Comprehensive Privacy Policy

I. Identity and Address of the Data Controller

División de Multiingeniería Empresarial, S.A. de C.V. (hereinafter “DIMEM”), with Federal Taxpayer Registry number (RFC) DME1712048B1, located at:

Is the legal entity responsible for the processing of your personal data, in accordance with the Mexican Federal Law on Protection of Personal Data Held by Private Parties (“LFPDPPP”), its Regulations, the Privacy Notice Guidelines, and all other applicable legislation in force in the United Mexican States.

II. Personal Data Collected

For the purposes stated in this Privacy Policy, DIMEM may collect and process the following categories of personal data:

a) Identification data

• Full name
• Company name (for legal entities)
• Federal Taxpayer Registry number (RFC)
• Unique Population Registry Code (CURP)
• Nationality
• Date of birth

b) Contact data

• Address (street, number, neighborhood, postal code, city, and state)
• Landline and/or mobile phone number
• Email address
• WhatsApp number

c) Employment and professional data

• Employer name or institution
• Job title or position
• Work address
• Business activity or industry

d) Tax and billing data

• Federal Taxpayer Registry number (RFC)
• Tax regime
• Tax domicile
• Tax identification certificate
• CFDI usage

e) Financial data

• Banking data for payment and billing purposes
• Interbank CLABE number
• Bank account number

Sensitive personal data: DIMEM declares that it does not collect sensitive personal data (such as racial or ethnic origin, health status, genetic information, religious beliefs, union membership, political opinions, or sexual preference). Should it ever become necessary to collect such data, you will be informed in advance and your express written consent will be requested.

III. Purposes of Data Processing

A) Primary purposes (necessary for the legal relationship)

1. Identification and verification of your identity as a client, supplier, candidate, or user.
2. Execution, compliance, and administration of service agreements, purchase contracts, or other legal instruments.
3. Provision of services contracted through any of our business units: DIMERA (private security), LAFRA (architecture and interior design), Dev-Binary-X (software development), Organic Botox (cosmetics), Conta FMM (accounting and tax services), Maestros del Mezcal, Catalyst Design Group (industrial design), and Grupo Raíces Mexicanas (gastronomy).
4. Issuance of invoices, digital tax receipts (CFDI), service billing, and payment management.
5. Handling requests, inquiries, complaints, or claims.
6. Compliance with applicable legal, tax, accounting, and regulatory obligations.
7. Contact and communication related to contracted or requested services.

B) Secondary purposes (not necessary for the legal relationship)

1. Sending commercial, advertising, promotional, or marketing communications about DIMEM products and services and its business units.
2. Conducting market research, statistical analysis, and satisfaction surveys.
3. Creating preference and consumption profiles to personalize service offerings.
4. Invitations to corporate events, social responsibility activities, and loyalty programs.

If you do not wish your personal data to be processed for secondary purposes, you may indicate so by sending an email to privacidad@dimem.mx with the subject line “Opt-Out Secondary Purposes.” Your refusal to have your data used for secondary purposes will not be grounds for denying the services and products you request or contract.

IV. Mechanisms to Limit Use or Disclosure of Personal Data

DIMEM implements the following measures to limit the use and disclosure of your personal data:

• Internal privacy and personal data protection policies.
• Training and awareness programs for personnel who process personal data.
• Role-based access control systems for personal data.
• Physical, technical, and administrative security measures in accordance with Articles 60 through 66 of the LFPDPPP Regulations.
• Data encryption in transit and at rest.
• Periodic internal information security audits.

Additionally, you may register with the Public Registry to Avoid Advertising (REPEP), available at https://repep.profeco.gob.mx/.

V. Personal Data Transfers

DIMEM may transfer your personal data to domestic or foreign third parties without requiring your consent in the following cases provided by Article 37 of the LFPDPPP:

• When the transfer is provided for by law or by a treaty to which Mexico is a party.
• When necessary for medical prevention or diagnosis, healthcare provision, medical treatment, or health service management.
• When made to controlling companies, subsidiaries, or affiliates under common control, or to a parent company or any company within the DIMEM group operating under the same internal processes and policies.
• When necessary by virtue of a contract entered into or to be entered into in the interest of the data subject, between the controller and a third party.
• When necessary or legally required to safeguard a public interest, or for the administration or pursuit of justice.
• When necessary for the recognition, exercise, or defense of a right in judicial proceedings.
• When necessary for the maintenance or fulfillment of a legal relationship between the controller and the data subject.

