Privacy Policy

PRIVACY NOTICE regarding the personal information collected by ETON, S.C. and/or other companies belonging to the same group as ETON S.C. (hereinafter known as “ETON SCHOOL”).

1. -General

1.1.- ETON SCHOOL is a civil society committed to respecting individuals’ rights regarding their personal information, which are acknowledged in Article 16, paragraph II, of the Political Constitution of the Mexican United States, as well as in the provisions of the international treaties Mexico is a part of and the Federal Act for the Protection of Personal Information Guarded by Individuals or Private Institutions (Ley Federal de Protección de Datos Personales en Posesión de los Particulares), its corresponding regulations, and other applicable law. Therefore, ETON SCHOOL makes this Privacy Notice available so that THE RIGHT HOLDER whose information is guarded will be able to exercise their right to informational self-determination.

1.2.- When THE RIGHT HOLDER accesses and browses the “Privacy Notice” section of the websites www.eton.edu.mx and https://eo.eton.edu.mx, which are property of ETON SCHOOL and will hereinafter be collectively known as “THE WEBSITES,” and when they personally and directly provide their personal information, in writing or on the phone, they (THE RIGHT HOLDER) acknowledge that they understand and agree with the terms and conditions of this Privacy Notice and declare and give express acceptance and consent using the electronic means stipulated in Article 1803 of the Mexican Civil Code.

1.3.- If THE RIGHT HOLDER does not fully and absolutely accept the terms and conditions of this Privacy Notice, they must refrain from sharing any information with ETON SCHOOL through any means, including its websites.

1.4.- If THE RIGHT HOLDER continues to use ETON SCHOOL’s WEBSITES, either wholly or partially, this action will be considered their full and express acceptance of the terms and conditions provided herein.

1.5.- The mere use of ETON SCHOOL’s WEBSITES makes the user a right holder (hereinafter, the “RIGHT HOLDER” or “RIGHT HOLDERS”), and it implies full and unconditional acceptance of all the general and specific conditions included in the version of this Privacy Notice published by ETON SCHOOL at the moment THE RIGHT HOLDER accesses the aforementioned websites.

1.6.- THE RIGHT HOLDER acknowledges and accepts that ETON SCHOOL's WEBSITES may have links to third party websites in which ETON SCHOOL has no responsibility or obligation over the handling of personal information they do, and any questions should be directed to their respective data managers.

The parties hereby declare that, as there is no error, dolus, mala fides, or anything else that could affect or void the validity of this document, they both agree to be bound by the provisions of the following:


2. -Definitions

2.1.- Personal information.- Any information related to an individual that is, or can be, identified.

2.2.- Sensitive personal information.- Personal information that affects the private life of THE RIGHT HOLDER or that could cause discrimination or lead to risk for THE RIGHT HOLDER in case of misuse. Sensitive personal information, in particular, is considered that which could disclose aspects such as ethnic or racial origin, current or future state of health, genetic information, religious, philosophical, and moral beliefs, union affiliations, political opinions, and sexual orientation.

2.3.- Right Holder.- The individual (RIGHT HOLDER) who is identified by said personal information. In this Privacy Notice, it refers to current or prospective clients; any applying, past, and present students; and the individuals who have custody of students who are minors according to Mexican law, for whom


this document is made available and who are required to provide their express, written, and signed consent in the forms ETON SCHOOL provides and according to what is stipulated in applicable Mexican law.

2.4.- Keeper.- An individual or private entity (ETON SCHOOL) that decides how to manage personal information.

2.5.- Individual in charge.- An individual or entity that, by themselves or with others, manages personal information on behalf of the keeper.

2.6.- Management.- Collection, use (including access, handling, usage, transfer, and disposition of personal information), disclosure, or storage of personal information by any means.

2.6.1.- Transfer.- Any information communicated to an individual other than the keeper or individual in charge of handling personal information.

2.6.2.- Relay.- The communication of personal information between the keeper and the individual in charge, in Mexico or abroad.

2.7.- Third party.- A national or foreign individual or entity other than the keeper or individual in charge of the information.

2.8.- ARCO rights.- The right to Access, Rectify, Cancel, and Oppose.

