PRIVACY NOTICE

Basham, Ringe y Correa, S.C., having an address at Paseo de los Tamarindos 400-A, 9° Piso, Col. Bosques de las Lomas, C.P. 05120, Mexico City, Mexico (“Basham”), recognizes the significance of a legal, controlled and informed processing of your personal data and makes this Privacy Notice available to you so that you know our practices for obtaining, using, storing and in general, processing your personal data as required by the Federal Law on the Protection of Personal Data in Possession of Private Parties (the “Law”).

Personal Data that May Be Processed

Personal data that you provide to us voluntarily, for example, when you send us your résumé or an e-mail to contact you, or when you log in to receive information or read our newsletters, as well as data you provide to us in order to create a legal relationship with our firm, retain our legal services or provide a service to us, may be of a nature of any of the following:

-  Identification, such as: name, home address, date of birth, personal identity number (CURP), home phone or mobile, fax and e-mail address.

-  Education, such as: academic background, university degree, professional ID number, specialization, certificates.

-   Employment, such as: position title, work address, e-mail address, work phone or mobile and fax.

-   Billing, such as: entity to which charges will be billed, tax address, and federal taxpayer identification number.

-   Financial, such as: bank account information, payment method.

Purposes and/or Uses of Personal Data

The personal data provided to us voluntarily, when you send us your résumé or an e-mail to contact you or when you log in to receive information or read our newsletter, will be used to contact you if your profile appears to be of interest to our firm, to respond to your request and to send you information or our newsletters.

Personal data obtained due to a legal relationship, which processing is necessary to comply with the obligations arising from such relationship, will be used only to provide you the requested professional services, send you communications related to the case entrusted to us, prepare bills, retain services or acquire your products, forward payments for such services or products, enter into agreements or execute other documents to formalize the relationship created with you.

Your personal data may be used for purposes other than the aforementioned or those included in the Privacy Notice made available to you, provided that such purposes are consistent with the purposes previously described and may be considered analogous.

Transfers of Personal Data

Basham will not sell, assign or transfer any personal data to any third party not pertaining to our firm, without your prior consent. However, Basham may transfer its personal data when such transfer is contemplated by the Law.

Security Measures

Basham has taken and kept the necessary security, administrative, technical and physical measures for protecting your personal data against damage, loss, alteration, destruction or unauthorized use, access or processing. However, no Internet data transmission is fully safe; thus Basham cannot guarantee that your personal data will be free from any damage, loss, alteration, destruction or unauthorized use, access or processing.

Rights of the Personal Data Subject

As a personal data subject, you may exercise the access, rectification, cancellation and opposition rights (“ARCO” rights) against the data processor. Also, you may cancel at any time the consent that you have granted for the processing of your personal data, and limit the use or disclosure of such data

The foregoing by sending a request, as set forth in the Law, to the e-mail address: privacidad@basham.com.mx or to Paseo de los Tamarindos No. 400-A, piso 9°, Bosques de las Lomas, C.P. 05120, Mexico City, Mexico. As reference,

ARCO rights are briefly described:

-   Access. Be advised on which personal data have been stored in Basham´s database, how such personal data are used, their origin and communications made with such data and, in general, the conditions and general provisions of the processing.

The access obligation will be deemed satisfy when:

i) The data are made available to the data subject or,

ii) By the issuance of simple copies, magnetic, optical, audio, visual, and holographic devices, electronic documents or any other means or technology deemed appropriate.

-   Rectification. Correct or update your personal data if they are inaccurate or incomplete. You will have to advise Basham on any change to be made to your personal data, when you are the only one who knows such changes.

-   Cancelation. Your personal data will be cancelled, in whole or in part, from Basham´s database once the purpose for which they were gathered has been accomplished.

-   Opposition. Opposing for a legitimate reason to the processing of your personal data.

Changes to the Privacy Notice

If there are substantial or full changes to this Privacy Notice or in the one provided to you, the updated version will be made available in our web site www.basham.com.mx.

Contact

If you have any questions about this Privacy Notice, please contact our person in charge of personal data at the following e-mail address: privacidad@basham.com.mx or at Paseo de los Tamarindos No. 400-A, piso 9°, Bosques de las Lomas, C.P. 05120, Mexico City, Mexico.

Pursuant to the Law and its Regulations, please note that, in view of the refusal to response to a petition for ARCO rights or disagreement with such response, you may file with the Federal Institute for Access to Information and Data Protection the relevant Application for Protection of Rights within the deadlines and terms set forth in the Law and its Regulations.

