In order to comply with the provisions of the Federal Law for the Protection of Data in Possession of (Held By) Private Companies or Individuals, its Regulations and applicable Guidelines (the "Law"), Tecnologías LC 42, S.A.P.I. de C.V., ("Ridian"), with address located at Pedregal 24, Interior 300, Colonia Molino del Rey, Delegación Miguel Hidalgo, Zip Code 11040, Mexico City, Mexico (the "Address"), email address: https://ridian.io/ (the "Site"), owner of the rights of the digital platform called "Ridian" (the "Platform") and other present and future platforms of its property, and with contact email support@ridian.io (the "Email"), hereby makes this document available to you:

 

DATA PRIVACY NOTICE

In order to provide a lawful, controlled and informed treatment to the personal data of users of the Site and the Platform (the "Users") and Users who decide to create an account and hire any of the services of Ridian (the "Customers"), as well as to ensure their privacy and their right to informational self-determination when providing such data, we inform you that Ridian is responsible for the processing and protection of your personal data which will be treated based on the principles of legality, consent, information, quality, purpose, loyalty, proportionality and accountability provided by law. 

When Ridian must treat the personal data of Users and Customers through its holding companies and / or affiliates and / or subsidiaries and / or related parties (the "Related Third Parties") and / or those third parties who, by the business relationship with Ridian have contracted the use of the Platform to complement its business proposal, always will inform them of the contents of this Privacy Notice.

 

PERSONAL DATA COLLECTED BY US

Ridian requests and obtains the personal data of its Users and Customers (hereinafter "Personal Data") through access, registration, and creation of User profile on the Site and / or the Platform, and / or by email, and / or by completing forms or physical or electronic surveys, as appropriate to the services. 

In all cases, the collection of Personal Data by Ridian is done in good faith and for the purposes set forth herein; therefore, it is presumed that the Personal Data provided by its owners are true and complete, so they are the responsibility of the owner who provides them.

  1. The only Personal Data that will be collected from Users when they make use of the Site and/or the Platform consists of their IP Address (Internet Protocol) of their electronic device and the URL from which the Users' searches come from (whether or not they are on the Site), which URL they access next (whether or not they are on the Site), which browser they are using, the pages visited, the searches performed, the publications carried out, the commercial preferences expressed and the messages published.
  2. The Personal Data that will be collected from Customers in order to provide the services available on the Site and/or on the Platform (the "Services") consists of the following:
  1. Full name;
  2. E-mail address;
  3. Mobile and/or home telephone number;
  4. Physical address;
  5. The contents of your official identification;
  6. Client’s Application Programming Interface (API) information; 
  7. Details of your bank account(s);
  8. IP (Internet Protocol) address of your electronic device;
  9. URL from which Customers' searches originate (whether or not they are on the Site), which URLs they then access (whether or not they are on the Site), which browser they are using, the pages visited, the searches performed, the publications made, the commercial preferences expressed, and the messages published.
  10. Unique Identifier (UID) number assigned by your Cryptocurrency Exchange to your account. 

We also inform you that we do not collect sensitive Personal Data from Users or Customers.

 

PURPOSES OF THE PROCESSING OF PERSONAL DATA

 

FROM USERS

  1. To consolidate the list of procedures and Services offered by Ridian to Users in connection with its business partners through the Platform.
  2. To help diagnose problems with the Site and the Platform and to solve them.
  3. To fully comply with applicable laws, regulations and guidelines, internal policies, procedures, and legal obligations applicable to Ridian, the Site, and the Platform.

 

FROM CUSTOMERS

Once a User decides to engage any of the Ridian Services, it will automatically become a Customer and Ridian will treat your Personal Data to carry out the following purposes that give rise to and are necessary for the existence, maintenance, and fulfillment of the legal relationship between the two:

  1. To create your profile and account as a "Customer".
  2. To register the relationship between the parties, the process of use and selection made or to be made by the Client of the modules that make up the Platform Services.
  3. To create a record of the Clients and the Services they use, manage, or operate through the Platform.
  4. To provide the Services directly or through its Related Third Parties or through those third parties who, by the business relationship they have with Ridian, have contracted the use of the Platform to complement their business proposal.
  5. To build the list of procedures and services offered by Ridian to the Customer in connection with its business partners through the Platform.
  6. To keep track and monitor the commercial and legal relationship that exists with Ridian's business partners that offer Services on the Platform to the Customer.
  7. To communicate with Customers. 
  8. To help diagnose problems with the Site and the Platform and resolve them.
  9. To comply fully with applicable laws, regulations and guidelines, internal policies, procedures, and legal obligations applicable to Ridian, the Site and the Platform.