2.9.- Tacit consent.- It will be assumed that the RIGHT HOLDER has consented to the management of their personal information when they do not expressly oppose after having received the Privacy Notice.

2.10.- Primary purposes.- The main purposes for which the personal information is requested, which create the relationship between ETON SCHOOL and the RIGHT HOLDER.

2.11.- Secondary purposes.- The purposes that are not essential for the relationship between ETON SCHOOL and the RIGHT HOLDER, but which exist to contribute to ETON SCHOOL's corporate purposes.

 

3.- Identity and Domicile of the Entity in Charge of Managing Personal Information

3.1.- The entity in charge of managing the RIGHT HOLDER’S personal information is ETON SCHOOL, who is committed to respecting the provisions of this Privacy Notice (hereinafter the “Notice” or the “Privacy Notice” interchangeably), which is made available according to the provisions of the Federal Act for the Protection of Personal Information Guarded by Individuals or Private Institutions (hereinafter the “Act” or “FAPPIGIPI” interchangeably). The Notice is applicable to the personal information of individuals such as clients or prospective clients, parents or legal guardians of potential, past, and present students, which ETON SCHOOL or other companies belonging to the same group as ETON, S.C. manages in order to impart the educational services in all grades and levels, including Early Childhood, Elementary, Middle School, and High School, as well as the counseling services in commercial and educational areas provided by ETON SCHOOL to Mexican customers, in Spanish and English.

3.2.- For effects of this Notice, the domicile of ETON SCHOOL is Av. Santa Lucía 220, colonia Prados de la Montaña, alcaldía Cuajimalpa de Morelos, CP 05619, Ciudad de México, México.

 

4.- Personal Information Subject to Management

4.1.- THE RIGHT HOLDER acknowledges and accepts that ETON SCHOOL will manage the following personal information, either directly or through individuals in charge, considering the relationship held with each RIGHT HOLDER:


4.1.1.- Clients and prospective clients:

General and identification information: full name, date and place of birth, age, sex, nationality, marital status, profession, official photo ID, images or photographs, voice, signature, digital signature and/or advanced digital signature, passport, and immigration documents in the case of foreign individuals.

Contact information: address (street, number, neighborhood, city, state, district or municipality, zip code), landline and mobile phone numbers, email, and emergency contacts.

Financial and tax information: TIN, credit or debit card information, and bank information (account number, wire code (Clabe), bank).

Student information: name, date of birth, nationality, sex, languages spoken, Unique Population Record Number (CURP), record of correspondence with ETON SCHOOL, previous and current state of health, blood type, medications taken, images or photographs, voice, people they live with, and immigration documents in the case of international students.

Family information: full name of whoever has custody of the student, images or photographs, voice, native language, address (street, number, neighborhood, city, state, municipality or district, zip code), landline and mobile phone numbers, email, nationality, Unique Population Record Number (CURP), date of birth, signature, digital signature and/or advanced digital signature, company where they work, sector, area, company website, profession, job title, office phone number, family doctor, emergency contacts, contacts for social activities and third party information (name of the person, home phone number, mobile phone number, office phone number, relationship to student, email), information for tax receipts (name or corporate name, tax residence, tax regime, TIN, email, phone number), copy of the immigration documents (in the case of foreign nationals), recommendation letters from other schools and Eton families, and a record of their correspondence with ETON SCHOOL. If the family has personal security, they will provide ETON SCHOOL with the full names, emails, and landline or mobile phone numbers of their security personnel. Likewise, if the family has a family doctor, they will provide ETON SCHOOL with the full name, specialty, and office and mobile phone numbers of the physician, as well as the family’s insurance company, policy number, and preferred hospital in the event of an emergency.

Information linked to the use of ETON SCHOOL's WEBSITES and related communications: details of visits to ETON SCHOOL's WEBSITES, including the use of any educational tool, and information obtained through cookies and other monitoring technologies, including IP address, browser and operating system, traffic data, location data, web logs and other communication data, resources accessed, and associated telemetry data.

In all instances where THE RIGHT HOLDER provides ETON SCHOOL with a third party's personal information, they declare, under penalty of perjury, that they have consent from said third party to share their personal information with ETON SCHOOL, and they agree to protect ETON SCHOOL from any controversy or claim caused by the unauthorized use of the third party’s personal information.

Trust Fund information: student's economic support provider’s personal information (full name, date of birth, address (street, number, neighborhood, city, state, district or municipality, zip code)) and the percentage of tuition covered by said economic support provider.

Academic information: official SEP/UNAM report cards and letters of good conduct and good economic standing from the student’s previous school.

If the RIGHT HOLDER hires the services provided by ETON SCHOOL for a third party, THE RIGHT


HOLDER must get the third party’s consent before providing their personal information to ETON SCHOOL. If the third party is a minor, i.e., a student, according to current Mexican legislation, the RIGHT HOLDER declares, under penalty of perjury, that they are legally allowed to provide the minor’s personal information to ETON SCHOOL and to accept this Privacy Notice, agreeing to keep ETON SCHOOL safe from any claims that may arise from the unauthorized use of the personal information of third parties and minors.

ETON SCHOOL declares that it will be able to manage a student’s sensitive personal information, such as past and present health information, to take care of health conditions they may present while receiving the educational services, and, per Article 9 of the FAPPIGIPI, the RIGHT HOLDER-Client will be required to give their express, written, and signed consent to authorize the management of this information, using the corresponding forms.

Copies of the following documents: official photo ID, TIN, proof of residence, front page of a bank statement, previous SEP/UNAM report cards, letter of good conduct from the student’s previous school, and recommendation letter from an Eton family.

4.2.- The RIGHT HOLDER hereby gives their express consent, per Article 8 of the of the FAPPIGIPI, for ETON SCHOOL to manage their personal information, including the financial and asset information listed in this clause, to comply with the purposes stated in this Privacy Notice.

4.3.- The RIGHT HOLDER hereby accepts, under penalty of perjury, that the information they provided to ETON SCHOOL is true, correct, and up to date. Additionally, they agree to keep ETON SCHOOL safe from any claims that may arise from errors in said information.

4.4.- ETON SCHOOL declares that it will manage the personal information of minors, i.e., students, and will collect the consent and authorization from said minors’ parents or legal guardians, according to the applicable Mexican legislation, using the corresponding forms provided to the RIGHT HOLDERS.

4.5.- ETON SCHOOL declares that it can manage the RIGHT HOLDERS’ sensitive personal information according to what is stipulated in this Privacy Notice and, per Article 9 of the FAPPIGIPI, it will collect for this purpose the express, written, and signed consent of the RIGHT HOLDERS using the corresponding forms.

4.6.- ETON SCHOOL declares that it can collect the RIGHT HOLDER’s personal information through public access sources in order to verify and update the RIGHT HOLDER’S information, respecting at all times the reasonable privacy expectations of Article 7 of the FAPPIGIPI.

 

4.7.- ETON SCHOOL will use IP (Internet Protocol) information to analyze any threat to ETON SCHOOL’s WEBSITES and to collect demographic information. However, the IP information will not be used, under any circumstances, to identify the RIGHT HOLDERS, except in the case of probable fraudulent activity.

 

5.- Purposes of Managing Personal Information

5.1.- ETON SCHOOL accepts and acknowledges that it will manage the RIGHT HOLDER’s personal information, directly or through the individuals in charge, manually or digitally (including through learning tools that may use technology like automated learning), according to the type of relationship it has with the RIGHT HOLDER, for the following primary purposes:

5.1.1.- THE RIGHT HOLDER-Client or Prospective Client:

  1. Contact the RIGHT HOLDER-Client by phone, email, social media, or any other means to respond to and follow up on requests made about products and services provided by ETON SCHOOL.
  2. Provide the RIGHT HOLDER-Client with educational services offered by ETON SCHOOL,

including the school bus service, according to requests made through any means, so that the RIGHT HOLDER-Client can receive said offered products and services, as well as select and enroll students and manage student academic and extra-curricular schedules. Additionally, to know the identity of third parties authorized by parents or guardians to pick up minors from campus.

