Privacy Notice for Potential Clients, Clients, Administrators and Users of the JOIN2WORK Platform

The JOIN2WORK Platform is a complete technological solution for human resource management, which operates through the Internet site https://www.join2work.com.

I. Identity and address of the Data Controller.

The person responsible for processing the personal data you provide is Pilar Tech México, S. de R.L. de C.V., (hereinafter “J2W” or the “Data Controller”), with address at Insurgentes Sur 1898 piso 3, Colonia Florida, Alcaldía Álvaro Obregón, Código Postal 01030 in Mexico City, Mexico, to hear and receive notifications as well.

II. Collected personal data.

In the case of potential clients and clients, we inform you that we process personal identification, employment, contact and location data. Besides, sensitive personal data will not be processed.

In the case of Administrators and Users, we inform you that, in order to comply with the purposes indicated in this Notice, J2W will process identification, contact, employment, location (address) data, property data, financial data, identification data of the device through which it is accessed, IP, entry and exit records and use of the Platform. We inform you that, where appropriate, sensitive personal geolocation data will be processed. The processing of geolocation personal data is applicable for cases in which the place from which the work is conducted under the “Home Office” scheme must be reported, that is, such personal data is processed in the registry of start or end of working hours or breaks. Likewise, we inform you that, due to the use of J2W (when requesting some proof or derived from the control of working days) personal health data will be processed.

III. Purposes for the collection.

In the case of potential customers and (effective) customers, the Data Controller may process your personal data for the following primary purposes:

1. 1. 1. 1. Contact to prospect you as a client to offer services by various means, such as telephone, email, SMS messages, instant messaging tools such as WhatsApp or Telegram, or through social networks.
         2. Schedule appointments to visit or contact you and offer you PILAR services.
         3. Follow up on the activities conducted with potential clients.
         4. Submit business proposals and quotes.
         5. Follow up on the commercial proposals presented.
         6. Make statistical reports of the activities conducted with potential clients.
         7. According to the activity of the potential client, conduct the risk class classification.
         8. Prepare the document stating the commercial relationship with the Data Controller.
         9. Identify the representatives of the parties (entities) or the parties (individuals).
         10. Locate you to enforce compliance with contractual obligations.
         11. Identify you to provide the contracted services.
         12. Register you as a client in order to monitor and control the contracted services.
         13. Contact you to communicate situations related to the provision of contracted services.
         14. Identify specific situations to provide customer service and propose, execute and monitor corrective actions.
         15. If applicable, provide a role registration and registration service and administration and technical support regarding the tools or systems that you use and the Data Collector has its administration.
         16. If applicable, record and report the activity conducted within the tools or systems used by the Data Collector and its administration.
         17. Apply satisfaction surveys of the services provided by the Data Collector and analyze their results.
         18. Contact you to improve the services of the Data Controller and thank you for your preference.
         19. Send you the invoices that support the collection of services rendered.
         20. Perform collection acts, either by phone, by mail or at your home.
         21. Provide you with a role registration and deregistration service and administration and technical support regarding the tools or systems that you use and PILAR has its administration.
         22. Send you documentation by courier for your review, signature, acceptance, knowledge and/or use.
         23. Identify you to authorize your entry to the Data Collector’s facilities, assist you by telephone and/or by any means you use to contact PILAR.
         24. Follow up and attend to requests for procedures conducted before PILAR.
         25. Follow up on legal or contractual obligations.
         26. In case of being in the facilities of the Data Collector and suffering an accident, provide the required assistance.
         27. Elaborate operational, statistical or historical reports.
         28. Through video surveillance systems, the monitoring of activities conducted within the facilities of the Data Collector.

In the case of Administrators, the Data Controller may process your personal data for the following primary purposes:

1. 1. 1. 1. Administration and control of the Platform.
         2. Identification for the management, configuration and administration of your username and password to use the Platform.
         3. Configuration of permissions within the Platform.
         4. Provide you, for consultation, with the personal data with which your user is registered.
         5. Present you with messages that other users send you through the Platform.
         6. Deliver the messages you send through the Platform to the indicated recipient.
         7. Sending and receiving email notifications.
         8. Provide you with technical support.
         9. Provide attention and follow-up to doubts and requests related to the Platform, as well as contact you to make clarifications or follow-up on such requests.
         10. Generate reports and statistics on the use of the Platform and the records contained therein.
         11. Manage the cancellation of your user within the Platform.

