Privacy Notice

1. Identity and address of the data controller

The party responsible for processing personal data is ADJUAN, S.A. de C.V., with its address at Médanos 169, Las Águilas, Álvaro Obregón, Postal Code 01710, Mexico City, Mexico. For privacy matters, contact us at: soporte@primepass.mx

2. Personal data collected

To use the Application, Prime Pass may collect the following categories of personal data:

• Identification data: name, email address and phone number.
• Account data: username, identifiers within the Application and usage history within the platform.
• Technical data: IP address, device type, operating system and browsing information within the Application.
• Subscription-related data: information about purchased subscriptions and payment history within the Application.

Prime Pass does not collect sensitive personal data for the ordinary operation of the Application.

3. Purposes of processing

The personal data collected will be used for the following primary purposes, which are necessary to provide the service:

• Creating and managing user accounts.
• Providing access to the Application.
• Managing subscriptions and payments.
• Validating promotions within the platform.
• Providing technical support and customer service.
• Improving how the Application works.
• Complying with applicable legal obligations.

4. Secondary purposes

In addition, personal data may be used to:

• Send informational or promotional communications.
• Perform statistical analysis on the use of the Application.
• Improve services, features or user experiences.

The data subject may refuse consent for these secondary purposes by sending a request to soporte@primepass.mx.

5. Transfers of personal data

Prime Pass may transfer personal data to third parties only when necessary to:

• Process payments through payment service providers.
• Enable the technical operation of the Application through technology providers.
• Comply with legal obligations or requests from competent authorities.

Where required by applicable law, such transfers will be made with the prior consent of the data subject. Prime Pass does not sell or trade users’ personal data.

6. ARCO rights

The data subject has the right to exercise, at any time, the rights of Access, Rectification, Cancellation and Opposition (ARCO). To exercise them, send a request to soporte@primepass.mx with the following information:

• Name of the data subject.
• Contact method for sending the response.
• Documents proving their identity or legal representation.
• A clear description of the right they wish to exercise.
• Any information that helps locate the data.

Prime Pass will respond to the request within the time limits set by applicable law.

7. Withdrawal of consent

The data subject may withdraw the consent given for the processing of their personal data at any time by sending a request to soporte@primepass.mx. Withdrawal will not have retroactive effect and may mean that certain features of the Application can no longer be used.

8. Limiting the use or disclosure of personal data

The data subject may request that the use or disclosure of their personal data be limited by sending a request to the email address listed in this Privacy Notice. Prime Pass will review each request in accordance with applicable law.

9. Use of tracking technologies

The Application may use technologies such as cookies, device identifiers and analytics tools to:

• Improve the user experience.
• Analyze use of the Application.
• Optimize how it works.

Users can configure their device to limit the use of these technologies.

10. Security of personal data

Prime Pass adopts reasonable administrative, technical and physical measures to protect personal data against loss, misuse, unauthorized access, alteration or disclosure.

11. Data retention

Personal data will be kept only for as long as necessary to fulfill the purposes described in this Privacy Notice and in accordance with applicable law.

12. Changes to the Privacy Notice

Prime Pass may modify or update this Privacy Notice at any time. Changes will be published within the Application or through the corresponding digital channels.

13. Competent authority

If the data subject believes their right to personal data protection has been violated, they may contact the competent authority in Mexico: the National Institute for Transparency, Access to Information and Personal Data Protection (INAI).