Cholula, Puebla, September 2014
The Fundación Universidad de las Américas, Puebla (hereinafter UDLAP), as an institution that respects the fundamental rights of every human being associated to their privacy and personal identity, and fulfilling the content of the Mexican legal framework, particularly the content of the Federal Law on Protection of Personal Data Held by Private Parties (the Law) and the Regulations to the Law, communicates this Privacy Notice.
The UDLAP, through its interactions with students, personnel, suppliers and third parties, process personal data of different nature in order to fulfil its obligations and to exercise its rights.
Purposes of the processing of personal data
Following its foundational purpose, the UDLAP promotes and fosters higher education, scientific research and conducts several cultural promotions within the Mexican Republic and abroad. Under this line, the UDLAP process personal data, including those considered as sensitive, in order to fulfil its obligations that derive from contracts and agreements signed betwixt the UDLAP and the data owner; to comply with constitutional mandates, particularly with those relating to Article 3 and the second paragraph of Article 16 of the Political Constitution of the United Mexican States; to address emergency situations that could potentially harm the data owner in his person or property; and, in general to execute the different educational, cultural, athletic, recreational services that it offers to its university community, and to its visitors, suppliers and third parties. The processing of personal data includes retrieval, use, access, management, exploitation, transfer, disposal, disclosure and/or storage, by any means considered appropriate by the UDLAP. This processing will be subject to the content of the Federal Law on Protection of Personal Data Held by Private Parties (the Law) and the Regulations to the Law, the General Criteria for the Instrumentation of the Compensatory Measures without the Expressed Authorization of the Federal Institute for Access to Information and Data Protection, the UDLAP’s Personal Data Protection Policy, and this Privacy Notice that derives from the referred Policy.
Prior to the provision of any personal datum to the UDLAP in any form, you, as data owner, must confirm your consent to the content of the UDLAP’s Personal Data Protection Policy, this Privacy Notice and the physical and/or technological instruments that derive from them in order to obtain your informed consent according to the terms of articles 6, 8, 16, 17 of the Federal Law on Protection of Personal Data Held by Private Parties. If you do not agree with content of the instruments referred in this Privacy Notice, please do not reveal any personal datum. If you decide not to provide the required personal information to the UDLAP, or if you decide, at any time, make a request to the UDLAP for cancellation of your personal data, you accept that the UDLAP has the power to deny you the access to its facilities, activities or other offered services.
With basis on the spirit of the lines above, and following the principles of notice and purpose, the UDLAP informs you that it can do the following:
- Transfer your personal data to third parties with whom it has agreed terms of services relating to the processing of personal data under the terms established in section IV of article 10 of the Federal Law on Protection of Personal Data Held by Private Parties, and article 17 of its Regulations, in order to fulfil with processes of accreditation and certification, to make socioeconomic studies, for the purpose of exercising its rights, and to offer to the data owners its academic, cultural, medical and athletic services.
- Transfer your personal data to other domestic and foreign academic institutions in order to materialize academic, cultural and athletic projects. Under these cases, the UDLAP will reveal only the data required for the optimal development of the specific actions and services requested by the data owner following the principle of proportionality.
With basis on the content of articles 50 and 53 of the Regulations of the Federal Law on Protection of Personal Data Held by Private Parties, the third parties receiving and processing personal data will only receive those personal data required to fulfil their obligations following the instructions issued by the UDLAP, maintaining confidentiality regarding the personal data subject to processing.
Some contact information such as name, address, telephone number and email will be processed by the UDLAP in order to inform you about our services, cultural, athletic and academic events, projects, lotteries, amongst others. In addition, the UDLAP will structure different actions with basis on General Criteria for the Instrumentation of the Compensatory Measures without the Expressed Authorization of the Federal Institute for Access to Information and Data Protection.
Videos, audio and photographs
The UDLAP records (audio and video) and takes photographs during the events that it organizes such as classes, lectures, conferences, athletic, cultural, recreational, promotional and academic events, institutional projects, amongst others. When you access to the UDLAP’s facilities, under the terms of article 74 of the Regulations of the Federal Law on Copyright, and according to the paragraphs 21 and 22 of the UDLAP’s Policy on Intellectual Property, you recognize that you could be recorded and/or photographed, consenting that the UDLAP will have all the powers to use, distribute or transmit the recordings and/or the photographs in the activities that it realizes according its purpose.
With the aim of protecting your personal data, the UDLAP has created a set of categories of information and has designed legal, operative and technological security measures according to the nature of the data and the processes relating to them.
The terms during which the UDLAP will process your personal data will not exceed the terms required for the optimal fulfilment of the objectives described in this Privacy Notice; thus, when the personal data is no longer necessary for the fulfilment of the objectives set forth in this privacy notice and applicable legislation, it will be cancelled by the UDLAP.
Requests for Access, Rectification, Cancellation or Objection
You have the right to request, at any time, your rights of access, rectification, cancellation or objection. For these effects, you or your legal representative, must present your request at the UDLAP´s address (Ex Hacienda Santa Catarina Mártir S/N, San Anrés Cholula, Puebla, C.P. 72810) where the institutional data processor will receive and ´process the request issued by the data owner, or you could present your request to the personal data protection area through the following electronic address: email@example.com
The access, rectification, cancellation or objection request must include: 1) your name, 2) documents establishing the identity or, where appropriate, legal representation of the data owner, 3) your address or e-mail to notify you the response to your request, 4) a clear and precise description of the personal data with regard to which you seek to exercise any of the abovementioned rights, and 5) any other item or document that facilitates locating the personal data.
The UDLAP will notify you, within a maximum of twenty days counted form the date of receipt of the request for access, rectification, cancellation or objection, of the determination made, so that, where appropriate, same will become effective within fifteen days from the date on which the notice is provided. These time periods may be extended a single time by a period of equal length, provided that such action is justified by the circumstances of the case. For personal data access requests, delivery will be made upon proof of identity of the requesting party or legal representative.
If you want to revoke your consent for the processing of your personal data, you should notify your decision in writing directly to the UDLAP’s data processor that obtained your data and/or to the e-mail firstname.lastname@example.org.
Personal Data Protection Area
The UDLAP’s Personal Data Protection Area is the General Direction of Legal Affairs, having its address at Ex Hacienda Santa Catarina Mártir S/N, San Andrés Cholula, Puebla, Mexico, C.P. 72810, and the following electronic address: email@example.com. The Personal Data Protection Area is empowered to give you advice on how you can exercise your rights.
Modifications to this Privacy Notice
The UDLAP, through its Personal Data Protection Area, has the right to change, at any time, modifications or actualizations to this Privacy Notice based on its sole discretion. These changes will be available for the public through the following institutional webpage (www.udlap.mx/privacidad/). For that reason we encourage you to visit this website on a periodical basis before reveal any personal datum to the UDLAP; thus continuing working with your informed consent. Any substantial change to the referred Policy will be in force immediately, unless this change derives from a reform to the Mexican legal framework or from an order issued by a competent authority, and it will be informed through the institutional website (www.udlap.mx).
Address of the Fundación Universidad de las Américas, Puebla
Ex Hacienda Santa Catarina Mártir S/N, San Andrés Cholula, Puebla, Mexico, C.P. 72810
This Privacy Notice will take effect on September 26, 2014.
Note: The contents, construction and interpretation of this document shall be determinate solely based on its Spanish version.