INTEGRAL PRIVACY NOTICE

 

"MURILLO SOLUCIONES EMPRESARIALES", SOCIEDAD CIVIL, (Hereinafter Nawwa Galería) with address at CONCEPCIÓN BEISTEGUI 622-7, COLONIA DEL VALLE, ALCALDÍA BENITO JUÁREZ, CP 03100, CDMX, MEXICO, designating as responsible for the use and protection of your personal data; Mr. Alan Daniel Álvarez Tostado Corona with email aalvarez@nawwa.mx, who will also act as the physical handler of the management and protection of your data, together we inform you of the following:

 

For what purposes will we use your personal data?

 

It is important to mention that "Nawwa Galería" will collect the following data:

 

• Personal data provided directly by users during the use and interaction of the different platforms through which we provide digital and physical services, as well as those generated during account creation.

• Data created during the use of our services, such as details of the device, location and use of the app, among others.

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Nawwa Galería collects and uses information to provide "Interconnection of people and groups for a possible future sale of works of art" services, as well as to offer other products and services. We also use the collected data to do the following:

 

• Improve the security of users and services.

• Provide customer support.

• Carry out research and development tasks in regard to develop our services.

• Allow communication between users.

• Send marketing and other communications to users.

• Address issues related to legal procedures.

 

Nawwa Galería does not sell or disclose personal data of our users to third parties for direct marketing purposes, unless the users give their consent in writing and under specific cases.

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The personal data that we collect from you will be used for the following purposes that are necessary for the service you request:

 

1.- Provide services and functions. Nawwa Galería uses the collected data to provide, personalize, maintain and improve our art platform.

 

This includes using them for the following:

 

• Create and update user accounts.

• Verify the identity, background and compliance with the requirements of the users.

• Help and manage procedures and services on behalf of the artists participating in the platform.

• Offer, process or facilitate payments for our services and works of art.

• Offer, obtain, provide or facilitate billing or financing with respect to our services.

• Activate functions that allow users to share information with other people, for example, when customers comment on an artist, or when users send an acknowledgment to an artist, refer a friend to Nawwa Galería among others.

 

2.- Security. We use personal data to maintain the security and integrity of our services and users. This includes the following:

 

• Conduct the user and artist screening process before allowing them to use our services, including during background check reviews when permitted by law, and afterwards to prevent untrustworthy individuals from using our services.

• Under certain Anti Money Laundering (AML) assumptions, we will use information derived from official ID photos and other images previously sent to Sala Nawwa for security purposes, which could include ID verification in real time, our users may be asked to share a selfie before connecting to ensure that the person using the app matches the registered owner of the Nawwa Galería account. This also includes comparing registered photographs; (i) with those of other users to avoid identity borrowing and (ii) with those in public databases to verify the identity of the user.

• Use device, location, profile and usage data, among others, to prevent, detect and combat fraud or unsafe activities.

 

3.- Customer support. Nawwa Galería uses the data we collect (such as recordings of customer support calls with notice to the user and their consent) to provide assistance, as follows:

 

• Direct questions to the appropriate customer support associate.

• Investigate and address user concerns.

• Monitor and improve our responses and customer support processes.

 

4.- Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning in order to improve the user experience. This helps us to improve the security of our services, as well as to prevent their use for illegal or improper purposes, to develop new features and products, and to facilitate insurance and financial proposals related to our services.

 

5.- Allow communications between users.

 

Additionally, we will use your personal information for the following purposes that are not necessary for the requested service, but that allow and facilitate us to provide you with better care:

 

1. Marketing. Nawwa Galería may use the collected data to market our services to users. This includes sending communications to users about Sala Nawwa services, features, promos, sweepstakes, studies, surveys, news, updates, and events.

 

2. Non-commercial communications. Nawwa Galería may use the data we collect to generate and provide user receipts, inform them of changes to our terms, services, or policies, or send other communications that are not intended to market Nawwa Galería products or services or of its Artists.

 

3. Procedures and legal requirements. We may use the personal data we collect to investigate or resolve complaints or disputes related to the use of Nawwa Galería services, or as permitted by current law, or if requested by regulatory bodies, government entities and official investigations.

 

In case you do not want your personal data to be processed for these additional purposes, from this moment you can communicate the above, by sending an email to aalvarez@nawwa.mx, with the heading title "I OPPOSE TO THE USE OF MY PERSONAL DATA FOR ADDITIONAL PURPOSES "

 

The refusal to use your personal data for these purposes may not be a reason for us to deny you the services and products that you request or contract with us.

 

What personal data will we use for these purposes?