Additionally, DIMEM may transfer your personal data to the following categories of third parties, subject to obtaining your consent:

VI. ARCO Rights (Access, Rectification, Cancellation, and Opposition)

You have the right to know what personal data we hold about you, what we use it for, and the conditions of its use (Access). You also have the right to request correction of your personal information if it is outdated, inaccurate, or incomplete (Rectification); to have it deleted from our records or databases when you consider it is not being properly used (Cancellation); and to oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.

Procedure for exercising your ARCO rights

To exercise any of your ARCO rights, you must submit a request (hereinafter, “ARCO Request”) through any of the following channels:

• Email: privacidad@dimem.mx
• Written request to the Personal Data Protection Department: Calle Arquímedes 15, Colonia Polanco, Alcaldía Miguel Hidalgo, CP 11560, Mexico City.

ARCO Request requirements

In accordance with Article 29 of the LFPDPPP, your request must contain:

1. The full name of the data subject and address or other means to communicate the response to your request.
2. Copies of documents proving your identity or, where applicable, legal representation of the data subject (valid official identification: INE/IFE, passport, or professional license).
3. A clear and precise description of the personal data for which you seek to exercise any of the ARCO rights.
4. Any other element or document that facilitates the location of the personal data.
5. For rectification requests, the modifications to be made and supporting documentation.

Response timeframes

DIMEM will respond to your request within a maximum period of 20 (twenty) business days from the date of receipt of the ARCO Request. This period may be extended for an equal period in cases provided by law. The determination adopted will be communicated to the data subject within a maximum period of 15 (fifteen) business days following the date on which the response is communicated, so that, where applicable, it may be enforced.

VII. Revocation of Consent

You may revoke the consent granted to DIMEM for the processing of your personal data, so that we cease using it. However, it is important to note that we may not be able to comply with your request immediately or terminate the processing in all cases, as there may be legal or contractual obligations requiring us to continue processing your personal data.

To revoke your consent, you must send your request to privacidad@dimem.mx with the subject line “Consent Revocation,” along with a copy of your valid official identification and a clear description of the data and purposes for which you are revoking consent.

DIMEM will respond to your revocation request within a maximum period of 20 (twenty) business days from its receipt.

VIII. Use of Cookies, Web Beacons, and Tracking Technologies

The DIMEM website (dimem.mx) may use cookies, web beacons, and other tracking technologies for the following purposes:

• Essential cookies: Necessary for basic website functionality, navigation, and use of its features.
• Analytical cookies: Allow measurement and analysis of website usage to improve user experience (e.g., Google Analytics).
• Functional cookies: Store user preferences such as the selected language.

Personal data obtained through these tracking technologies include: IP address, browser type and version, operating system, pages visited, time spent on site, referral source, and site interaction data.

You may disable the use of cookies through your Internet browser settings. Please note that disabling essential cookies may result in some website features being unavailable.

IX. Data Processing Through Digital Channels

DIMEM collects personal data through the following digital channels:

• Website contact form: Name, company, email, phone/WhatsApp, service of interest, and message.
• WhatsApp Business: Phone number, profile name, and content of conversations related to service requests.
• Email: Data contained in electronic correspondence addressed to DIMEM.
• Social media (LinkedIn, Instagram): Public profile data and interactions.

X. Security Measures

DIMEM has implemented and maintains administrative, technical, and physical security measures to protect your personal data against damage, loss, alteration, destruction, or unauthorized use, access, or processing, in accordance with Articles 19 of the LFPDPPP and 60 through 66 of its Regulations.

Measures implemented include:

• HTTPS protocol (SSL/TLS) for secure data transmission on our website.
• Physical access controls at facilities where personal data is stored.
• Logical access control systems based on authentication and authorization.
• Periodic information backups.
• Staff training on personal data handling.
• Clean desk and clear screen policies.
• Periodic risk and vulnerability assessments.

XI. