Pontem Advisory SAPI de CV

Effective date: [11/07/2025]

1. Identity and contact details of the data controller
   Pontem Advisory SAPI de CV, Tax ID (RFC) PAD250711DFA.
   Registered address: Av Progreso 25, Escandon, Miguel Hidalgo, Ciudad de Mexico, 11800, Mexico.
   Privacy contact email: soporte@pontemadvisory.org.
   Phone: +52 55 7981 3587.
   Authorized representative for privacy matters: Alejandro Valencia Alvarez.
   Contact for exercising data rights: soporte@pontemadvisory.org or the postal address above.
2. Scope and purpose
   This notice explains how Pontem Advisory collects, processes, stores, shares, and protects personal data when you interact with our team or use our website at pontemadvisory.com. The notice applies in Mexico and to transfers of personal data outside Mexico if we perform such transfers.
3. Legal framework
   We process personal data in accordance with the Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, LFPDPPP) and related regulations. The National Institute for Transparency, Access to Information and Protection of Personal Data (INAI) serves as the competent authority for data protection matters.
4. Personal data we collect
   We collect data directly from you, from data you provide through our site, and from authorized third parties. Categories include:
   • Identification: full name, national ID, CURP, RFC, date of birth.
   • Contact: postal address, billing address, email address, telephone number.
   • Professional and academic: CV, job title, employer, references, education history.
   • Fiscal and banking: tax regime, invoicing data, bank account identifier for payments.
   • Service records: contracts, work product, communication history.
   • Technical: IP address, device identifiers, browser and usage logs, cookies.
   • Media: photographs and audio recordings collected for identification or events.
   • Sensitive data: health or biometric data only when you give express consent or when the law allows.
   • Minors: we collect data of minors only with explicit authorization of parents or legal guardians.
5. Purposes of processing
   We process personal data for necessary purposes to provide professional advisory and consulting services and to comply with legal and tax duties. Core purposes:
   • Execute and manage client engagements and contracts.
   • Issue invoices and manage collections.
   • Communicate on administrative or operational matters.
   • Meet tax, regulatory, and legal obligations.
   • Manage job applications and recruitment.
   Secondary purposes that require express consent:
   • Send newsletters and commercial communications.
   • Conduct internal studies to improve services.
   • Share data with third parties for nonessential commercial or marketing activities.
6. Legal basis for processing
   We process data on the basis of contract performance, legal obligations, and the consent you give when providing data for specific purposes. Where the law requires, we will request your express consent prior to processing sensitive data.
7. Transfers of personal data
   We disclose data to service providers, banking entities, legal or tax authorities, consultants, and subcontractors when necessary to deliver services or comply with law. Transfers can occur within Mexico or abroad. We require recipients to adopt adequate security measures. If a transfer requires your prior consent under law, we will request it.
8. Rights of data subjects (ARCO and revocation)
   You hold rights of access, rectification, cancellation, and opposition, and rights of portability and revocation of consent. To exercise rights:
   • Send a written request to soporte@pontemadvisory.org or to the postal address above.
   • Provide: your full name, contact details for reply, clear description of the request, copy of official ID, and proof of representation if applicable.
   • We will respond within 20 business days after receipt. We may extend the response for one additional 10 business days by notifying reasons.
   Requests will not carry cost. We may charge reproduction fees for physical copies.
9. Procedure to revoke consent
   To revoke consent, send a revocation request to soporte@pontemadvisory.org. State your identity and the specific data or processing to revoke. Revocation will not affect lawful processing performed before revocation or processing required by law.
10. Security measures
    We apply administrative, technical, and physical safeguards to protect data. Measures include access control by role, encryption for sensitive information, backups, and confidentiality agreements with service providers. Despite safeguards, absolute risk elimination is impossible. We will follow legal reporting obligations in case of a reportable incident.
11. Data retention
    We retain personal data while necessary to fulfill the stated purposes or to meet legal retention periods. Examples: fiscal and accounting records for statutory tax periods. Job applicant records for up to one year after process closure unless you authorize longer retention. Marketing records until you revoke consent. After retention periods, we will delete or anonymize data according to policy and law.
12. Cookies and tracking technologies
    We use cookies and analytics to operate the website and improve user experience. Types used: necessary cookies for operation, performance cookies for analytics, functional cookies for preferences, and marketing cookies for personalized content. You can block cookies in your browser. Blocking cookies may affect site functionality. See our cookie policy on the site for more detail.
13. Minors and sensitive data
    We collect the data of minors only with prior consent of parents or legal guardians. We process sensitive data only with express consent and for specific, limited purposes.
14. Changes to this notice
    We will update this notice for legal, operational, or regulatory reasons. We will publish the updated version on our website. Substantial changes that affect your rights will require your consent if the law requires.
15. Supervisory authority and complaints
    If you believe we did not address your rights under law, you have the right to file a complaint with INAI. INAI website: www.inai.org.mx
16. Short privacy notice for collection points
    Pontem Advisory SAPI de CV, RFC PAD250711DFA, Av Progreso 25, Escandon, Miguel Hidalgo, Ciudad de Mexico, 11800. Main purposes: provide consulting services, manage contracts, invoice, and meet legal obligations. Secondary purpose: send commercial communications. For the full notice and instructions to exercise your rights visit the website or write to soporte@pontemadvisory.org.
17. Contact and authority
    For privacy questions send email to soporte@pontemadvisory.org or write to the address above. Authorized representative: Alejandro Valencia Alvarez.