In the case of Users, that is, collaborators and leaders, the Data Controller may process their personal data for the following primary purposes:

1. 1. 1. 1. Identification for the management, configuration and administration of your username and password for the use of the Platform.
         2. Configuration of permissions within the Platform.
         3. Provide you, for consultation, with the personal data with which your user is registered.
         4. Provide your information to other authorized Users of J2W for the use of authorized functionalities according to the roles and permissions designated in the Platform.
         5. Give you access to use the Platform in its different functionalities: View activity reports within the Platform; Link your Microsoft, Google and Zoom accounts to the Platform; Registration, management and administration of your working day, your agenda, meetings, hours worked, vacations (permissions, requests, days in advance); Registration, management and administration of objectives and tasks and the activities for their fulfillment; Control and management of assigned computer equipment; Administration and consultation of payment receipts and history; Control, management and notification of requests for records related to work activities; Send you internal communications, news or emails.
         6. Management and synchronization of your calendar, agenda and events, both in the Platform and in third-party services integrated to it.
         7. Integrated meeting management and synchronization with third-party video conferencing services.
         8. Present you with the messages that other users send you through the Platform.
         9. Deliver the messages you send through the Platform to the indicated recipient.
         10. Sending and receiving email notifications.
         11. Provide you with technical support.
         12. Provide attention and follow-up to doubts and requests related to the Platform, as well as contact you to make clarifications or follow-up on such requests.
         13. Generate reports on the use of the Platform and the records contained therein.
         14. Manage the cancellation of your user within the Platform.

 IV. Secondary purposes

For all holders of personal data, additionally, we will use your personal data for the following secondary purposes:

1. 1. 1. 1. Invite you to events organized by J2W.
         2. Have a control of attendees and evidence of events conducted by J2W.
         3. Send you information issued by J2W.
         4. Preparation and dissemination of advertising with your identification data (photographs, videos, audio of events conducted by J2W).

In the event that you do not want your personal data to be processed for any or all of the secondary purposes, from this moment you can notify us by sending an email to the address dataprivacy@join2work.com.

For cases in which personal data is obtained indirectly, you have a period of 5 (five) business days (from the first contact that the Data Controller has with you), in order to send an email to the address dataprivacy@join2work.com, expressing the refusal to have your personal data processes.

 V. Transfers

To comply with the purposes described above and others that are legally required or by competent authorities, through a well-founded and motivated request, the following transfers of your personal data will be made:

If you do not want your personal data to be transferred with respect to those transfers for which your consent is necessary, please let us know at any time by sending an email to dataprivacy@join2work.com.

VI. ARCO rights and/or revocation of consent

You or your legal representative may exercise any of the rights of access, rectification, cancellation or opposition, also known as ARCO rights, as well as revoke your consent for the processing of your data, by communicating it via email to the address dataprivacy@join2work.com, which is managed and attended by our J2W Personal Data Committee domiciled at Insurgentes Sur 1898 piso 3, Colonia Florida, Alcaldía Álvaro Obregón, Código Postal 01030 in Mexico City, Mexico.

You must submit an application that: (i) Indicates the name of the applicant, and if applicable, of your legal representative; (ii) Prove the personality of the applicant, and if applicable, of your legal representative; (iii) Indicate the address and/or email where you can be reached; (iv) Identify the right to be exercised and the data on which it is required to exercise it – if it is a right of correction, indicate the data to be corrected and the correction to be made, or, if it is a right of opposition, indicate the secondary purposes on which you want to exercise the right. Failure to comply with the point indicated in number (iii), the request will be considered as not submitted.

Once J2W receives the request, it will have 5 (five) business days to verify compliance with the provisions of the previous paragraph. In the event that your request is incomplete or there is an error, J2W will let you know and you will have 10 (ten) business days to comply with the request that we made, if not done within such period, the request will be considered as not submitted.

Once the request has been received, meeting all the requirements, J2W will have 20 (twenty) business days to notify you of the origin of your request. Once the previous notification has been made, and if the exercise of the right is appropriate, J2W will have 15 (fifteen) business days to make the right effective.

The deadlines indicated in the previous paragraph may be extended for the same time indicated for a single occasion and justified cause.

VII. Limitation and/or Disclosure of your data

You may limit the use or disclosure of your personal data by making your request via email to dataprivacy@join2work.com. If your request is appropriate, you will be registered in the list that the Company has for such purpose.

VIII. Data retention regarding third-party apps and use of third-party apps.

We only retain personal identification data regarding the entry to such applications, which is collected to improve your experience in the interaction and use of it within J2W. Regarding the integration with the Google, Zoom and Microsoft service, you are informed that we obtain your identification and agenda data for the synchronization of calendars and events through videoconference with J2W and provide you with such functionality integrated into our technological solution.

We inform you that such personal data is kept for the time required for the provision of the service provided by J2W in accordance with applicable legislation. The provision of this Privacy Notice and the use of J2W configures your tacit consent for the processing of your personal data.