  1. For the RIGHT HOLDER-Client to digitally sign, with any form of digital signature and/or advanced digital signature and using any type of platform, all the documents ETON SCHOOL requires to provide its services as a legally binding means of consent, in compliance with the applicable Mexican laws.
  2. Contact the RIGHT HOLDER-Client by any means, to make clarifications and follow up on payments or any other situations related to the products and services provided by ETON SCHOOL, such as complaints or comments about said products and services.
  3. Input and update information in the internal company administration system for authorized individuals to access personal information.
  4. Contact the RIGHT HOLDER-Client to manage and collect debts, as well as analyze matters related to additional charges for lack of payments, and, if applicable, contact the individuals the RIGHT HOLDER-Client appointed as contacts for payment purposes.
  5. Contact the RIGHT HOLDER-Client to inform them about a student's academic standing.
  6. Manage a student’s sensitive personal information, such as their past and present health information, to take care of health conditions they may present while receiving the educational services provided by ETON SCHOOL, and, if applicable, to conduct the work that ETON SCHOOL’s Psychopedagogy Department recommends be done with the RIGHT HOLDER-Client or the student. The RIGHT HOLDER-Client will sign the forms provided by ETON SCHOOL for this purpose, in which the RIGHT HOLDER-Client provides their express, written, and signed consent. This sensitive personal information will be managed by ETON SCHOOL for 5-five years after its collection.
  7. Manage a student’s sensitive personal information, such as their past and present health information, so ETON SCHOOL’s health care providers may administer to students the medications the RIGHT HOLDER-Client indicates to ETON SCHOOL using the forms it provides for such purpose, which the RIGHT HOLDER-Client signs to give their express, written, and signed consent. This sensitive personal information will be managed by ETON SCHOOL for 5-five years after its collection.
  8. Send information or invitations to courses, workshops, camps, excursions, field trips, training sessions, and community events held by ETON SCHOOL, as well as to attend (students) Psychopedagogy Department workshops.
  9. Evaluate scholarship applications filed by the RIGHT HOLDER-Client.
  10. Assign the RIGHT HOLDER-Client email accounts with the ETON SCHOOL domain and provide them access to the ETON SCHOOL electronic platforms and communication networks. The RIGHT HOLDER-Client's email accounts will be active for the duration of the commercial relationship between them and ETON SCHOOL and will be deleted, along with the content stored there, when the contractual relationship with ETON SCHOOL ends.
  11. Distribute documents and certificates issued by the Ministry of Public Education (Secretaría de Educación Pública), comply with the requirements imposed by this or any other government authority, and complete any necessary processes.
  12. Compile and keep physical records of the RIGHT HOLDER-Client for the duration of the commercial relationship and up to 5-five years after the relationship ends in the case of parents or legal guardians and prospective clients, and for 5-five years in the case of parents or legal

guardians that request tuition discounts or scholarships from ETON SCHOOL. Regarding students, their academic information such as full name, birth certificate, Unique Population Record Number (CURP), report cards, student ID number registered with the public authorities, and exam results, will be kept for as long as ETON SCHOOL remains in operation, as the Ministry of Public Education and the National Autonomous University of Mexico require said records to be delivered to students at the time ETON SCHOOL shuts down for good. The RIGHT HOLDER- Client’s electronic files will be kept for as long as ETON SCHOOL remains in operation.

