WEN LIVING - PRIVACY POLICY

In compliance with what is established in the Federal Law for the Protection of Personal Data held by Private Parties published in the Official Gazette of the Federation in July 5th, 2010 and its Regulations (the Regulations), the following Privacy Notice is herein issued.

1.- IDENTITY AND ADDRESS OF THE RESPONSIBLE PARTY
Awen Wellness, S de R.L. de C.V. (The "Company”) represented by its Legal Representative, Edgar Matute Neaves and which is a commercial entity established in compliance with Mexican Law with corporate purpose related to real estate marketing matters, among other activities, and with an office and mailing address at Plaza Pescador, M-1, Colonia Campo de Golf, San Jose del Cabo, Baja California Sur, Mexico and with telephone number (52) 624 152 8770.

2.- INFORMATION
The Company gathers information provided by its, clients, suppliers, service providers, commercial partners, employees, or any third party which may have access to the products and/or services provided by the Company. For purposes of documenting our relationship with each one of them, they provide us willingly and freely, information that is included in contracts, letters, forms, databases or other means, as applicable, for us to keep appropriate record of our relationships and to meet legal requirements, when so mandated. Among such personal data, including sensitive personal data, but not limited to, is included the following:​

INDIVIDUALS
Complete Name (Paternal Surname, Mother Surname and Name (s))Particular Address (Block, exterior Number, and applicable, interior number, Colony, ZIP code, Delegation or Municipality, City or Population and Federative Entity)
Nationality.
Date of birth and place of birth.Marital statusProfession or current Occupation.
Activity of the Business.
Telephone or telephones that refer to their location, when existing.
Email address.
The Unique Key of the Record of Population (CURP).Contributors' Federal Record (RFC).
Personal reference information
Educational information
Union membership information
Current Health and medical information
Training information
Safety and environmental testing information
Income information
Gender
Bank Account Information and salary
Tax ID numbers

ENTITIES
Name or Trade name
Mercantile activity or corporate purpose
Contributors' Federal record (RFC)Address - Street, exterior number, and if applicable, interior number, Colony, ZIP code, Delegation or Municipality, City or Population and Federative Entity
Date of Incorporation
Nationality
Telephone number
E-mail or address of their website, if applicable.
Name and nationality and information of the person who with their signature could force the moral person on having entered into the operation, which may be the administrator or administrators, the director, manager general, legal representative or attorney-in-fact.


Personal Data is gathered in compliance with what is established in applicable law, as well as in compliance with the clauses of the contracts and legal documents entered into with the parties that provide said data voluntarily, also provided by suppliers or any third party related with the Company, which are self-responsible for the protection of personal data that each of them collects in accordance to their own privacy policies.​

3. - CONFIDENTIALITY AND HANDLING OF PERSONAL DATA

Confidentiality: The Personal Data, including the Sensitive Data referred to by the Federal Law for the Protection of Personal Data held by Private Parties, which are provided to us by our employees and third parties with consent, whether physically, electronically or by any other means, are handled and stored in a confidential manner.
Also, through technological means and internal protection procedures, the Company constantly does its best effort to maintain the safety of the Personal Data that is provided to the Company to avoid the unauthorized access to such.
Handling: The Personal Data that is provided to the Company is used to meet legal requirements, to keep appropriate record of personnel and providers of supplies and services, and to coordinate all services provided by and to the Company, including emergencies.
Personal Data is the personal information provided to The Company that could be used for means of publicity, promotion, website administration of The Company, development of new products and services, quality and client satisfaction polls, analysis of use of products, services, and website, for the sending of notices regarding products and services operated by The Company and/or its affiliates, subsidiaries, and/or business partners; when the Law requires it, to request the update of their data and identification documents, and generally to comply with our terms, conditions and operation, functioning and administration of our business.
The Company performs the classification, debugging and / or destruction of the documentation and/or information related to Personal Data, in a reasonable manner in terms of the Law, notwithstanding the foregoing, and considering the vulnerable activity that The Company performs in certain aspects, Personal data (documentation and/or information) must be maintained and safeguarded for a period of 10 years in accordance with the provisions established in the Law for the Prevention and Identification of Transactions involving Resources of Illicit Origin.
When personal data is provided, it should be provided in a precise, complete and updated manner at the time that the gathering occurs, regardless of the fact that The Company may further verify the accuracy of said personal data and that the provider of the personal data  may exercise the right to rectify such Data, as provided chapter 5.- below “Means for the exercise of rights of the Owner of Personal Data” section, in case they detect or identify that the Data that was provided to The Company is inaccurate, incomplete, or not updated.
The Company is not required to have the previous consent of the Owner of the Personal Data for its handling, in the following cases: (i) when The Company acts in direct compliance with applicable law; (ii) the data is in public access sources; (iii) the personal data has been submitted previously to a dissociation procedure; (iv) for the fulfillment of the obligations that, in its case The Company has acquired with the Owner of the Personal Data as a result of a contract entered into with it; (v) there is an emergency situation that may potentially harm an individual or property; (vi) it is indispensable for medical attention, prevention, diagnostic, lending of sanitary aid, as long as the owner is in no condition of granting consent in terms of what is established in the General Health Law and other applicable legal instruments and that said handling of data is made by an individual subject to professional secrecy or an equivalent obligation; or (vii) by resolution of competent authority.
The Company may transfer the Personal Data, including sensitive personal data throughout its related entities, for administrative purposes. Appropriate use will be made, and special care will be taken when such Personal Data is transmitted or used by a related entity and be treated under the principles of legality, consent information, quality, purpose, loyalty and responsibility in accordance with the Law.
It is emphasized that The Company’s technology service providers are self-responsible to carry out technology reviews, from time to time, to the data bases, for their protection, such as, debugging them, as well as implementing the necessary technological protection measures to avoid adulteration, loss, consultation, use or unauthorized access of the Personal Data either physically or by any electronic means as the Informatics Industry demands.

