This Privacy Notice regulates the use of Personal Data by S&M Nano-Biotechnology, S.A. de C.V., hereinafter referred to as “SANKI”, which address is located at Av. Constituyentes #908, Col. Lomas Altas, Delegación Miguel Hidalgo, C.P. 11950, Mexico City, as provided by the Federal Law for the Protection of Personal Data owned by Third Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the “Law”) and its corresponding Regulation rules.
SANKI limits its personal data collection to the information that is relevant for the purposes of such collection, whether collected directly or through a third party acting in our behalf, and always using legal and just methods to collect personal data, according to the applicable legal precepts which regulate personal data collection.
I.- Collected Data and Collection Methods.
SANKI processes your personal data, meaning such information with which you can be reasonably identified, and which can be composed by di_erent documents, whether in printed or digital format.
The personal data that is collected and/or used includes: name and last names; gender; date and place of birth; address and country of residence, whether it is a personal, workplace or taxpayer address; personal and/or workplace’s e-mail address, personal and/or workplace’s phone number; personal and/or workplace’s cellphone number; Federal Taxpayers Registry (Registro Federal de Contribuyentes) (RFC) identification code; Unique Population Registry’s Code (Clave Única de Registro de Población) (C.U.R.P.); PIN; Consumer’s Id Code (Clave de Consumidor); and signature.
SANKI may collect and use the information from your voters Id card and from your current passport.
SANKI could also collect and use your patrimonial and financial information, such as the information related to your bank account, your debit card, credit and/or checks accounts, and your credit behavior, which information is deemed as sensible data and for which we will require your express consent.
Likewise, SANKI collects and uses the name and last names, address and country of residence, whether it is personal, workplace or taxpayers address; personal and/or workplace’s e-mail address; personal and/or workplace’s phone number; personal or workplace’s cellphone number, of your Leader, Co-applicant or Beneficiary, as well as from your o_spring, grandchildren, and of your prospects.
The personal data above mentioned will allow SANKI to duly comply with its administrative, tax, civil and/or commercial obligations. Personal data is collected through: i) the use of e-mails; ii) telephonic communications with our authorized personnel; iii) you voluntary providing your personal data and information in interviews with our authorized SANKI sta_; iv) you voluntary providing your personal data and information through the dialogue windows of our web site http://myconnect.sankiglobal.com; and v) the use of public access sources and other kind of sources available in the market.
II._ PURPOSES OF DATA PROCESSING.
The corresponding personal data will be processed for purposes of:
- Verify clients’, distributors’ and prospects’ identity;
- Verify the personal information provided by you to SANKI;
- Enter into, if applicable, the corresponding purchase and or distribution agreements with you;
- Manage the commercial relation with you, if applicable, whether you become SANKI’s client and/or distributor, including managing the Auto-Delivery Plan, handle orders, and managing your payments and delivery of products at the corresponding address(ess).
- Process and manage invoices;
- Process payments of commissions, bonus and other incentives for distributors;
- Manage clients’ and/or distributors’ registration and deregistration in SANKI’s system;
- Include your information in SANK’s clients’ and distributors’ data base, and keep such data base up dated;
- Allow navigation in SANKI’s web site;
- Manage distributors’ performance and the performance of the members of their organization;
- Manage the distributors’ prizes and incentives system, including the Integral Wellness Program (Programa Integral de Bienestar) (IWP), the discounts program, and the pay out of bonus and other incentives such as voyages and cars;
- Manage the access passwords of SANKI’s distributors’ section on its on-line system;
- Participate in training programs and activities, SANKI’s certification programs and seminars, such as diploma courses, face-to-face and on-line training courses, regarding diverse subjects, such as the sales’ techniques and strategies for multi-level networks;
- Participate in national and international SANKI’s distributors’ conferences;
- Participate in events organized by SANKI, such as SANKI Summit, as well as in other events in which SANKI may be part of;
- Manage the newsletters and communications of SANKI’s community, whether they are in printed and/or digital format;
- Comply with applicable legal requirements; and
- Elaborate statistic information and commercial research.
