1. Identity and address of the Responsible

5TORRES DESARROLLOS SA DE CV. with address in Calle Jesus Garcia 2427, PH Oficina 5, Colonia Lomas de Guevara, C.P. 44657, Guadalajara, Jalisco, México (hereinafter “Pardela”) in its capacity as the person responsible for the processing of personal data, makes this Privacy Notice available to you, as the owner, in compliance with the provisions of the Federal Law on Personal Data in Possession of Individuals (Ley Federal de Datos Personales en Posesión de los Particulares), its Regulations and the Guidelines of the Privacy Notice.

2. Personal Data

Pardela, in its capacity as Responsible Party, may collect one or more of the following Personal Data:

  1. Personal Data: name, home address, date of birth, age, nationality, CURP, RFC, telephone number (home phone or mobile), email, copy of official identification and copy of proof of address.
  2. Financial or property data. Information on bank accounts and credit cards, value and information regarding their properties, and any financial information that is necessary for the contractual relationship they have with the person in charge.

3. Primary Purposes of Data Processing

a. Users/Clients

In the case of users or clients who are natural persons of the services offered by Pardela, their personal data may be used for lodging or use in the properties determined by Pardela, for acquiring Pardela products and contracting any service provided by Pardela, as well as for sharing them with third parties that sell products or provide services related to the above. The information will be used for: (i) to identify and verify the identity of users or customers, (ii) to send information on the use of Property, accommodation, acquisition of products and/or contracting of the services offered, (iii) to deliver information on products and services, (iv) to show publicity and advertising of related products and services to the ones offered by Pardela, (v) address doubts, complaints and suggestions or any procedure related to the performance of services, (vi) process payments from users or customers in consideration of services provided and/or to purchase additional products and services, (vii) invoice payments by any means, (viii) notify the user of the receipt of offers through his account, (ix) make authorized online payments to Pardela by telephone or by any other means, and (x) request, contract, change or cancel services offered by Pardela or by third parties.

b. Owners

In the case of owners or holders of the Properties with whom Pardela intends to or has entered into a contract for the lease or use of the Properties, their personal data may be used for all purposes related to the performance of Pardela'sservices, including but not limited to (i) performing audits on the properties, (ii) preparing a catalogue of properties within a technology platform by means of a mobile application or through any other type, for the performance of services to users, (iii) reproducing photographs, videos, plans, diagrams, sketches, renders and any material of the properties, (iv) advertising and/or offering through any means the properties for rent or use, and (v) complying with regulatory obligations in charge of Pardela, including any obligation for the prevention of money laundering and financing of terrorism activities.

4. Secondary Purposes of Data Processing

We inform you that your Personal Data may be used for purposes that are not necessary for the performance of services, or have not given rise to the legal relationship of the Responsible Party, such as (i) offering promotions and events, (ii) conducting market research and analysis to learn the consumption preferences of our current or potential customers and to generate statistical reports, (iii) learning about consumption patterns or trends in the consumer segment of our products, (iv) receiving advertising in print or through electronic media, including communications for online marketing purposes or telemarketing about products and services, and (v) participating in surveys.

In case the Holder does not want the Holder’s Personal Data to be used for the Secondary Purposes described above, the User can communicate it through the following email: viaja@pardelanow.com

5.Sensitive Personal Data

The Responsible Party does not collect or process Sensitive Personal Data in the ordinary course of its business. If Sensitive Personal Data is collected and processed, such data shall be collected, maintained and processed with strict security and confidentiality for purposes related to the performance of services in accordance with this Privacy Notice and in compliance with the provisions of the Federal Law on Personal Data in Possession of Individuals.

6. Transfer of Personal Data

Having read, understood and agreed to the terms set forth in this Privacy Notice, the Data Subject agrees that the Responsible Party or any Officers may transfer Personal Data to any third party, whether domestic or foreign, provided that such third party's processing of the Data Subject's Personal Data shall comply with this Privacy Notice and shall be used for the primary and secondary purposes set forth in Sections 3 and 4 of this Privacy Notice.

For the purposes of the provisions of this Section 6, the Responsible Party informs the Holder that in order to deliver products, services and solutions to its customers, consumers, employees, suppliers and other users of its services, the Responsible Party and/or its Officers have concluded or will conclude various commercial agreements with suppliers of products and services, both in national territory and abroad, to provide, among other services, the services of (i) telecommunications and electronic mail, (ii) administration and management of databases, (iii) automated processing of Personal Data and its storage, (iv) “call center” for customer service, (v) authentication and validation of emails, and (vi) telemarketing, credit card terminals and electronic billing. The authorization of the Data Subject granted in accordance with this Section 6 gives authority to the Responsible Party and/or its Officers to transmit the Data Subject's Personal Data to such suppliers or third parties, provided that such suppliers or third parties are obliged, by virtue of the corresponding contract, to maintain the confidentiality of the Personal Data provided by the Responsible Party and/or its Officers and to observe this Privacy Notice. The Responsible Party and/or its Officers may transfer the Personal Data collected from the Data Subject to any other company of the same business group to which the Responsible Party belongs and which operates with the same processes and internal policies.