Last update: April 2012.

PRIVACY POLICY

In Basham, Ringe y Correa (“Basham”) we acknowledge the value of your privacy, as well as your right to informational self-determination.  The purpose of this Privacy Policy is to notify you how we obtain, use, disclose, store or, in general, treat the personal data that you voluntarily provide us through the web site www.basham.com.mx.

Personal Data

You may navigate through our web site without providing any personal data; however, there are specific sections in the web page where you may voluntarily provide data such as: name, address, e-mail, telephone or other identification data.  For example, whenever you contact us requesting information about our firm or the legal services, we provide or for submitting a job application or obtaining information on our Foundation.

Certain characteristics of, and access to, our web site are exclusively reserved to registered users.  There are user’s names and passwords for all registered users, which are assigned by the Information Technology Department of our firm.  Such data are only used to give access to registered users and to personalize web page functions.

How We Use Your Personal Data

The personal data you decide to share with us through the web site www.basham.com.mx will be used to identify and, if required, contact you by replying the e-mail you sent us, as well as to include you in our database and to send you information that may be of your interest.

If you contact us to apply for a job in our firm, please read the specific Privacy Notice, which will be available in our web site or will be sent to you by e-mail.

The personal data that you provide us will be kept as long as required to comply with the above-described purposes.

Additional Information

When you navigate in our web site, certain non-personal information is collected through “cookies” and the server records.  The purpose of collecting such information is to obtain statistics related to the number of visits to our web site or the reference sites that may have linked you to ours.  This information is also used to maintain and update the users’ profiles in our web site, to personalize the user profile when visiting the site, and to adapt the information provided through our web site.

-   Cookies – A cookie is an alphanumeric identifier that is stored in your hard disk, through your browser, when you visit our web site.  Cookies allow us to improve our web site service and may also be used to collect additional information about our most visited sections.  The traffic information is used to improve the content of our web site and make its use easier.  If you want to reject the use of cookies, you may configure your browser to do it; however, it is possible that certain applications are not correctly displayed due to such rejection.

-   Log files - Our web site uses certain files that register information on the activity that may occur inside; for example, users of the Internet Protocol (“IP”), type of browser, Internet Service Provider (“ISP”), the referred and incoming pages, type of platform, the date/time seal and number of clicks.  This information is used to manage the page and analyze the traffic in our web site.

Security Measures/Access Restrictions

Basham has taken the necessary technical, administrative and physical security measures for procuring the integrity and confidentiality of your personal data and avoiding any damage, loss, alteration, destruction or unauthorized use, access or treatment; however, it is clear that no Internet data transmission is entirely safe; thus, Basham cannot guarantee that the personal data treatment will be free from any damage, loss, alteration, destruction or unauthorized use, access or treatment.

Only authorized personnel, who have met and complied with the applicable confidentiality requirements may participate in your personal data treatment.

How We Share Personal Data

Basham does not sell, assign or transfer any personal data without the prior consent of the data subject.

As part of our firm’s operations and in order to comply with some of the above-described purposes, we may share some of your personal data with domestic or foreign third parties.  It must be understood that such third parties act in the name and on behalf of Basham, for example, service providers and external auditors.

In such cases, Basham will cause such third parties to keep the necessary administrative, technical and physical security measures to protect the personal data against any damage, loss, alteration, destruction or unauthorized use, access or treatment, as well as to abide by this Privacy Policy.

Links

Our web site may contain, for your convenience, links to other web sites.  Basham has not reviewed the Privacy Policies of such sites; therefore, our firm neither guarantees nor is responsible for their content.  Please read carefully the Privacy Policy of each site linked to our web site.

Your Personal Data Rights

As data subject, you may e-mail to our data processor (privacidad@basham.com.mx) or personally file at Paseo de los Tamarindos No. 400-A, piso 9°, Bosques de las Lomas, C.P. 05120, México, D.F., Mexico, your application for exercising your access, rectification, cancellation and opposition rights.

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy; therefore, we suggest you to review this Policy from time to time in order to know the latest changes.  The Privacy Policy in effect will be published in our web site, stating the last revision date.  The use of our web site implies that you have read, become aware, and accepted the Privacy Policy in effect at the time of using it.

Contact

If you have any query or comment with respect to this Privacy Policy or wish to exercise your rights provided by law, please contact our data processor at the following e-mail address: privacidad@basham.com.mx or visit us in Paseo de los Tamarindos No. 400-A, piso 9°, Bosques de las Lomas, C.P. 05120, México, D.F., Mexico.

Updated on July 5, 2011.