The purposes mentioned in numbers 3 and 4 above, are necessary and therefore the legal relation between you and SANKI is thereto originated.
PERSONAL DATA COLLECTION WHILE BROWSING THROUGH SANKI’S WEB SITE: Among the diverse tools used by SANKI for automatic collection of data in its web site, there are “cookies”. “Cookies” should be enabled in your Internet navigator for SANKI’s web site to duly function. “Cookies” are small data files that are transferred from the web site to your computer’s hard drive while you browse through such web site. There may be temporal or permanent cookies.
Temporal cookies do not stay in your computer once you have closed the current web site session, meanwhile permanent cookies remain in your computer until they are eliminated or they expire. In most web navigators, cookies are automatically accepted due to its default configuration, you can adjust your navigator’s preferences with respect to the acceptance or rejection of cookies. Disabling cookies may disable diverse functions of SANKI’s web site or prevent that such functions are displayed correctly. In case you prefer to eliminate the information of the cookies sent by SANKI, you can eliminate the corresponding file(s) at the end of each navigator’s session. Relevant information may be consulted in the main Web navigators’ sites.
PROTECTION OF MINORS:
SANKI encourages parents and/or guardians to take an active role in on-line activities of the minors under their care. In the event SANKI deems that Personal Data has been provided by a minor, in violation to the provisions of this Privacy Notice, SANKI will eliminate such Personal Data as soon as possible. If you become aware of any Personal Data that has been shared by anyone under 18 years of age, please send an e-mail to the following e-mail address: firstname.lastname@example.org.
III. USE BY SANKI, COOKIES AND WEB SCREENING TECHNOLOGIES.
We also reserve the right to use external publicity companies to show commercial advertisements in our web sites. Such advertisements may contain cookies. The cookies that are received with those advertisements are gathered by such publicity companies and we do not have access to that information.
IV._ DATA TRANSFER.
SANKI informs you that for purposes of fulfilling its contractual, administrative, tax, civil and/or commercial obligations, it has entered into or will enter into diverse agreements with national and international suppliers, for the provision of di_erent kind of services that allow SANKI to undertake its activities in Mexico, provided that such suppliers are compelled to keep any personal data they might receive as confidential and to comply with all terms of this Privacy Notice. SANKI may transfer collected personal data, for its corporate management, to any of the companies pertaining to the
SANKI Group, which share internal processes and politics.
- HOW DOES SANKI GATHERS YOUR PERSONA INFORMATION.
When you open an account, you will be asked to provide your name, telephone number and e-mail address. In addition, some of the servers of the web sites, such as promotions, limited time o_ers and contests, may require your date of birth, gender, occupation, personal interests, etc. If you are a registered user, your contact information will be automatically saved.
SANKI may send you e-mails or postal services communications promoting products or events that, according to your preferences, might be of your interest, unless you expressly choose not to receive such communications. During your registry process, you may choose not to receive via e-mail any kind of requests from SANKI, submitting such requirement through SANKI’s o_cial web site and/or by contacting SANKI’s Call Center.
Whenever you purchase a product, you will be asked to provide your contact information, including your billing and delivery address, as well as your credit card information. Your credit card information will not be saved and cannot be accessed in SANKI’s data center nor in any of its files or registries. SANKI will keep a registry with the purchased products, the contact information of the recipient will be automatically saved in SANKI’s address log for its consultation. It is optional to provide the requested information, nevertheless, if you choose not to provide such information, you may not be able to purchase products or register to several services through SANKI’s web site.
In the event you sign up to SANKI’s mailing list (for e-mails or ordinary mail), you will be asked to provide us with your name, address, e-mail address and telephone number. You can choose to unsubscribe from such mailing list at any time. Any request to unsubscribe or to update your contact information can take up to 20 (twenty) days, for requests sent via e-mail, and from 6 (six) to 8 (eight) weeks for requests sent via ordinary post mail.
