DATA CONTROLLER.

 

Brócoli Consultores S.C. (hereinafter “Brócoli Consultoría”), with its registered address in Mexico City, Mexico, is responsible for the use, protection, and processing of your personal data. Said data will be handled with strict confidentiality. Its collection, processing, transfer, and the exercise of rights related to such data will be carried out through proper, lawful, and legitimate use, at all times safeguarding the principles of legality, consent, quality, information, proportionality, and accountability.

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PURPOSES OF DATA PROCESSING.

 

The personal data we collect will be used for the following purposes, which are necessary for the purposes of the service provided:

• Establishing and maintaining business relationships with our clients.

• Providing consulting services in anti-corruption compliance, privacy, and personal data protection.

• Delivering consulting services for organizational restructuring, process improvement, and implementation of management systems aligned with international standards.

• Offering advisory services in legislative lobbying and legal reform project development.

• Providing legal counsel in matters of transparency, electoral law, criminal law, constitutional procedural law, and public policy.

• Implementing training programs for our clients’ employees and collaborators.

• Entering and maintaining business alliances with our commercial partners for joint projects.

• Establishing and maintaining communication channels between our consultants and clients for service delivery and support.

• Managing labor and service relationships with our employees and external collaborators.

• Retaining client records to provide future services.

• Invoicing and collecting payment for our services.

• Following up on any contractual relationship.

Additionally, we may use your personal data for the following purposes, which are not necessary for service provision:

• Marketing: Promotion of our services.

• Responding to inquiries and/or comments.

 

USE OF COOKIES, WEB BEACONS AND SIMILAR TECHNOLOGIES.

 

Our website, found at https://www.brocoli.mx/, uses cookies and Google Analytics web traffic analysis services. These tools allow us to identify the IP address used to access our site, the device’s operating system, the browser type, the date of access, and the specific pages visited. This information helps us understand how users interact with our site and allows us to improve its content and structure. The data collected through these tools does not include personal information that can identify users, nor any sensitive personal data.

 

PROCESSED PERSONAL DATA.

 

To fulfill the purposes described above, we may collect, in whole or in part, the following personal information:

• Full name

• Phone number

• Email address

 

TRANSFERRING OF PERSONAL DATA.

 

Your personal data may be shared with individuals, companies, organizations, and/or government entities, whether within or outside Mexican territory, for the purposes of providing consulting services and maintaining communication channels.

Your explicit consent is required for the transfer of your data. If you do not express your refusal to such transfers, we will consider that consent has been granted.

We also inform you that, in accordance with Article 37 of the Mexican Federal Law on the Protection of Personal Data Held by Private Parties, your data may be transferred without your consent under the following circumstances:

• When required by law or an international treaty to which Mexico is a party;

• When necessary for medical prevention, diagnosis, healthcare delivery, treatment, or healthcare service management;

• When the transfer is to parent companies, subsidiaries, or affiliates under common control, or to a parent company or any entity operating under the same internal policies;

• When necessary for the performance or execution of a contract in the interest of the data subject, entered into by the controller and a third party;

• When legally required or necessary to safeguard public interest, or for the administration of justice;

• When needed for the recognition, exercise, or defense of rights in a legal process;

• When necessary to maintain or fulfill a legal relationship between the data controller and the data subject.

 

ARCO RIGHTS (ACCESS, RECTIFICATION, CANCELLATION, AND OPPOSITION).

 

In accordance with applicable data protection laws, you have the right to:

• Access the personal data we hold about you, including details on how we use it;

• Request correction of any inaccurate, outdated, or incomplete information;

• Request the deletion of your data from our records (cancellation);

• Object to the use of your data for specific purposes.

These rights are collectively known as ARCO rights.

To exercise your ARCO rights, you must submit a request via email to: contacto@brocoli.mx including the following:

• Full name of the data subject

• RFC or CURP

• Copy of official ID with photo

• Contact information (phone, address, email)

• Indication of which ARCO right you wish to exercise

• Any other information that can help us respond to your request effectively

If you are acting on behalf of another individual, please attach the legal documentation that proves your authority to do so.

Once your request is processed:

• If exercising your Access right, we will send you a list of the personal data we hold.

• If requesting Rectification, please specify the incorrect information and the correction to be made. We will confirm once the update is complete.

• If requesting Cancellation, we will notify you once the data has been removed.

• If submitting an Opposition, please specify which purpose(s) you oppose. We will review and respond accordingly.

Please note that if exercising your ARCO rights makes it impossible for us to continue providing services, we will inform you so you can make an informed decision.

Brócoli Consultoría will respond to your request within 20 calendar days. If applicable, your request will be carried out within 15 calendar days following that response.

If you believe your personal data rights have been violated by any act or omission attributable to Brócoli Consultoría, or you suspect a breach of the LFPDPPP, you may file a complaint with Mexico’s data protection authority: the INAI. More information at: www.inai.org.mx.

 

MINORS, THIRD PARTIES, AND CONSENT EXCEPTIONS.

 

If the user of our services is not the data subject and provides personal data of third parties, they must have proper authorization and legal capacity to do so. By using Brócoli Consultoría’s services, the user confirms that they have the right to transfer such data, including (but not limited to) parents or guardians with parental authority over a minor, legal representatives of individuals lacking capacity, or of persons unable to input their own data due to health conditions.

If you are unsure whether you have proper authorization, do not submit any personal data via our platforms or services.

Consent will not be required when data processing and transfer are necessary for medical care, prevention, diagnosis, treatment, or health service management, provided the data subject is unable to give consent, and processing is carried out by a professional under confidentiality obligations in accordance with the General Health Law and other applicable regulations.

 

WITHDRAWAL OF CONSENT.

 

You may revoke the consent you previously granted for the processing of your personal data. However, in some cases, we may not be able to fulfill your request immediately due to legal obligations that require continued data processing. In any case, we will respond and inform you of the applicable steps and possible implications.

Revoking your consent may result in the inability to continue providing the requested services, termination of legal relationships, or other legal consequences.

To submit your request, email: contacto@brocoli.mx

 

LIMITING THE USE OR DISCLOSURE OF YOUR DATA.

 

If you no longer wish to receive promotional content or marketing messages, please email contacto@brocoli.mx and request to be added to our exclusion list. Please include:

• Your full name

• Your email address

 

CHANGES TO THIS PRIVACY NOTICE.

 

This Privacy Notice may be modified or updated due to legal changes; internal needs related to our products or services; changes in privacy practices; business model updates; or other reasons beyond our control.

If changes occur, we will notify you through the email address you provided and will update the notice at https://www.brocoli.mx/aviso-de-privacidad, or via other means such as printed, verbal, or electronic communications, as appropriate.