
2. For the operation, management, electronic billing, payment, administration, provision, expansion and improvement of our services;
3. To grant access to the Websites;
4. To send notifications, letters or bulletins or respond to your requests regarding the services we provide;
5. To help you make a reservation or sign up for promotions that have been offered or
are offered on the Websites;
6. To transfer your personal information in applicable cases, according to the “With
Whom We May Share Your Information†section of this Policy;
7. To prevent unlawful acts or report them to the authorities;
8. To send advertisements and existing or new promotional offers via email marketing, as well as print or phone advertising, in a personalized manner or for market research by CMR, its subsidiaries, affiliates or third parties. At the end of this Policy you may indicate your acceptance of such purposes;
9. For maintaining labor relations, payroll, staff health campaigns and compliance with applicable social security regulations, activities to improve the work environment, as well as for contracting such insurance and/or services on behalf of CMR employees, upon their request;
10. To comply with the exercise of your ARCO Rights, as well as to revoke permission to handle your data;
11. To comply with contractual relations with CMR or its affiliates and subsidiaries, in which your data may solely and exclusively be handled for the express purpose of this relationship, whether client or supplier, in the manner and terms established in this section for use of personal information.
With Whom We May Share Your Information: To properly render its services and comply with the Federal Law for the Protection of Personal Data in the Possession of Private Parties and its Regulation, CMR may send and/or transfer your personal information, partially or completely, to its subsidiaries, affiliates, companies in the same group, managers, or domestic or foreign third parties to achieve one or more of the purposes indicated in this document, in the following cases:
1. To persons affiliated with and/or linked to CMR for fiscal, administrative or labor verification, revision or certification;
2. To the Servicio de Administración Tributaria (Mexican internal revenue service) and electronic billing service companies in accordance with the processes of issuance and transmission of Digital Fiscal Receipts by Internet;
3. To affiliated or non-affiliated companies that assist, support or collaborate with CMR in effectively providing its services, email transmission of information related to our services and offers, negotiationsor to provide services to third parties;
4. To staff charged with protecting and defending the interests of yourself, CMR and/or third parties;
5. To staff charged with contracting all types of insurance and/or services on behalf of CMR employees, upon their request;
6. To staff charged with protecting the security and/or or interests of yourself, CMR personnel and affiliates, their clients and suppliers, and the general public;
7. To various authorities in order to carry out requirements or record them in certain kinds of legislation or regulation;
8. In addition, your personal information may be sent to CMR managers to accomplish certain tasks related to handling your personal data, to comply with a legal or labor relations matter, as the case may be, and if necessary, to carry out activities based on our legal relationship with you. In all such cases, it is understood that your personal data is handled solely according to CMR instructions and this Policy, with prior commitment by the recipients of the data to protect the confidentiality of the personal data sent and safeguard it using the same security measures established by CMR.
9. Personal data will be withdrawn once legal relations have been complied with, as instructed by CMR or as a result of the application of your ARCO rights, and the manager must withdraw such personal data except when its preservation is required by applicable laws.
10. Managers cannot transfer personal data that has been sent to them except when necessary to comply with their contractual relations with CMR or for purposes specified in this Policy.
11. When personal information is transferred to third parties and changes are made in authorized purposes, you may review such changes as established in the UPDATES AND/OR MODIFICATIONS section of this Policy.
Use of Tools for Automatic Data Collection: Cookies are text files that are automatically downloaded and stored on the hard disk of a user’s computer when browsing a specific web page. They allow the Internet server to remember certain data for that user, among them his or her purchasing preferences, name and password, for the visualization of the pages on that server. Web bugs are images inserted on a web page or email that can be used to monitor a visitor’s behavior, storing such details as the user’s IP address, length of interaction with the page and type of browser used, among others. We use cookies and web bugs to obtain personal information about you, such as:
The type of browser and operating system you use; the web pages you visit before and after entering the Websites of CMR and its affiliates and subsidiaries; the links you follow and the time you spend on our site; your IP address; the place from which you visit us and browsing statistics. Such cookies and other technologies can be deactivated. You can search for information on recognized browsers and check how to adjust cookie preferences at the following Web sites:
Microsoft Internet Explorer: http://www.microsoft.com/info/cookies.htm
Mozilla Firefox:
http://www.mozilla.org/projects/security/pki/psm/help_21/using_priv_help.html
In cases where cookies are used, the “help†button found on the toolbar of most browsers tells you how to decline new cookies, how to set the browser to notify you when it receives new cookies or how to deactivate all cookies.