VI._ MEASURES TO PROTECT PERSONAL DATA.
Personal data processed by SANKI is protected by adequate administrative, technical and physical security measures that protect such data against damage, loss, variation, destruction or unauthorized use, access or processing, as provided by the Law and its corresponding Regulation rules.
VII._ MEASURES TO EXERCISE ARCO RIGHTS.
You have the right to access, rectify and cancel your personal data, as well as to oppose to the processing of such personal data, you can also revoke your consent granted to us for such purposes. You can also limit the use, disclosure or transference of your personal data, using the procedures that we have set up for such purposes. To know more about such procedures, requirements and deadlines, please contact our Personal Data Protection Department.
VIII._ PERSONAL DATA PROTECTION DEPARTMENT.
If you have any inquiry with respect to the protection of your personal data, please contact SANKI’s Personal Data Protection Department at: Av. Constituyentes #908, Col. Lomas Altas, C.P. 11950, Mexico City, Phone number: (+52-55) 1105-0785; or via e-mail at: email@example.com.
Unfortunately, unscrupulous people may pretend to act on behalf of SANKI, requesting you to provide them with your credit card information and/or other highly sensitive information, whenever SANKI becomes aware that someone or some company is using deceitful advertisements or any advertisement which leads to confusion, without SANKI’s previous authorization, SANKI will undertake the reasonable actions to put an end to such activity. The latter may take time and might be di_cult, or even impossible, to stop those activities. Therefore, you must take all necessary measures for your own protection.
For purposes of the abovementioned, you must be cautious when handling the personal data provided and such information must be saved in a safe place and should not be shared with anyone. Once you have finished browsing through any of the authorized SANKI’s web sites, you should close your account’s session and close the corresponding navigator’s window; this should prevent anyone from accessing your account and/or your personal data. This procedure is especially important if you share your computer with someone else or if you are using a computer from a public space, such as a library.
If you are SANKI’s Independent Distributor, Member or Client, it is possible that we will share your information with other SANKI’s Distributors, including without limitation and as part of a Linage Report that includes personal data, your name, contact information, level or rank, as well as sales and volume statistics of other SANKI Distributors and Members. The reports that are provided to Distributors are strictly confidential and are shared for the sole purpose of helping Distributors develop their SANKI business, including its use in diverse platforms and marketing tools.
We may share your personal information with Distributors to o_er you several products and services, such Distributors may, in turn, share your personal data, as provided in their own privacy policies. For example, if you use any of our o_cial web sites, your personal information may be shared with one or more Distributors. Likewise, we may share your personal information with any of the Distributors that work directly in the Sanki Stations and/or Sanki Lounges. We may also share your information with Distributors so that they can provide you with a more personalized experience, such as recommending products and services in which you could be more interested.
SANKI’s Distributors that receive your information must observe the terms provided in the corresponding Distribution Agreement entered into with us, as well as the personal data and privacy protection stipulations included thereto. Please note that, it is possible that some of this Distributors are located in countries in which the level of privacy protection is not equal or similar to the privacy protection terms of your own country.
XI._ CHANGES TO THE PRIVACY NOTICE.
SANKI can modify its privacy notice for purposes of making improvements, include new measures provided by the Law, its Regulation terms and other legal dispositions, therefore we suggest that you regularly consult its content in the corresponding section of the web site http://myconnect.sankiglobal.com.
As owner of your Personal Data, or as agent acting on behalf of the owner of such data, you provide your implicit consent for us to collect, process and transfer your personal information in the terms herein provided, as long as you do not object or oppose to the terms of this privacy notice within the 48 hours following the moment in which it was made available to you in our web site. For patrimonial, financial and/or other sensible information, SANKI will always request your express consent via electronic media.