 

BOTH FROM USERS AND CUSTOMERS

If you do not oppose this data processing, Ridian may process your Personal Data to carry out any or all of the secondary purposes mentioned below:

  1. To generate data indicators and for Ridian to make decisions relevant to its business.
  2. To improve, develop and enhance the Services.
  3. To make use of "push" technology through the application that Ridian uses to send notifications with prior authorization of the User or Customer.
  4. For marketing, advertising, or commercial prospecting purposes. 

It is important to mention that Ridian will only use your Personal Data for the secondary purposes previously described if you consented to them. In case you do not want your Personal Data to be used for these secondary purposes, please send an e-mail to the following e-mail address: support@ridian.io indicating your refusal for the use of your Personal Data for the secondary purpose(s) you wish to limit. If you do not express your refusal for the processing of your Personal Data in accordance with the above, it will be understood that you have given your consent for the processing of your Personal Data.

The refusal to use your Personal Data for the above purposes will not be a reason for us to deny you the Services you request or contract with Ridian on the Site and the Platform.

Once the purposes of the processing of your Personal Data have been fulfilled, and when there is no legal provision to the contrary, Ridian will proceed to the cancellation, elimination and/or destruction of the Personal Data obtained, under the terms established by law.

 

USE OF COOKIES AND SIMILAR TECHNOLOGIES

Ridian informs you that, through the use of technologies, it seeks to ensure the best possible experience on the Site and/or the Platform by providing you with personalized information, remembering your Services and marketing preferences and helping you to obtain the appropriate information.  Based on the above, Ridian informs you that it collects Personal Data through cookies and web beacons (sometimes referred to as "tracking pixels" or "clear GIFs").

 

COOKIES

Cookies are data files that are stored on the hard drive of a user's computer or electronic communications device when browsing a specific website, which allow status information to be exchanged between that site and the user's browser. The status information may reveal ways of identifying the user's session, authentication, or preferences, as well as any data stored by the browser with respect to the website.

Ridian and its service providers may use one or more types of cookies, below described as:

I. Essential cookies. Required to improve the functionality of the Site and Platform, enabling the User and Customer to navigate the Site and Platform and make use of its features (for example, to allow you to log in to secure areas of the Site or use a shopping cart on the Platform). Disabling these cookies will result in hindering the performance of the Site and Platform, and possibly render the features of the Site, Platform, and its Services unavailable.

II. Analytics and personalization cookies. Designed to analyze User and Customer activity on the Site and/or on sites where Ridian publishes or promotes content, which are used to ensure that the User and Customer can find the information they are looking for on the Site more easily. These cookies allow the recognition and registration of visitors to the Site, as well as the measurement of the performance of advertising campaigns and optimization of the content of the Site by Ridian.

III. Functionality Cookies. Used to recognize the User and Customer when they enter or return to the Site or Platform, by personalizing content, use of the name registered as a customer and particular language or regional preferences.

IV. Advertising Cookies. These cookies are used for the purpose of highlighting Site content that is most relevant to the User and Customer, based on apparent interests collected based on their online activity, including visits to the Site and Platform, pages visited and selection of links and advertisements. This allows, through the use of data management and editing platforms, advertisements to be linked on the Ridian-owned Site or any other site, in order to maintain an ongoing promotion of the products and services visited on the Site.

 

WEB BEACONS

Web beacons are very small graphic files that contain a unique identifier that makes it possible to recognize the visit to the Site and Platform or notify Ridian when the Customer opens an e-mail that has been sent by Ridian. Generally, these technologies rely on cookies to function properly, so disabling them directly affects their functioning.