  1. Issue electronic invoices and credit notes for the products or services that ETON SCHOOL sells. These invoices, both electronic and hard copy, as well as the credit notes, will be kept by ETON SCHOOL for the duration of the contractual relationship and for 10-ten years after the relationship ends.
  2. Schedule meetings with the RIGHT HOLDER-Client by phone, email, social media, Skype, or any other means, whether physical or digital.
  3. Complete transactions with credit institutions as a result of commercial operations.
  4. Record image and/or audio of the RIGHT HOLDER-Client, students, parents, or family members, in the CCTV cameras when inside ETON SCHOOL facilities, as well as when videotaping the inside of classrooms. Images and sounds caught by ETON SCHOOL’s security system will be used to ensure the safety of the RIGHT HOLDER-Employee and the staff, parents, students, and/or other individuals visiting the ETON SCHOOL facilities, keeping track of the entrances and exits of the individuals inside said facilities. The RIGHT HOLDER-Client’s image and audio will be kept by ETON SCHOOL for 14-fourteen calendar days after the footage was obtained.
  5. Likewise, image and audio of the RIGHT HOLDER-Client, students, parents, and/or family members will be managed by ETON SCHOOL to teach in classes, workshops, and/or tutoring sessions, whether the RIGHT HOLDERS attend them using electronic tools and platforms, applications for smartphones and/or tablets, in real time or through pre-recorded classes, workshops, and/or tutoring sessions recorded with electronic devices owned and/or developed by ETON SCHOOL or third parties. The RIGHT HOLDER-Client’s personal information will be kept by ETON SCHOOL for 14-fourteen calendar days after it was obtained.
  6. Additionally, image and audio of the RIGHT HOLDER-Client, students, parents, and/or family members will be managed by ETON SCHOOL to publish photographs, video, audiovisual material, and other kinds of graphic materials (brochures, banners, etc.) of school life through different means, in both physical and digital formats, including social media platforms. Said image and audio will also be used for ETON SCHOOL’s advertisement and/or marketing activities, which can include photographs and video of students and parents. The RIGHT HOLDER-Client’s personal information will be kept by ETON SCHOOL for 10-ten years after it was obtained.
  7. Provide a safe and healthy environment for ETON SCHOOL students and staff.
  8. Support, develop, and improve the educational services provided by ETON SCHOOL, for which they will be able to analyze the RIGHT HOLDERS' pseudonymized personal data to gather information about the educational services, which allows ETON SCHOOL to understand and develop its study plan, as well as develop and improve its educational products (including its digital tools).
  9. Comply with legal or regulatory obligations or resolutions issued by the corresponding authorities when it is necessary to exercise or defend rights or to use against legal claims.

5.2.- ETON SCHOOL will be able to manage the RIGHT HOLDER’s personal information for the following

secondary purposes:

  1. For the RIGHT HOLDER-Client to evaluate the quality of the products and services rendered,

as well as the attention given to their comments or requests.

  1. To provide additional information, promotions, communications, new product launches, brand image changes, and informational and news bulletins.
  2. To inform via email about changes and new products or services related to those requested by the RIGHT HOLDER.
  3. To produce internal reports about engagement with the ETON SCHOOL WEBSITES.
  4. To send mass marketing emails, as well as emails with publicity or marketing purposes.
  5. To contact the RIGHT HOLDER-User to inform them about updates to the ETON SCHOOL WEBSITES, as well as to provide information and messages related to services, including important security updates.
  6. To complete drills and evacuations on ETON SCHOOL facilities.
  7. To send the RIGHT HOLDER-Client email greetings at the end of the year, as well as condolences in case any member of the school community passes away.
  8. To prepare statistical and marketing data.
  9. To publish materials related to school life through different means, both physically and electronically, including social media platforms.
  10. To process accident insurance reimbursement claims.

5.3.- If the RIGHT HOLDER does not want their personal information to be used for all or some of the secondary purposes outlined in section 5.2., they must send a request to controlescolar@eton.edu.mx to discard their personal information, specifying the purposes for which they do not want their personal information to be managed.

 

6.- Use of Cookies and Web Beacons

6.1.- ETON SCHOOL WEBSITES may use cookies for certain characteristics or functions. Cookies are specific types of information that a website transmits to the hard drive of the RIGHT HOLDER’s computer to keep records. Cookies might be used to facilitate the browsing of a website by saving passwords and preferences while the RIGHT HOLDER navigates the web. ETON SCHOOL WEBSITES do not use cookies to obtain personal identification information from the RIGHT HOLDER’s computer that was not originally sent as part of the cookie.

6.2.- Web beacons are images inserted into a website or email that may be used to monitor the visitor’s behavior, such as storing information about the user’s IP, interaction time on the website, and the type of browser used, among others.

6.3.- Even though most web browsers accept cookies and web beacons automatically, the RIGHT HOLDER may set up their browser to reject them.

6.4.- You can disable cookies by following the instructions below:

6.4.1.- On a PC: open the internet browser, access the “Tool” menu, click on “Internet Options,” choose the “Privacy” tab, and move the cursor to “Block Cookies.”