4.- LIMITATIONS OF USE AND DIVULGING OF DATA
The Personal Data that is provided to us through legal or legitimate means is handled in an appropriate and confidential manner. Regardless of the foregoing, the Personal Data will be employed and divulged for and with the purpose of fulfilling the objectives established in the “Handling” section of this Notice as well as for statistical means, dissociated and for the improvement of our products, services, operation, activities, and even regarding the update of the contents published on our website.
Personal Data will be transferrable to third parties to (a) fulfill existing legal obligations; (b) comply with a legal or judicial ruling; and (c) as long as it is necessary for the operation and functioning of the Company. In case of transfer of the Personal Data, this will occur through means and legal instruments that provide an adequate protection level and security measures for said data.
The Company will adopt necessary and reasonable measures to cancel the identification of the Personal Data that is provided to it, when these are no longer necessary for the purposes referred to in this Notice and/or when there is no legal obligation for the Company to keep them or by reason of another rules or regulation that obliges “the Company” to keep them.

5.- MEANS TO EXERCISE RIGHTS OF THE OWNER OF THE PERSONAL DATA.
The owner of the personal information may request to the responsible party of the Company at any time to access, rectify, cancel or correct his/her/its Personal Data (ARCO DATA- Access, Rectification, Cancellation or Opposition Data Personal). For such end, the owner of Personal Data shall direct a written request to the Responsible Party, which shall at least contain the following information:
a) Name of the owner and address or other means to communicate the answer of his/her/its request.b) The documents that evidence the identity, or, if applicable, the legal representation of the ownerc) The clear and precise description of the Personal Data regarding those on whom the exercise of rights is intended.d) Any other element or document that may facilitate the location of the Personal Data, as well as any other document required by the current laws at the time of the filing of the request.
The Owner of the Personal Data has the right to request to the responsible party by via e-mail the changes or modifications that he/she requires at privacy@weniving.com or to the address indicated in Item 1 above.

6.- REVOCATION
The Owner of the Personal Data may revoke the current consent for the handling of personal information at any time. To such end, he/she/it shall file a request via e-mail at privacy@wenliving.com or to the address indicated in Item 1 above.  Such communication shall comply with the applicable request requirements mentioned in the previous section.

7.- MODIFICATIONS TO THE PRIVACY NOTICE
The Company reserves the right to modify this privacy notice, in which case it will communicate such through notice placed in a visible location in the Company’s facilities at its address mentioned above, or through written notice to employees or others.

8.- ENFORCEMENT OF THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (GDPR). 
The Company is responsible and makes its better efforts regarding the use of Personal Data; as it get them, how they are protected; and the term does it keep them, in respect of individuals or entities who are part of the European Economic Community, where applicable, Article  3 subsection V of The Law and articles 4, 5, Third Section   of its Regulations, as well as Article 3.2 and other applicable provisions of the GDPR and other law as well as the Convention for the Protection of Persons with respect to the Automated Processing of Personal Data and its Additional Protocol concerning Control Authorities and Cross-Border Data Flows published on 12 June 2018.

 9.- CONSULTATIONS

For any doubts, comments or consultations regarding this Notice, you may file an inquiry to the address indicated in Item 1 above.
a) Any complaints or information regarding the processing of your personal data or questions regarding the Federal Law on Protection of Personal Data Held by Private or its Regulations, may be conducted at IFAI. For more information visit www.ifai.org.mx. and/or IFAI PRODATOS
b) Governing Law: The interpretation and application of this Privacy Notice is governed by the Federal Law on Protection of Personal Data in Possession of Individuals, the Federal Civil Code and other laws and regulations and administrative provisions that are applicable.
Consent: The Owner of Persona Data, expressly have read the content of this Privacy Notice and have no opposition to it.
April 22, 2021