These technologies may be disabled in accordance with the settings on the use of cookies in the browser or Internet service you use. Notwithstanding the foregoing, we inform you that the blocking by the User or the Client of all cookies may cause the total or partial blocking or impairment in the access and use of the Site and the Platform.

 

TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred to fulfill the purposes set forth in this Privacy Notice, only to: (i) related third parties and / or business partners of Ridian; (ii) Mexican and foreign judicial authorities, in order to comply with the Law applicable to Ridian, the Site and the Platform, notifications, requirements or judicial offices; (iii) to Internet service providers on which Ridian technological infrastructure is established; and / or (iv) to technical support service providers of the Platform. In case of any transfer of your Personal Data, in which your consent is required, we will inform you in order to obtain it.

In all cases, Ridian will communicate this Privacy Notice to these third parties and will ensure through the signing of agreements and / or the adoption of other binding documents, that such third parties maintain the necessary administrative, technical and physical security measures to safeguard your Personal Data, and that such third parties only use your Personal Data for the purposes for which they were collected. 

Ridian will not transfer your Personal Data to third parties unrelated to Ridian, without your prior consent.

 

PROCEDURES AND METHODS FOR THE EXERCISE OF YOUR ARCO RIGHTS

You, as the owner of the Personal Data provided to Ridian, may request at any time, the exercise of your rights of Access, Rectification, Cancellation or Opposition (the "ARCO Rights") of your Personal Data, consisting of: (i) access your Personal Data and the details of the processing thereof; (ii) rectify your Personal Data if it is inaccurate or incomplete; (iii) cancel your Personal Data when you consider that it is not required for any of the purposes stated in this Privacy Notice, is being used for non-consensual purposes or has terminated its contractual or service or other relationship with Ridian; and (iv) oppose the processing of your Personal Data for specific purposes.

To do so, you must follow the process of submitting your request in writing at Ridian's Address, or by sending your request to Email, as applicable, which must contain, at a minimum, the following information: (a) your full name and address, or other suitable way to communicate the response to your request; (b) documents proving your identity or, if applicable, that of your legal representative; (c) a clear and precise description of the Personal Data with respect to which you seek to exercise any of the aforementioned rights; and (d) any other element or information that facilitates the location of the Personal Data, as well as any other document required by the current regulation at the time of submitting the request. You may also request further information about the procedure to exercise your ARCO Rights by e-mail.

Ridian will respond to your request and resolve it within the terms and deadlines set forth in the Law. However, you may obtain more information about the status of your request and the deadline for responding to it, by contacting Ridian or sending your request to the Email, where they can also address any questions or concerns you may have regarding the processing of your Personal Data and the exercise of your ARCO Rights.

 

REVOCATION OF CONSENT; LIMITATION OF USE AND/OR DISCLOSURE OF PERSONAL DATA

You may also revoke, at any time, the consent you have given to Ridian for the processing of your Personal Data, as well as request to limit the use and disclosure of the same, provided that it is not prohibited by a legal provision and / or your request is not appropriate in terms of the Law. For this purpose, you must submit your request in writing to Ridian's Address, or send your request to the Email, as applicable. Such request must comply with the same requirements mentioned in the previous Section.

Ridian will respond to your request and resolve it within the terms and time limits set forth in the Law. However, you may obtain more information about the status of your request and the deadline for responding to it, by contacting Ridian or sending your request to the Email, where they can also attend to any clarification or questions you may have regarding the treatment and these rights that apply to you with respect to your Personal Data.

In the event that your Personal Data had been submitted prior to the date of revocation of consent, and continue to be processed by employees Ridian, it will inform the latter of such revocation, so that they proceed to make the appropriate action.

 

CHANGES TO THE PRIVACY NOTICE

Ridian reserves the right to modify and / or update this Privacy Notice, in any or all of its parts, at its sole discretion, in which case it will communicate through its Site and / or Platform. In addition, Ridian will post a notice in a visible location at the Domicile.

 

LANGUAGE

This privacy notice is made available to users and/or customers in English and Spanish for reference purposes. In the event of any conflict, the Spanish version available on the Platform shall prevail.

 

First Issuance Date: November 10, 2021

Last Updated Date: June 1, 2023