Likewise, we inform you that the processing of your personal data executed by the use of third-party tools is the responsibility of the companies that own such technology; therefore, we recommend that you review the Privacy Policies that govern the service of each of them. Next, we make available the websites that you can consult for such purposes; however, we suggest you visit the main website of the provider in question, in order to consult the current and applicable policies for each case: i) For Microsoft, we suggest you visit the site https://account.live.com/consent/Manage and/or https://myapps.microsoft.com; ii) For Google, we suggest you visit the site https://developers.google.com/terms/api-services-user-data-policy and/or https://policies.google.com/privacy?hl=es, and for Zoom https://explore.zoom.us/es/privacy/.

IX. Use of Cookies, web beacons or other similar technologies

We inform you that, through our website https://www.join2work.com we use cookies and other technologies, through which it is possible to monitor your behavior as an internet user, as well as to provide you with a better service and experience while browsing our page. The personal data that can be obtained through the use of these technologies are the following: locations, source IP address, browser used, operating system, access devices. These technologies may be disabled by following the procedures of the Internet browser you use.

X. Users residing in the European Union.

We inform you that your personal data will be processed by Pilar Tech México, S. de R.L. de C.V, (hereinafter “J2W” or the “Responsible”), with address at Insurgentes Sur 1898 piso 3, Colonia Florida, Alcaldía Álvaro Obregón, Código Postal 01030 in Mexico City, Mexico The provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data and repealing Directive 95/46/EC (General Data Protection Regulation) will be applicable only in cases where the owner of the personal data resides in the European Union.

To comply with the principle of transparency, we inform you of the following:

1. 1. 1. 1. The identity and contact details of the Data Collector: To comply with this requirement, the provisions of numeral I of this instrument will be followed.
         2. The contact details of the data collection delegate: To comply with this requirement, the provisions of numeral V of this instrument will be followed, in particular, you must consider that the contact for issues related to the processing of your personal data is the J2W Personal Data Committee, located at Insurgentes Sur 1898 piso 3, Colonia Florida, Alcaldía Álvaro Obregón, Código Postal 01030 in Mexico City, Mexico, and you may contact it via email dataprivacy@join2work.com.
         3. The purposes of the collection to which the personal data is destined and the legal basis of the collection. To comply with this requirement, the provisions of numeral III of this instrument will be followed. Besides, you are informed that the legal basis for the collection is updated in the assumption that the processing of your personal data is necessary to provide the contracted service regarding the use of J2W; therefore, collection is necessary for the fulfillment of the legal obligations of the Data Collector. In the case of potential clients, the legal basis is their tacit consent before the provision of this instrument.
         4. The recipients or categories of recipients of personal data. To comply with this requirement, the provisions of numeral V of this instrument will be followed.
         5. The intention of the Controller to transfer personal data to a third country or international organization. To comply with this requirement, the provisions of numeral V and IX of the instruments herein will be followed.
         6. The period during which the personal data will be kept. The term for which the personal data will be kept will be identified in two stages: The first refers to the time for which your personal data is used for the primary purposes indicated in numeral III of this instrument, and at the end of such period, your personal data will be kept in the second stage regarding the blocking of your personal data, which will attend the time established by the legislation that regulates the provision of the service. Specifically, the Data Controller has a specific Policy that governs the retention periods of your personal data, in particular, the blocking time of your personal data will be 10 years from the conclusion of the execution of the primary purposes stated above. Once this period has expired, and in accordance with the aforementioned policy, your personal data will be deleted.
         7. The existence of the right to request from the data controller access to the personal data relating to the interested party, and its rectification or deletion, or the limitation of its processing, or to oppose the processing, as well as the right to data portability. In order for you to exercise the rights indicated above, the provisions of number VI of this instrument will be applicable, however, the specific rules for processing the corresponding request, the applicable precepts will be applicable according to the Regulation (EU) 2016/679.
         8. The right to file a claim with a supervisory authority. You may file a claim with the corresponding control authority in accordance with the applicable jurisdictional authority.
         9. The source from which the personal data comes. If the personal data is not obtained directly by the owner of such, you are informed that the source of origin is the J2W client who contracts the Platform to provide it as a tool to its collaborators or employees. Besides, users or administrators of the Platform may enter personal data of other holders of personal data, which is necessary for its configuration and/or use.
         10. In this case, the provisions of numeral V of this section will apply, in which personal data is transferred encrypted to social networks to identify the profile of our users with the aim of prospecting new customers.

XI. Changes to the Privacy Notice.

Any changes to the document herein will be published on our website https://www.join2work.com.

Update date: July 27th, 2022.