Notwithstanding the provisions of this Section 6 or any other Section of this Privacy Notice, the Data Subject acknowledges and accepts that the Responsible Party does not require authorization or confirmation from such Data Subject to carry out transfers of national or international Personal Data in the cases provided for in Article 37 of the Federal Law of Personal Data in Possession of Individuals (Ley Federal de Datos Personales en Posesión de los Particulares) or in any other case of exception provided for therein, its Regulations or the Guidelines.

In the event that the Data Subjects do not wish the Responsible Party to transfer their Personal Data, they may express their refusal by addressing a communication to the Controller at the following email address: viaja@pardelanow.com

7. Limitation of use and disclosure

To prevent unauthorized access to your personal information and to ensure that it is used for the purposes outlined in this Privacy Notice, we have put in place appropriate physical, electronic, and managerial procedures to limit the use or disclosure of your information and to enable us to treat it appropriately. In addition, your personal data will be treated exclusively by those persons who carry out activities that require the knowledge of such data.

We inform you that your Personal Data will be safeguarded at all times under the highest security standards, guaranteeing at all times, the strictest confidentiality and privacy of the same.

At any time, the Holder may limit the use and disclosure of the Holder’s Personal Data by sending an email to the following address: viaja@pardelanow.com

At the same time, in order to limit the use and disclosure of the Personal Data, you may additionally register with the Public Registry to Avoid Advertising or Public Registry of the Consumer (Registro Público para Evitar Publicidad o Registro Público del Consumidor), which is in charge of the Federal Consumer Protection Office (Procuraduría Federal del Consumidor), which has the purpose that the Personal Data is not used to receive advertising or promotions by the companies of the telecommunications, tourism and commerce sectors, in their marketing practices. For further information about this registration, the owner can consult the PROFECO's website.

8. ARCO Rights

You have the right at all times to access, rectify, cancel or oppose the treatment we give to your personal data (the “ARCO Rights”), as well as to revoke the consent given for the treatment of the same; a right which you may exercise through the Special Unit for the Protection of Personal Data of Pardela, whose details appear below. It is important that although the exercise of your ARCO Rights is free of charge, Pardela may charge you for justified shipping costs and reproduction costs.

This request must contain at least your name, full address or other means of communicating the answer to your request, documents proving your identity and specifying clearly and precisely the personal data from which you are requesting access, rectification, updating or cancellation, the elements or documents in which the personal data can be found and indicating the reasons why you wish to access your personal data, or the reasons why you consider that your data should be updated, rectified or cancelled.

In addition, we ask you to consider that it is possible that Pardela may deny access to the Personal Data or may not be able to rectify, cancel, block or grant opposition to the processing of all your personal data in accordance with the laws applicable to you, particularly in the following cases:

When the applicant is not the Holder of the Personal Data, or the legal representative is not duly accredited to do so;

When in its database, the Personal Data of the applicant is not found;

When there is a legal impediment, or the resolution of a competent authority, which restricts access to the Personal Data, or does not allow the rectification, cancellation or opposition thereof, and;

When the rectification, cancellation or opposition has been previously made.

Pardela will inform you within a maximum period of 20 calendar days from the date on which it receives the request for access, correction, cancellation or opposition, of the determination made, so that, if appropriate, it becomes effective within 15 calendar days from the date on which the response is communicated.

We inform you that you may initiate the procedure for the protection of ARCO Rights, before the National Institute of Transparency, Access to Information and Protection of Personal Data (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales), within 15 calendar days from the date on which your request has been answered and this is not satisfactory to you, or, if the term indicated has elapsed, your request has not been answered.

9. Revocation

In case you do not want us to process your Personal Data, you can send us your request by email to the following address: viaja@pardelanow.com, and you should receive an answer to your request. If necessary, we will inform third parties who have access to your data of this revocation.

10. Special Unit for the Protection of Personal Data

For any doubt or clarification, as well as for the exercise of your ARCO Rights, please contact us by email at the following address: viaja@pardelanow.com or at the Pardela address indicated in point 1. above.

If you have any questions, you can also contact INAI at http://inicio.inai.org.mx/SitePages/ifai.aspx

11. Modifications to the Privacy Notice

Any changes to this Privacy Notice will be made available to the general public on Pardela’s website and at our offices. It is the responsibility of the Owner to periodically review the content of the Privacy Notice at www.pardelanow.com/privacy-policy.