Privacy for Minors
Given that CMR does not intentionally collect information from minors, parents and teachers are urged to perform their registration activities on Websites.
Limits on Use and Distribution of Information: In our email notification program for promotions, special offers and services, CMR, its subsidiaries and managers have access to the information gathered. This type of advertising is carried out through email promotional announcements and messages sent solely to you and those contacts that are signed up for that purpose. You may modify such authorization at any time.
Liability Exclusion
Our Website may contain links, hyperlinks or hypertext links, banners, buttons and/ or Internet search tools, which upon use take Users to other portals or Websites that could belong to third parties. CMR has no control over such sites nor is it liable for their privacy policies. Neither CMR nor its affiliates or subsidiaries can be held liable for the personal data that users provide via such portals or different websites, thus the Privacy Policy of each site should be reviewed before entering it. In addition, we may enable social media functions on our Website that permit the sharing of information from the Website on such networks and interact with CMR on several similar sites. The use of such functions could result in the collection or sharing of information about you, depending on each specific function. We recommend that you review the configuration and privacy policies for social media sites with which they interact to ensure you understand what information can be shared on such sites.
Exercise of ARCO Rights
CMR ensures that the principles for personal data protection are observed at all times. Therefore, you, as the owner of that personal information, or a duly accredited legal representative, may limit the use or release of your personal data and withhold permission for its handling. For questions or clarifications regarding the use of such personal data, we have implemented a suggestions and complaints line regarding our use of the personal information that we collect, at the following Mexico City phone
number: (55) 5263 6951.
Similarly, you can exercise your rights of access, correction, cancellation or objection that the Law stipulates by emailing a request to privacidadinfo@cmr.mx or visiting our offices, where any question regarding the contents of this Policy will be addressed and/or resolved. To facilitate your request, we provide the following form letter for exercising your ARCO Rights.
(Place and date)
CMR, S.A.B. DE C.V. (CMR)
Havre No. 30
Col. Juárez, Del. Cuauhtémoc
06600 México, Distrito Federal
Attention: Department of Personal Data (Legal)
Reference: Request to exercise rights regarding personal data
Dear Sirs:
I hereby request: _______ (brief, clear and precise description of personal data about which you wish to exercise a right, as well as the right you wish to exercise), for which I verify my identity with ______ (indicate the official document used as proof of identity). The abovementioned is in compliance with your company’s privacy policy. Sincerely, Name and signature of data owner or of his or her legal representative (for security reasons, the corresponding identifying document and the document proving the representative’s faculties may be requested).†Updates and/or modifications Any modification or update to this Policy will be published on the CMR.WS Website so that, if deemed necessary, you may address your objection in light of any new guidelines for processing your personal information.
Acceptance of Terms
This Policy is subject to the terms and conditions of all CMR Websites and those of its affiliates and/or subsidiaries, and is thus a legal agreement between you and CMR. Your use of the services on any of the Websites of CMR, its affiliates, and/or subsidiaries implies that you have read, understood and agreed to the terms  in this Policy or respective policyIf you do not agree with these terms, you should not provide any personal information nor use the services of the CMR Website or those of its affiliates or subsidiaries.
If you accept having read this Policy and express no objection to having your personal data handled or transferred, it is understood that you have granted your permission to do so.
Este Aviso está sujeto a los términos y condiciones de todos los sitios Web de CMR y de sus sociedades afiliadas y/o subsidiarias, lo cual constituye un acuerdo legal entre el Usted y CMR.
Si Usted utiliza los servicios en cualquiera de los sitios de CMR, sus afiliadas y/o subsidiarias, significa que ha leÃdo, entendido y acordado los términos contenidos en el presente Aviso o en el aviso respectivo. Si no está de acuerdo con los mismos, Usted no deberá proporcionar información personal alguna, ni utilizar los servicios de los sitios Web de CMR o de sus sociedades afiliadas o subsidiarias.
Si Usted acepta haber leÃdo el presente Aviso y no manifiesta su oposición para que sus datos personales sean tratados o transferidos, se entenderá que ha otorgado su consentimiento  ello.
Fecha de última actualización: 17 de abril de 2012.
