COMPREHENSIVE PRIVACY NOTICE

Desarrollo Marina Vallarta, S.A. de C.V., with an address to hear and receive notifications located at Av. Paseo de la Marina Sur, #220, Marina Vallarta, Puerto Vallarta, Jalisco Z.C. 48335, we are a company that commercializes and carries out the contracting of lodging rights and tourist services (Hereinafter referred to as “DMV”). Our company is committed to protect your privacy under the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Partículares) [“LFPDPPP”], its regulations, the Guidelines of the Privacy Notice, and other legal provisions applicable in the Mexican Republic (hereinafter and collectively, the “Legislation”). In addition to the provisions of the Legislation, DMV has adopted the best international practices in “Personal Data” management and administration, with the final purpose to clearly and specifically inform which Personal Data we collect, how it is collected, As well as the treatment we give to them, always mediating our commitment to protect your privacy under the highest standards of ethics, responsibility, and professionalism, we put this Privacy Notice at your disposition.

1. PERSONAL DATA WE COLLECT.

For the fulfillment of the legal relationship and the provision of the requested services, if you are our customer, DMV may collect from you the following categories of Personal Data, either through physical or electronic formats:

• Identification and contact data.
• Property Data (bank data for collection, tax data for billing).
• Biometric data. (Fingerprints, voiceprint signature, image data in photographs and / or videos).
• Geolocation data, when using the Vidanta Resorts App.

Within the categories of Property Data and / or Biometric Data, since they are considered as Sensitive Personal Data that require special protection, DMV will give special treatment to them and will request your express and written consent in accordance with the provisions of the Legislation and the purposes established in this Notice.

2. THE PERSONAL DATA PROCESSING BY DMV HAS THE FOLLOWING PURPOSES.

• For identification, verification and / or contact, in any type of legal or business relationship with DMV.
• For the fulfillment of contractual obligations regarding the services that we must provide you.
• To inform you about the changes in the products and services that we commercialize.
• For your attention in case of security incidents during your stay in our facilities, for which we establish security and surveillance measures, including monitoring through video cameras, security control and physical and logical access surveillance.
• To carry out the collection and billing of the services you acquire with us, as well as to execute reimbursement processes if applicable.
• To authenticate your voice when contacting us through our Customer Care Center.
• To send advertising and promotions while using the Vidanta Resorts App.

Additionally, we use your Personal Data for the following “Secondary Purposes” that are not necessary for the fulfillment of the legal relationship that gives rise to the processing of Personal Data, but that allow and facilitate us to provide you with better care:

• To develop studies and programs for marketing or advertising purposes.
• For record keeping for future service provision.
• To inform you of current or future products, services, advertising, promotions, and newsletters that may be of your interest.
• To carry out quality surveys of our products and / or services.

In case you do not want your Personal Data to be used for any of the Secondary Purposes, we invite you to follow the procedure established in point “E” of this Privacy Notice. The refusal to use your Personal Data for these Secondary Purposes may not be a reason for us to deny the provision of the services and / or products that you acquire or contract with DMV.

3. CONSERVATION PERIOD OF YOUR PERSONAL DATA.

DMV will keep your Personal Data for the duration of the legal relationship with you, or according to the established terms in the Legislation, or until you request us to delete them, if the Legislation allows it.

4. MEANS TO LIMIT THE USE OR DISCLOSURE OF PERSONAL DATA.

If you wish to express your refusal to use or disclose Personal Data, you may request your registration in our “Exclusion List”. To request inclusion in our Exclusion List, you must follow the process established in point “E.” of this Privacy Notice.

5. EXERCISE OF THE: (i) ACCESS, RECTIFICATION, CANCELLATION, AND OPPOSITION RIGHTS (“ARCO Rights”); (ii) REQUEST THE REVOCATION OF THE CONSENT TO THE TREATMENT OF YOUR PERSONAL DATA; (iii) DATA PORTABILITY; AND (iv) RIGHT TO BE FORGOTTEN.

In accordance with the Legislation, you may exercise your right of access to know the Personal Data we have about you in our records, as well as to know what we use them for and the treatment we give them, you can rectify or request their correction in case of be inaccurate; You can request its cancellation, as well as express your opposition to the use and treatment; request the right of portability; or revoke the consent for its treatment, as well as request the right to be forgotten.

For the purposes of exercising any of the rights indicated above, we ask you to download the format that we make available to you through the following web link: “https://avisos.vidanta.com/formatosARCO/en/nuevovallarta/SDA-NV-Desarrollo-Marina-Vallarta.pdf”. The request must be sent by email to the account: datospersonales@grupovidanta.com and must be accompanied by the documentation indicated in said format. Our “Personal Data Office” will notify you of the response within a maximum period of 20 (twenty) business days from the date on which the notification of your request takes effect. If your request is appropriate in accordance with the guidelines established in the Legislation and this Privacy Notice, it will become effective within 15 (fifteen) business days following the date on which we notify you of the corresponding response.

When DMV deems it convenient, it may agree with Personal Data Owner, the alternative means for registration in our Exclusion List, always acting in accordance with the Legislation, so that our “Personal Data Office” can authenticate your identity and be able to respond to your request.

It is important to mention that not in all cases we will be able to satisfy your request for ARCO rights, revocation of consent, portability or right to be forgotten, since it is possible that due to some legal obligation we will need to continue keeping and / or treating your Personal Data in accordance to this Privacy Notice. If this is the case, we will inform you by indicating the corresponding obligations and we will proceed, where appropriate, blocking the corresponding Personal Data, the above during the term that the Legislation requires for its conservation and until its elimination is definitive.

In case of doubts or if you wish to obtain more information regarding the procedure to (i) limit the use or disclosure of your Personal Data, (ii) ARCO rights exercise (access, rectification, cancellation, and opposition), or (iii) exercise the right to revoke consent, we offer you the following means of contact:

Email: datospersonales@grupovidanta.com, or contact the “Personal Data Office” at the telephone number 322 226 4000 Extension 64713. Business hours from Monday to Friday from 09:00 a.m. at 02:00 p.m. and 04:00 p.m. at 7:00 p.m. Mexico City Central time.

6. DATA TRANSFER.

DMV may transfer your Personal Data with affiliated or subsidiary companies, as well as with independent third parties with whom it has a legal relationship, to comply with the services or products that you acquire from us and in accordance with the following:

PERSONAL DATA RECIPIENT	PURPOSE
Affiliated companies, subsidiaries and/or specialized third parties.	Evaluation of satisfaction and quality of service. Sending promotions and advertising (email, SMS text message, certified mail, home parcel services).
Comenity Capital Bank.	Subscription to credit card program.
Barclays Bank PLC.	Subscription to credit card program.
GCV Vacations, S.A. de C.V.	Financing Application.
VCM Capital, S.A.P.I. de C.V.	Financing Application.
Instituciones Bancarias Mexicanas.	Payment processing and/or refunds if applicable.
Operadora PayPal de México, S. de R.L. de C.V.	Payment processing and/or refunds if applicable.
Resort Condominiums International de México, S. de RL de C.V. (RCI).	Subscription to an Exchange company.
The San Francisco Exchange Company (SFX).	Subscription to an Exchange company.
Interval International, INC. / Intercambios Internacionales de México, S.A. de C.V., (INTERVAL).	Subscription to an Exchange company.

7. ELECTRONIC MEDIA, COOKIES OR WEB BEACONS.

We inform you that on our website we use analytical cookies that allow us to monitor your browsing behavior on our website, to offer you a better experience. In the same way, we inform you that when you use our Vidanta Resorts App, we can use some tools which we could collect Personal Data always in accordance with the purposes described in this Privacy Notice.

You can disable all cookies, avoid accepting new cookies, and have your browser notify you when you receive a new cookie through the “help” button found on the existing toolbar in most web browsers, or if you use the Vidanta Resorts App, you can change the geolocation permissions in your device settings.

8. COMMUNICATION MEANS FOR CHANGES AND / OR MODIFICATIONS TO THE PRIVACY NOTICE.

DMV reserves the right to update, change or modify this Privacy Notice at any time. In the event of any change, DMV will communicate it through our website: https://avisos.vidanta.com/en/dmv.pdf.

9. JURISDICTION.

This Privacy Notice is governed by Mexican law and any controversy will be resolved before the competent Mexican authorities. By accepting this Privacy Notice, you waive any other jurisdiction and legislation that may correspond to you by reason of your address.

10. AUTHORITY.

If you consider that your right to Personal Data Protection has been injured by any conduct or omission on the part of DMV, or you presume any violation of the provisions set forth in the Legislation and other applicable regulations, you may file your disagreement with 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”] (“INAI”).

11. VALIDITY.

This is the most recent version of our Privacy Notice, which became effective as of April 20, 2017.

Date of last modification, March 10th, 2022.

This document comes from its Spanish language version, and it is translated into English language in good faith by DMV, however, it is understood and accepted that, in case of doubt or controversy regarding its interpretation, the Spanish version will prevail in all cases.