 

To carry out the purposes described in this privacy notice, we will use the following personal data:

 

1. Data provided by users. This includes the following:

 

• User profile: We collect the data generated when users create or update their Nawwa Galería accounts, which may include their name, email, phone number, username and password, address, profile picture, payment details or bank, government identification documents, date of birth, signature and photo. Artist information and user settings are also included. We can use the photos sent by the Artists to verify their identities, using technologies such as facial recognition.

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• Demographic data: We may collect demographic information about users, including through surveys intended for them.

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• User Content: We collect information that users submit when they contact Nawwa Galería customer support or contact Nawwa Galería in some other way. This may include comments, photos, or other recordings collected by users.

 

2. Data created during the use of our services. This includes the following:

 

• Location data: If the user allows it, we collect accurate or approximate location data from your mobile device. Users and customers can use Nawwa Galería apps without allowing location data to be collected from their mobile devices. However, this may affect some available features, such as personalized recommendations.

 

• Transaction information: We collect data on transactions related to the use of our services, which includes the type of work requested, details of the operation, date and time of the operation, total amount of the operation and payment method.

 

3. Data from other sources. This includes the following:

 

• User comments, ratings, opinions, or acknowledgments.

• Providers that help us verify the identity of users, background information and compliance with the requirements to work for regulatory and security purposes.

• Publicly available sources.

• Marketing service providers.

 

With whom do we share your personal information and for what purposes?

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We inform you that your personal data will NOT be shared with any other individual or legal entity inside or outside the country. Your data will always remain in the possession of Nawwa Galería.

 

How can you access, rectify or cancel your personal data, or oppose its use?

 

You have the right to know what personal data we have about you, what we use it for and the conditions of use that we give it (Access). Likewise, it is your right to request the correction of your personal information if it is outdated, inaccurate or incomplete (Rectification); that we delete it from our records or databases when it considers that it is not being used in accordance with the principles, duties and obligations provided for in the regulations (Cancellation); as well as oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

 

To exercise any of the ARCO rights, you must submit the respective request at aalvarez@nawwa.mx.

 

To know the procedure and requirements for the exercise of ARCO rights, you can call the following telephone number +52 (55) 5536-6317; enter our website www.nawwa.mx to the Nawwa Galería section, or contact our Privacy Department, which will process requests for the exercise of these rights, and will answer any questions you may have regarding the treatment of your information.

 

The contact details of the Privacy Department are the following: Responsible for the use and protection of your personal data; Mr. Alan Daniel Álvarez Tostado Corona with email aalvarez@nawwa.mx.

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How can you revoke your consent to the use of your personal data?

 

You can revoke the consent that, where appropriate, you have given us for the processing of your personal data. However, it is important that you bear in mind that not in all cases we will be able to respond to your request or terminate the use immediately, since it is possible that due to some legal obligation we will need to continue treating your personal data. Likewise, you should consider that for certain purposes, the revocation of your consent will imply that we cannot continue to provide the service you requested, or the conclusion of your relationship with us.

 

To revoke your consent, you must submit your request to: aalvarez@nawwa.mx

 

To know the procedure and requirements for the revocation of consent, you can call the following telephone number +52 (55) 5536-6317; enter our site at www.nawwa.mx to the Nawwa Galería section, or contact our Privacy Department.

 

How can you limit the use or disclosure of your personal information?

 

In order for you to limit the use and disclosure of your personal information, we offer you the following means:

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• Your registration in the Public Registry to Avoid Advertising, which is in charge of the “Procuraduría Federal del Consumidor” (PROFECO), so that your personal data is not used to receive advertising or promotions from goods or services companies. For more information on this registry, you can consult the PROFECO Internet portal; https://www.gob.mx/profeco, or contact it directly.

• Your registration in the exclusion list, so that your personal data is not processed for marketing, advertising or commercial prospecting purposes on our part. For more information, call the telephone number +52 (55) 5536-6317, send an email to the following address aalvarez@nawwa.mx, or consult our website www.nawwa.mx.

 

4. The use of tracking technologies on our Internet portal:

 

Nawwa Galería and its artists use cookies and other identification technologies in apps, websites, emails and online advertisements for the purposes described in this notice.

 

Cookies are small text files that websites, apps, online media, and advertisements store in the browser or on the device. Nawwa Galería uses cookies and similar technologies for the purposes listed below:

 

• Authenticate users.

• Remember user preferences and settings.

• Determine the popularity of the content.

• Provide and measure the effectiveness of advertising campaigns.

• Analyze site traffic and trends to understand online behaviors and interests of people who interact with our services.

 

We may also allow third parties to perform audience measurements and analytical services for us, serve ads on our behalf across the internet, and track and report to us on the performance of these ads. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices people use when they visit our site, as well as when they enter other sites and services online.