6.4.2.- On a Mac: open the internet browser, select “Preferences,” choose the option “Security,” then select “Never” in the option “Accept Cookies.”


 

7.- Personal Information Access and Disclosure Limitations

7.1.- ETON SCHOOL will protect, to the best of its ability, the integrity of the personal information provided by the RIGHT HOLDER through the implementation of legal acts, the use of technology to control access, the use or disclosure of personal information with no authorization, as well as the encryption of personal information subject to management, the use of SSL certificates on ETON SCHOOL WEBSITES, and the use of secure servers owned by ETON SCHOOL and its suppliers, as well as controlled access according to the ETON SCHOOL safety policies and standards. For this purpose, personal information is stored in limited-access databases located in facilities with security measures such as 24-hour surveillance and alarm systems in case of non-authorized access; ETON SCHOOL commits to managing the information provided by the RIGHT HOLDER as confidential and used under privacy terms.

7.2.- Accordingly, ETON SCHOOL will adopt all the necessary measures to guarantee that its individuals in charge will comply with this Privacy Notice, their obligations, and, particularly, the provisions of Article 50 of the FAPPIGIPI Regulations.

7.3.- Likewise, ETON SCHOOL is obliged to hire cloud services that will manage the RIGHT HOLDER’s personal information according to Article 52 of the FAPPIGIPI Regulations.

7.4.- Additionally, please be informed that, in order to avoid receiving publicity in general, you can register in the Public Record to Avoid Publicity (Registro Público para Evitar Publicidad). For further information, please refer to the Consumer Department (Profeco)’s website. Another way to limit the management of personal information is through the Public Record of Users of the National Commission to Defend Financial Service Users (Condusef).

7.5.- Regardless of the aforementioned information, and in the event of security breaches at any stage of management that can significantly affect the property or personal rights of the RIGHT HOLDERS, they will be informed immediately via email so that they can take the necessary measures to defend their rights, releasing ETON SCHOOL from any responsibility if it cannot be blamed for the breach.

 

8.- Individual Appointed to Process Requests

8.1.- If the RIGHT HOLDER needs to withdraw consent, as well as access, rectify, cancel, or oppose the management of the personal information they provided, they must go through the person appointed by ETON SCHOOL for such purpose, whose contact information is the following:

Appointed individual: María del Pilar Rodríguez Sordo

Email: controlescolar@eton.edu.mx


9.- Ways to Withdraw Consent

The personal information RIGHT HOLDER may withdraw the consent they provided through the acceptance of this Privacy Notice. The withdrawal of the consent given through electronic means must be executed following the process below and using the following form:

https://eo.eton.edu.mx/docs/ARCO_EN.pdf.

 

9.1.- Send an email to the individual appointed in item 8-eight of this Privacy Notice, who will process the request.

9.2.- Send a request or data message to the aforementioned email, attaching the following information


by way of the form provided by ETON SCHOOL in the previous paragraph or by means of a written request:

9.2.1.- The RIGHT HOLDER’s full name, address, and email where they want to receive the response to the request.

9.2.2.- The reason for the request.

9.2.3.- The arguments that substantiate the request.

9.2.4.- An official form of ID that corroborates who the RIGHT HOLDER says they are. If the request is made through a legal representative, also attach the ID of the legal representative and the proxy.

9.2.5.- The date when the revocation is to become effective.

9.2.6.- Attach the form indicated in this section to the email, signed by the RIGHT HOLDER or their legal representative.

9.3.- ETON SCHOOL will inform the RIGHT HOLDER of the petition resolution no more than 20-twenty days after the revocation request is received. If the request is granted, it will become effective within 15- days of the date the response is given by means of a message indicating that actions are being taken to stop managing the RIGHT HOLDER’s personal information.

 

10.- Means to Exercise ARCO rights

10.1.- If the RIGHT HOLDER needs to access, rectify, cancel, or oppose the personal information provided to ETON SCHOOL, the RIGHT HOLDER must complete the following process using the form: https://eo.eton.edu.mx/docs/ARCO_EN.pdf.

10.2.- Send an email to the appointed individual in item 8-eight of this Privacy Notice, attaching the form provided by ETON SCHOOL in the previous paragraph or a written request that includes the following:

10.2.1.- The RIGHT HOLDER’s full name, address, and email where they want to receive the response to the request.

