PRIVACY POLICY OF “HOTEL ELENA DE COBRE”

Based on Articles 15 and 16 of the Federal Law on Protection of Personal Data Held by Private Parties, we inform you that HOTEL ELENA DE COBRE and/or any of its affiliated or subsidiary companies, located at Rosas Moreno 201, Colonia Centro, is responsible for collecting your personal data, the use given to it,and its protection. Therefore, we inform you of the following:
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1. Content of Personal Data.
   According to the Law, "Personal Data" is understood as any information concerning an identified or identifiable individual. For the purposes of this Privacy Notice, and by way of example but not limitation, “Personal Data” includes: First and last names, Federal Tax Registration Number, Unique Population Registry Code, date of birth, gender, marital status, existence or non-existence of children, address, landline phone (home or office), mobile phone, email, and other similar data concerning an individual.
2. Person Responsible for Collecting Personal Data.
   The area responsible for collecting your Personal Data (in this act, as well as in past and/or future acts) is our Personal Data Protection Department, located at Rosas Moreno 201, Colonia Centro. Email: recepcion@elenadecobre.com.
3. Processing of Personal Data.
   According to the Law, the processing of Personal Data (“Processing of Personal Data”) refers to the collection, use, disclosure, or storage of Personal Data by any means. The use encompasses any action of access, management, utilization, transfer, or disposition of Personal Data. The Processing of Personal Data by HOTEL ELENA DE COBRE will be limited to fulfilling the Processing Purposes outlined in this Privacy Notice and will adhere to the following:
   a. If it is intended to process your Personal Data for a purpose different from the purposes of this Privacy Notice, HOTEL ELENA DE COBRE will require obtaining your consent for such purpose once again.
   b. It will be necessary, appropriate, and relevant for the purposes described in this Privacy Notice.
4. Purposes of Processing Personal Data.
   Through this Privacy Notice, HOTEL ELENA DE COBRE declares that your personal information will be used for the following purposes: to provide the services and products you have requested, such as reservations, purchase of vacation packages, memberships, or any other loyalty program, and any other transactions related to the provision of accommodation, tourism, and commercial services in general; notification about new services or products related to those already contracted or acquired; informing you of changes in the same; developing studies and programs necessary to determine consumption habits; conducting periodic evaluations of our products and services to improve their quality; evaluating the quality of the service we provide; and in general, to fulfill the obligations we have contracted with you. HOTEL ELENA DE COBRE may share or transmit the information with associates of the group to which it belongs or with third parties so that they can send you information about their products and services in general.
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   4.1 HOTEL ELENA DE COBRE has video surveillance cameras on its premises for general security purposes and loss prevention. The recordings are stored in a secure area with restricted access. The recordings are routinely destroyed(automatically or manually) every ---- (days, months, etc.), unless they are necessary for the investigation of an incident or for a judicial procedure.

5. Acceptance of the Processing of Personal Data. In order for HOTEL ELENA DE   COBRE to carry out the Processing of Personal Data, our clients and/or data subjects must provide us with express or implied acceptance for such processing, which will be obtained by any of the following means:
   
   5.1. Acceptance through electronic meansa) Publication on the HOTEL ELENA DE COBRE websites. In addition to notifying you of the Privacy Notice via email, HOTEL ELENA DE COBRE will publish this Privacy Notice on its websites so that onceyou are aware of its content, you can grant or deny your consent for HOTEL ELENA DE COBRE to carry out the Processing of your Personal Data. This will also apply in cases where, for any reason, HOTEL ELENA DE COBRE does not have your email address or when your Personal Data is incorrect or outdated and prevents us from locating you.
   b) Email. Based on the information you provide or have provided, HOTEL ELENA DE COBRE will send this Privacy Notice via email so that, once you are informed of its content,you can grant or deny your consent for HOTEL ELENA DE COBRE to carry out the Processing of your Personal Data.
   
   5.2. Acceptance in person. When Personal Data is obtained directly from the data subject,HOTEL ELENA DE COBRE will make this Privacy Notice available at the time your Personal Data is collected using the forms that HOTEL ELENA DE COBRE currently uses or may use for such purposes. Additionally, through these forms, HOTEL ELENA DE COBRE will collect the acceptance or denial of consent from the data subject to submit such data to the Processing Purposes established in this Privacy Notice.
   
