Privacy Notice.
1. Purpose.
BSW Tratamientos Sustentables de Agua de la Baja, S.A. de C.V. (hereinafter, “BSW”), in compliance with the Federal Law on the Protection of Personal Data Held by Private Parties (the “Law”), its regulations, and national and international guidelines and standards regarding personal data protection, as well as any other legislation applicable to it by reason of its activities, hereby informs, through this privacy notice (the “Privacy Notice”), the person to whom the personal data pertains (the “Data Subject”) that the information provided personally, verbally, in writing, electronically, optically, visually, audibly, or through any other technology during the course of their interactions with BSW (the “Personal Data”) may be collected, stored, and processed by BSW for the purposes set forth in this Privacy Notice. This Privacy Notice applies differently depending on the Data Subject’s relationship with BSW, distinguishing among: (i) BSW’s suppliers (the “Suppliers”); (ii) BSW’s customers (the “Customers”); (iii) persons who visit BSW’s Corporate Address or Water Farm, including guests, suppliers, and prospective customers (the “Visitors”); and (iv) BSW’s employees, candidates, and former employees (the “Employees”), who are individually and collectively identified as Data Subjects for purposes of this Privacy Notice.
2. Identity and Address of the Data Controller.
The party responsible for processing your Personal Data is BSW, with its address at Calle Concepción Olachea M., lot 11-B, Block 10, Santa Rosa neighborhood, San José del Cabo, Baja California Sur, Postal Code 23428 (the “Corporate Address”). For purposes of this Privacy Notice, “Water Farm” shall mean the showroom operated by BSW for the exhibition and demonstration of the Treatment Equipment that it develops and markets.
3. Collection of Personal Data.
BSW may collect Personal Data in the following cases and through the following means:
a. When the Data Subject provides it directly to BSW, whether verbally, in writing, electronically, or by any other means;
b. When the Data Subject visits or browses BSW’s website;
c. When the Data Subject visits the Corporate Address or the Water Farm, including through the access control and video surveillance systems installed at those locations;
d. When the Data Subject, in their capacity as an Employee, provides information as part of their recruitment or hiring process and/or during the term of their employment relationship with BSW;
e. When so established by a resolution issued by a competent authority empowered for such purposes; and
f. When BSW obtains information through other means permitted by current and applicable legislation.
4. Personal Data Collected by Data Subject Category.
a. Suppliers.
Full name or corporate name; tax address; Federal Taxpayer Registry Code (the “RFC”); business activity or corporate purpose; contact information (telephone number and email address); bank account (CLABE) for payment purposes; and, where applicable, identification details of their legal representatives and contact persons.
b. Customers.
Full name or corporate name; address; RFC; contact information (telephone number and email address); bank account (CLABE) for invoicing and collection purposes; identification details of their legal representatives and contact persons; and, where applicable, information relating to the project or facility where the Treatment Equipment will be used.
c. Visitors.
Full name; official identification, when required for access control at the Corporate Address or the Water Farm; company or institution represented; contact information; purpose of the visit; and images captured through the video surveillance systems installed at the Corporate Address and the Water Farm.
d. Employees.
Full name; address; age and date of birth; marital status; nationality; RFC; Unique Population Registry Code (the “CURP”); Social Security Number; contact information; bank account (CLABE) for payroll deposit purposes; academic and professional information; personal and employment references; information regarding financial dependents and beneficiaries; and images captured through the video surveillance systems installed at BSW’s facilities; and, where applicable, biometric data for access and attendance control purposes. Additionally, as a result of the employment relationship, BSW may collect sensitive personal data in accordance with Section 6 (six) below.
5. Purposes of Processing.
I. Primary Purposes.
The following purposes are necessary for the legal relationship between the Data Subject and BSW and for compliance with the obligations arising therefrom:
Suppliers: (i) supplier registration and updating of the corresponding database; (ii) management of the commercial relationship, including quotations, contracting, invoicing, and payment; (iii) compliance with tax, accounting, and legal obligations; and (iv) internal and external audits.
Customers: (i) customer registration and updating of the corresponding database; (ii) quotation, contracting, sale, and installation of the Treatment Equipment; (iii) invoicing and collection; (iv) customer service and technical support, including warranty and preventive maintenance; and (v) compliance with tax, accounting, and legal obligations.
Visitors: (i) access control and identification; (ii) assistance and management of the meeting, appointment, demonstration, or procedure giving rise to the visit to the Corporate Address or the Water Farm; and (iii) the security and safeguarding of persons and property within such facilities, including video surveillance.
Employees: (i) recruitment and personnel selection; (ii) formalization and administration of the employment relationship, including the execution of the individual employment agreement; (iii) registration, updates, and compliance with obligations before the Mexican Social Security Institute, INFONAVIT, AFORE, and tax authorities; (iv) calculation and payment of payroll and benefits; (v) access control, attendance, and video surveillance within BSW’s facilities; (vi) training, performance evaluation, and professional development; and (vii) compliance with all other obligations arising from applicable labor and social security legislation.