10.2.2.- The reason for the request.

10.2.3.- Arguments that substantiate the request.

10.2.4.- An official form of ID that corroborates who the RIGHT HOLDER says they are. If the request is made through a legal representative, also attach the ID of the legal representative and the proxy.

10.2.5.- A clear and detailed description of the personal information subject to any ARCO right, as well as any other element or document that may help locate the personal information in question.

10.2.6.- In the case of requests to rectify personal information, the RIGHT HOLDER must indicate, along with the previous information, the changes to be made, as well as provide the documents required to support said request.

10.2.7.- Attach the form indicated in this section to the email, signed by the RIGHT HOLDER or their legal representative.

10.3.- ETON SCHOOL will inform the RIGHT HOLDER about the resolution to their access, rectification,


cancelation, or opposition request no more than 20-twenty days after it was filed. If the request is granted, it will become effective within 15-fifteen days of the date the response is given. In the case of personal information access requests, the information will be released when the petitioner or the legal representative prove their identity.

 

11.- Transfer of Personal Information

11.1.- ETON SCHOOL will not share or transfer the information described in this Privacy Notice to third parties, except if it is to achieve the purposes of this Privacy Notice or if it is necessary to comply with an authority’s order.

11.2.- Additionally, to comply with its legal obligations and keep the RIGHT HOLDER informed, ETON SCHOOL will transfer information as follows:

11.2.1.- To the Ministry of Public Education (SEP), to comply with the obligations imposed on ETON SCHOOL by this government authority.

11.2.2.- To the National Autonomous University of Mexico (UNAM), to comply with the affiliation obligations outlined in the corresponding regulations.

11.2.3.- To the Internal Revenue Service (SAT), to comply with tax laws and payments.

11.2.4.- To banks, to charge for products or services provided by ETON SCHOOL.

11.2.5.- To the companies within the ETON SCHOOL group, to provide the services offered by

ETON SCHOOL.


12.- Amendments

12.1.- The parties hereby agree that ETON SCHOOL may amend this Privacy Notice as it deems necessary according to present and future personal information protection acts, which is why it will keep this Privacy Notice updated and available on the ETON SCHOOL WEBSITES, as well as the Tell Me on Tuesdays newsletter, through which it will be shared with all the members of ETON SCHOOL’s educational community, so that, if applicable, the RIGHT HOLDER can exercise their ARCO rights.

 

13.- Guarantor Authority

13.1.- If the RIGHT HOLDER considers that their right to the protection of their personal information has been violated by an action or omission of ETON SCHOOL’s, or they think any provisions in the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions (Ley Federal de Protección de Datos Personales en Posesión de Particulares), its regulations, and other applicable law have been broken, they can file a claim with the National Institute for Transparency, Access to Information, and the Protection of Personal Information (INAI). For further information, please refer to their official website: www.inai.org.mx.

 

14.- Governing Law and Jurisdiction

14.1.- The parties hereby agree that this Privacy Notice will be governed by the applicable legal provisions in Mexico, especially by the provisions of the Federal Act for the Protection of Personal Information Guarded by Individuals and/or Private Institutions (Ley Federal de Protección de Datos Personales en Posesión de Particulares), its regulations, and other applicable law.


14.2.- In case of dispute or controversy regarding the interpretation, execution, or compliance with the Privacy Notice and any document derived from or related to it, the parties will seek an amicable settlement within 30-thirty calendar days of the date in which the grievance arises and is notified to the other party in writing, following the amicable settlement process at the Alternative Justice Center of Mexico City according to the Alternative Justice Act of the Superior Court of Justice of Mexico City and its internal regulations in effect at the time the controversy arises.

14.3.- If the parties cannot reach a settlement, they hereby agree to submit any matters regarding this Privacy Notice or any of the documents derived from or related to it, to be definitively resolved under the jurisdiction and laws of the federal administrative authorities or the courts of Mexico City, and they hereby expressly resign to any other jurisdiction that, by reason of their domiciles, present or future, may apply to them.

 

Version 3.6 [Last update: December 1, 2023]