Privacy Notice

1. Identity and address of the data controller

ADN Services SA de CV ("ADN Services" or "the Controller"), Tax ID (RFC) ASM201008SK7, located at Av. Punto Sur #312, CP 45640, Tlajomulco de Zuniga, Jalisco, Mexico, is responsible for processing your personal data. For any matter related to this notice, contact us at [email protected].

2. Personal data we collect

Depending on your relationship with us (representative of a client company or prospect, an employee whose payroll we administer on behalf of a client, or a website visitor), we may collect the following categories of personal data:

• Identification data: full name, national ID numbers (CURP, RFC), date of birth, official identification.
• Contact data: address, phone numbers, personal and corporate email.
• Employment and payroll data: job title, salary, benefits, social security number (NSS), housing fund credit number (INFONAVIT), bank details for payroll deposits, attendance records.
• Tax data: RFC, tax status certificate, tax regime, fiscal address.
• Client or prospect company data: company name, RFC, address, representative name and title, phone, email, headcount.
• Browsing data: IP address, browser type and version, operating system, pages visited, time on site, traffic source (see Section 9).

3. Sensitive personal data

For payroll administration purposes, we may collect data about medical leave authorized by IMSS (Mexico's social security institute) and other health-related absences, to the extent needed to calculate payroll correctly and comply with our clients' employer obligations. This data is considered sensitive under the LFPDPPP and is processed only for that purpose, with reinforced security measures as required by law.

4. Purposes of processing

4.1 Primary purposes (necessary)

We process your personal data for the following purposes, which are necessary for our legal relationship with ADN Services:

• Responding to quote requests, commercial information requests and service proposals.
• Formalizing payroll administration, payroll outsourcing, REPSE-registered specialized services and fiscal-labor advisory contracts.
• Calculating, issuing and depositing payroll for our clients' workers, including CFDI 4.0 invoicing, income tax withholding, social security contributions and INFONAVIT deductions.
• Registering, modifying and terminating employees with IMSS, INFONAVIT and the Tax Administration Service (SAT), on behalf of the client.
• Complying with REPSE registry obligations before the Ministry of Labor (STPS), including SISUB and ICSOE reporting.
• Billing, collections and accounting management of the commercial relationship.
• Responding to requirements from competent authorities (STPS, SAT, IMSS, INFONAVIT, judicial authorities).

4.2 Secondary purposes (optional)

If you do not object, we may also process your data for these secondary purposes, which are not essential to our legal relationship but allow us to serve you better:

• Sending commercial communications, newsletters, regulatory updates and case studies.
• Satisfaction and service quality surveys.
• Internal statistical analysis to improve our services.

If you do not want your data processed for any secondary purpose, you may object by emailing [email protected] with the subject "Negativa finalidades secundarias", stating your name and the specific purpose. Your objection will not affect services you already have under contract.

5. Data transfers

ADN Services transfers personal data to the following third parties, under cases provided by the LFPDPPP that do not require your consent (Article 37):

Recipient	Purpose	Legal basis
IMSS, INFONAVIT, SAT, STPS	Compliance with labor, tax, social security and housing legal obligations.	LFPDPPP Art. 37(II)
Contracting client companies	Delivery of payroll and compliance information required for the underlying employment relationship, including SISUB/ICSOE reporting when REPSE registration applies.	LFPDPPP Art. 37(VI)
Banking institutions	Payroll deposits, SPEI transfers, bank layouts.	LFPDPPP Art. 37(VI)
Technology providers (CFDI invoicing authorized provider, payroll platforms)	Operation of contracted services. These third parties act as data processors and are contractually bound to confidentiality.	LFPDPPP Art. 36
Judicial and prosecutorial authorities	Responding to legal requirements, complaints or rulings.	LFPDPPP Art. 37(II)

Except as described above, we do not transfer your personal data to third parties without your prior consent.

6. ARCO rights and withdrawal of consent

As a data subject, you have the right to:

• Access your personal data held by ADN Services and learn the details of its processing.
• Rectify your data when inaccurate or incomplete.
• Cancel your data when you believe it is no longer required for any of the stated purposes, is being used for unconsented purposes, or the contractual relationship has ended.
• Object to the use of your data for specific purposes.
• Withdraw consent you previously granted for processing your data.

How to exercise ARCO rights

To exercise any of these rights, send a request to [email protected] with the subject "Solicitud ARCO", including:

1. Full name of the data subject and address or means to receive a response.
2. Copy of a valid official ID proving your identity. If acting through a representative, a simple power of attorney and the representative's ID.
3. A clear and precise description of the personal data for which you seek to exercise the right, and which right you wish to exercise.
4. Any other information that facilitates locating the data.

ADN Services will respond to your request within a maximum of 20 business days from receipt. If applicable, the request will be fulfilled within the following 15 business days.

Withdrawing consent may make it impossible to continue providing contracted services. Certain cancellations will not proceed where a legal obligation exists to retain data (for example, payroll and tax records that must be kept for the periods set out in the Federal Labor Law, the Federal Tax Code and the Social Security Law).

7. Limiting the use or disclosure of your data

You may request inclusion in our internal exclusion list so your data is not used for marketing or advertising purposes, by emailing [email protected] with the subject "Registro de Exclusion". You may also register with PROFECO's public consumer registry (REPEP).

8. Security measures

ADN Services has implemented reasonable administrative, physical and technical security measures to protect your personal data against damage, loss, alteration, destruction, unauthorized use, access or processing, as required by Articles 19 and 20 of the LFPDPPP. These measures include access controls, encryption of sensitive data in transit and at rest, periodic backups, staff training and internal information handling policies.

In the event of a security breach that significantly affects your property or moral rights, we will inform you immediately so you can take appropriate action.

9. Cookies and similar technologies

The site adnservicesmx.com uses cookies and similar technologies to improve browsing, remember preferences and obtain anonymous usage metrics, including:

• Essential cookies: required for the site to function.
• Analytics cookies: third-party tools such as Google Analytics, used to understand aggregate, anonymous site usage.
• Remarketing pixels: from advertising platforms to show you relevant ads on other sites.

You can disable cookies in your browser settings. Disabling essential cookies may affect site functionality.

10. Changes to this Privacy Notice

ADN Services reserves the right to modify this Privacy Notice at any time to reflect changes in our practices, applicable law or our services. Updates will be published at adnservicesmx.com/aviso-de-privacidad/ indicating the date of last modification. We recommend reviewing this page periodically.

11. Regulatory authority

If you believe your data protection rights have been violated, you may contact Mexico's National Institute for Transparency, Access to Information and Personal Data Protection (INAI): home.inai.org.mx.

This English version is provided for convenience. The Spanish-language Aviso de Privacidad Integral is the legally controlling document under Mexican law.