12. Use of Cookies

The correct functioning of the sites, applications and platforms of the Responsible Party and that of its suppliers requires the enabling of “cookies” in their browsers. Cookies are small data files that are stored on the hard drive of a user’s computer or electronic communications device when browsing a specific Internet site, which allows the exchange of status information between that site and the user’s browser. Status information may reveal means of session identification, authentication, or user preferences, as well as any data stored by the browser with respect to the corresponding Internet site. Most browsers automatically accept cookies by default, although the Holder can adjust the Holder’s browser preferences to accept or reject cookies. Disabling cookies may disable various features of websites or may cause them to be displayed incorrectly. In case the Holder prefers to delete the information in the cookies sent by the Responsible Party, the file(s) can be deleted at the end of each browser session.

Date of issue of the Privacy Notice: Last updated: 07 January 2021.

VI.J. Modifications. Pardela may, at any time and when it deems appropriate, without notice to the User, make corrections, additions, improvements, amendments or modifications to the content, presentation, information, services, areas, databases and other elements of the Site, Platform, without this giving rise to any claim or compensation, nor does it imply recognition of any responsibility in favor of the User. Pardela reserves the right to modify these Terms and Conditions at any time and without prior notice, provided that such modifications will not have retroactive effect and will only be applicable to visits to the Site and/or the Platform and operations carried out after such modifications. The User hereby agrees that the Terms and Conditions are only applicable to the operations that he or she carries out with Pardela from time to time and agrees to be bound by the terms of any amendments to these Terms and Conditions for any operations that he or she carries out after such amendments.

VI.K. Assignment of rights and obligations. Pardela and the User agree that Pardela may assign, alienate, encumber or affect all or part of its rights and obligations under these Terms and Conditions without the prior consent of the User, for which the User grants his irrevocable authorization and consent. User may not assign, alienate, encumber or otherwise affect all or any part of its rights and obligations under these Terms and Conditions under any circumstances.

VI.L. Compensation. The User and Pardela agree that, to the extent permitted by law, and the User irrevocably authorizes and empowers Pardela to set-off any amount that the User owes to Pardela at any time for any reason against any amount that the Pardela owes (presently or hereinafter) to the User for any reason (i) without notice, demand or demand, and (ii) up to an amount equal to the amount of the amount not paid to you by Pardela, plus interest and attachments, if any. Pardela's right under this Section is in addition to any other rights (including other rights of set-off) that Pardela may have under any contract or under any applicable law.

VI.M. Unenforceability of any Stipulation. Any provision, convention or stipulation of these Terms and Conditions which is ineffective or unenforceable shall be ineffective or unenforceable to the extent that such provision is ineffective or unenforceable, without affecting the validity or effectiveness of any other provision, or stipulation of these Terms and Conditions.

VI.N. Total Agreement. These Terms and Conditions contain the entire agreement and understanding between Pardela and the User and supersede all previous agreements and understandings between such parties that refer to the subject matter of these Terms and Conditions and may not be modified by communications between Pardela and the User unless delivered in writing signed by attorneys-in-fact or with sufficient powers of both or by their own right. Consequently, the Terms and Conditions may not be contradicted or challenged by evidence of previous agreements or arrangements, emails, prior, simultaneous or subsequent of an oral nature between the parties. There are no oral agreements between PARDELA and the User. In the event of any conflict or inconsistency between any communication between Pardela and the User and these Terms and Conditions, the terms used in these Terms and Conditions shall prevail.

VI.O. Subsistence. All obligations of the User and its guests under these Terms and Conditions shall survive termination of the accommodation, sale of any products and/or provision of any services, as applicable.

VI.P. Headings. The headings, titles or subtitles used at the beginning of each one of the Clauses, the titles, subtitles, sections and paragraphs, have been incorporated with the sole purpose of facilitating their reading and, therefore, constitute only the reference of the same and will not affect their contents or interpretation. For the purposes of interpretation of each Clause, attention should be paid exclusively to its content and in no way to its heading, titles or subtitles.

VI.Q. Termination. Pardela reserves the right, at its sole discretion and without notice to the User, to discontinue or stop disclosing information in the Site and/or in the Platform, in each case, without liability to Pardela, its affiliates, subsidiaries or suppliers.

VI.R. Legislation and Jurisdiction. Pardela and the User agree that these Terms and Conditions will be governed by the applicable legislation in the United Mexican States. Pardela and the User hereby expressly submit to the jurisdiction of the competent courts in Guadalajara, Mexico, waiving any other jurisdiction that may correspond to them by reason of their present or future domicile or for any other reason.

VI.S. Language. Pardela and the User agree that these Terms and Conditions are agreed upon in English and Spanish and that in the event of any discrepancy between the two languages, the Spanish version shall prevail.

VI.S. Irrevocable acceptance. By confirming that you have read and accepted these Terms and Conditions by pressing the “I accept” button, you consent to the contents of these Terms and Conditions (including without limitation the terms of the privacy notice and the processing of your personal data) and agree to be bound by them.

Last updated: 07 January 2021