   5.3. Implied acceptance. Based on the provisions of Article 35 of the Law, the content of this Privacy Notice, as well as any modifications or additions, will be communicated to you by any of the means established in sections 5.1 and 5.2above. If you do not express opposition to the content and scope within a period of 2 (two) months from the date on which HOTEL ELENA DE COBRE informs you about the Privacy Notice or its modifications, it will be understood that you grant your implied consent for HOTEL ELENA DE COBRE to carry out the processing of your Personal Data based on the Processing Purposes established in the Privacy Notice.
   
   5.4 Retroactive Acceptance. For all our clients who provided their Personal Data prior to the notification or publication of this Privacy Notice, whether by filling out various forms or by any other means, the Privacy Notice will be communicated to them in accordance with the provisions in sections 5.1 and 5.2 above, so that they can grant or deny their consent (express or implied) for HOTEL ELENA DE COBRE to continue processing their Personal Data based on the Processing Purposes established in the Privacy Notice.

6. Limitation on the Use or Disclosure of Your Personal Data.
   6.1 Actions to Prevent Unauthorized Use or Disclosure. In order to ensure the protection of your Personal Data and limit unauthorized use or disclosure, HOTEL ELENA DE COBRE continually performs and will perform the following actions:
   a) Confidentiality of Information. HOTEL ELENA DE COBRE will maintain confidentiality regarding the Personal Data collected; this obligation will persist even after the end of commercial or other relationships with the client or the holder of such Personal Data.
   b) Confidentiality Notification. If for any reason HOTEL ELENA DE COBRE needs to provide your Personal Data to third parties (as provided for in the Law or in this Privacy Notice), it will notify those third parties of their obligation to comply with the provisions of the Law and the confidentiality of your Personal Data.
   c) DatabaseManagement. Personal Data is managed and safeguarded through the use of databases (“Database”), which are managed solely by individuals designated by HOTEL ELENA DE COBRE for this purpose, without allowing use, consultation,handling, or access by unauthorized persons.
   d) Computer and IT Systems. Our Databases are protected by firewalls and computer and/or IT systems designed to prevent unauthorized access by individuals outside HOTEL ELENA DE COBRE to your Personal Data.
   
   6.2 Requeststo Limit Use or Disclosure. If you wish to limit the use or disclosure of your Personal Data in relation to one or more of the Processing Purposes (for example, advertising emails, offers, transmitting information to third parties,among others), you can send the respective request in accordance with the procedure established in section 7 of this Privacy Notice, or by accessing the links provided or to be provided on the HOTEL ELENA DE COBRE websites or in promotional information we send you.

7. Rights of Access, Rectification, Cancellation, or Opposition. It is important to inform you that you have the right to access, rectify, and cancel your personal data, to oppose the processing of your data, or to revoke the consent you have granted for such purposes. To do so, you must submit the request in the terms outlined in Article 29 of the Law and as indicated in this Privacy Notice to the Personal Data Protection Department.
   
   7.1 Personal Data Protection Department. HOTEL ELENA DE COBRE has designated a department responsible for the custody of Personal Data (“Personal Data Protection Department”), which will handle your requests and promote the protection of Personal Data within HOTEL ELENA DE COBRE. To this end, the Personal Data Department provides the following contact information for receiving information and documentation related to your requests:
   a) Email:recepcion@elenadecobre.com
   b) Address: Rosas Moreno 201, Colonia Centro
   Attention: Personal Data Department.
   
   7.2 Request for Access, Rectification, Cancellation, or Opposition. As the holder of Personal Data, you may submit or send a request to the Personal Data Department for access, rectification, cancellation, or opposition regarding your Personal Data. Such a request must contain at least:
   a) Full name and address of the holder of the Personal Data, or another means to communicate the response to your request.
   b) Documents that prove the identity or legal representation of the holder of the Personal Data.
   c) A clear and precise description of the Personal Data regarding which you wish to exercise any of the aforementioned rights.
   d) Any other element or document that facilitates the location of the Personal Data.
   e) Indication of the modifications to be made and/or the limitations on the use of the Personal Data, in accordance with the provisions of section 6.2 of this Privacy Notice.
   f) Submission of documentation supporting your request.
   