II. Secondary Purposes.
Additionally, BSW may process Personal Data for: (i) sending communications regarding new products, services, or promotions addressed to Customers; (ii) evaluating service quality; and (iii) in the case of Employees, team-building, recognition, and internal communication activities. These secondary purposes are not essential to the legal relationship between the Data Subject and BSW; therefore, the Data Subject may express their refusal or objection through the means set forth in Section 9 (nine) below. The Data Subject’s refusal to allow their Personal Data to be processed for these secondary purposes shall not, under any circumstances, constitute grounds for denying the products or services requested or contracted from BSW.
6. Processing of Sensitive Personal Data.
In the case of Suppliers, Customers, and Visitors, BSW does not collect sensitive personal data under the terms of Article 3 (three), Section VI, of the Law.
In the case of Employees, as a result of the employment relationship and compliance with social security obligations, BSW may collect data relating to the Data Subject’s current and/or future health status (including disabilities and pre-employment and fitness medical examinations), as well as, where applicable, biometric data for access and attendance control purposes. Such data shall be processed under the strictest security standards and measures to ensure its confidentiality, and its processing requires the Data Subject’s express written consent, which shall be deemed granted through the execution of the individual employment agreement or equivalent document containing this Privacy Notice.
7. Use of Video Surveillance Systems.
BSW has closed-circuit television and/or video recording systems installed at the Corporate Address and the Water Farm for the purpose of safeguarding the security of persons—including Customers, Visitors, and Employees—and the tangible property located within such facilities, as well as preventing unlawful acts. Images captured by such systems may be used as evidence before the competent authorities if required in accordance with Section 8 (eight) below. By entering the Corporate Address or the Water Farm, the Data Subject expressly consents to being recorded by such video surveillance systems for the purposes described above.
8. Transfer and Limitation of the Use or Disclosure of Personal Data. The Personal Data referred to in this Privacy Notice may be transferred, as applicable, to:
a. Judicial, administrative, and/or other authorities, whether domestic or foreign, for the purpose of complying with notices, requests, resolutions, and official communications issued by such authorities;
b. The Mexican Social Security Institute, INFONAVIT, AFORE, and tax authorities, in the case of Employees, for compliance with the corresponding social security and tax obligations;
c. Service providers, advisors, and auditors who assist BSW in complying with its legal obligations and providing its services; and
d. Insurance companies, with respect to insurance policies and benefits contracted by BSW for the benefit of its Employees.
Except in the circumstances described above, BSW shall not communicate, share, or transfer Personal Data to third parties unrelated to BSW, whether within or outside the national territory. If any additional transfer requiring the Data Subject’s consent is intended, such consent shall be obtained in advance in accordance with the provisions of the Law.
9. Means and Procedure for Exercising the Rights of Access, Rectification, Cancellation, and Objection (ARCO).
The Data Subject shall have the right to access their Personal Data held by BSW and to learn about its use and the conditions under which it is processed; to rectify it if it is inaccurate or incomplete; to request its cancellation when they believe it is no longer necessary for any of the purposes set forth in this Privacy Notice, is being used for purposes to which they did not consent, or their legal or contractual relationship with BSW has ended; or to object to its processing for specific purposes. To exercise any of the ARCO rights, the Data Subject must submit a written request by email to info@bajasustainablewater.com, which must include at least:
a. The Data Subject’s full name and address or email address for communicating the response to their request;
b. A copy of an official identification document proving the Data Subject’s identity or, where applicable, documents proving the authority and identity of their legal representative;
c. A clear and precise description of the Personal Data regarding which the exercise of any ARCO right is sought; and
d. Any other information or document that facilitates locating the Personal Data.
BSW shall notify the Data Subject of its decision within a maximum of 20 (twenty) business days from the date the request is received and, if the request is approved, it shall be implemented within the following 15 (fifteen) business days from the date on which the corresponding response is communicated.
10. Withdrawal of Consent.
The Data Subject may withdraw, at any time, the consent granted to BSW for the processing of their Personal Data. To do so, they must submit a request through the same means and subject to the same requirements set forth in Section 9 (nine) above. Withdrawal of consent shall not have retroactive effects. In the case of Employees and Suppliers, if such withdrawal is incompatible with BSW’s compliance with its legal, tax, or labor obligations, BSW may continue processing the Personal Data strictly necessary for such compliance.
11. Amendments to the Privacy Notice.
BSW reserves the right to amend or update this Privacy Notice at any time to address legislative developments, changes to its internal policies, or requirements imposed by a competent authority. Any amendments shall be made known by publication at the Corporate Address and the Water Farm and/or on BSW’s website.
12. Rights Protection Procedure.
If the Data Subject believes that their right to the protection of Personal Data has been violated by BSW, they may file a complaint with the Ministry of Anti-Corruption and Good Governance through its website at www.gob.mx/buengobierno, within the applicable time limits and in accordance with the procedure established by the Law.
13. Consent of the Data Subject.
The Data Subject represents that: (i) this Privacy Notice was made available to them before the processing of their Personal Data; (ii) they have read and understood its contents; and (iii) they expressly consent to the processing of their Personal Data in accordance with the terms set forth herein, including, where applicable, the processing of sensitive personal data and the capture of their image through the video surveillance systems referred to in Section 7 (seven) above.
Last updated: August 14, 2026.