   7.3 Resolution and Communication. HOTEL ELENA DE COBRE will communicate the determination made to the holder of the Personal Data within a period not exceeding 20business days from the date the request was received. This period may be extended by HOTEL ELENA DE COBRE once for an equal period, provided the circumstances of the case justify it.
   Based on the above and in accordance with the Law, HOTEL ELENA DE COBRE will inform the holder of the Personal Data of the decision and the reasons for it,through the same means by which the request was made and will accompany the decision with relevant evidence, if applicable. When the request is deemed appropriate, HOTEL ELENA DE COBRE will implement it within the 15 business days following the communication of the decision made.
   The holder may submit a request for data protection to the Federal Institute for Access to Information (IFAI) regarding the response received or lack of response from HOTEL ELENA DE COBRE. This request must be made by the holder within 15 business days following the date the response was communicated to the holder by HOTEL ELENA DE COBRE and will be subject to the provisions of the Law.
   In cases of requests for access to Personal Data, the requester or their legal representative must first verify their identity. The obligation to provide access to information will be deemed fulfilled when HOTEL ELENA DE COBRE makes the Personal Data available to the holder or by issuing simple copies or electronic documents.
   In the event that a person requests access to their Personal Data from HOTEL ELENA DE COBRE, assuming it is the responsible party and it turns out that it is not, it will be sufficient for HOTEL ELENA DE COBRE to inform the holder by any means (as established in this section) to consider the request as resolved.
   The response to your request for access, rectification, cancellation, or opposition of the Personal Data will be free of charge. You will only need to cover justified shipping expenses or the cost of reproduction in copies or other formats, which HOTEL ELENA DE COBRE will inform you of in due course.
   If the same person reiterates the request for access, rectification,cancellation, or opposition of the Personal Data within a period of less than12 months from the date of the last request, the response to your request may incur an additional cost indicated by HOTEL ELENA DE COBRE, in accordance with the provisions of Article 35 of the Law.
   
   7.4 Denialof Access to Personal Data. HOTEL ELENA DE COBRE may deny total or partial access to Personal Data or the rectification, cancellation, or opposition to the processing of the same in the following cases:
   a) When the requester is not the holder or the legal representative is not duly accredited.
   b) When the Personal Data of the requester is not found in the HOTEL ELENA DE COBRE database.
   c) When the rights of a third party are infringed.
   d) When there is a legal impediment or resolution from an authority.
   e) When the rectification, cancellation, or opposition has already been carried out, rendering the request moot.
   
   7.5 Consequences of Cancellation. The cancellation of Personal Data will result in ablocking period after which HOTEL ELENA DE COBRE will proceed with the deletion of the corresponding data. Once the relevant Personal Data is canceled, HOTEL ELENA DE COBRE will notify its holder.
   Following this, HOTEL ELENA DE COBRE may retain the Personal Data exclusively for the purposes of addressing responsibilities arising from the processing referred to in the Privacy Notice.
   When the Personal Data has been transferred to third parties prior to rectification or cancellation and is processed by those third parties, HOTEL ELENA DE COBRE must inform them of the request made by the holder so that they may proceed to make such rectifications or cancellations.
   HOTEL ELENA DE COBRE is not obligated to cancel your Personal Data when it pertains to the cases established in Article 26 of the Law.
   Furthermore, when the information collected in the Personal Data is no longer necessary for fulfilling the purposes established in this Privacy Notice and applicable legal provisions, your Personal Data will be canceled from the databases of HOTEL ELENA DE COBRE.

8. Changes to the Privacy Notice. HOTEL ELENA DE COBRE reserves the right to make modifications or updates to this Privacy Notice at any time, to address legislative or juris prudential changes, internal policies, new requirements for the provision or offering of its products and services, or for commercial practices.
   Therefore, if HOTEL ELENA DE COBRE modifies the content of this Privacy     Notice, it will inform you through any of the forms and means established     in section 5 of this Notice.
9. Transfer of Personal Data. If HOTEL ELENA DE COBRE transfers your Personal Data to any of its suppliers in order to fulfill the Processing Purposes established in this Privacy Notice, it will do so after signing confidentiality   agreements and only if (i) the supplier or person to whom the data is     transmitted agrees to subject the processing of Personal Data to this     Privacy Notice, and (ii) it does not fall under any of the cases established in Article 37 of the Law.
   
   If you do not express your opposition to the transfer of your Personal     Data to third parties, it will be understood that you have granted HOTEL     ELENA DE COBRE your consent for such transfer.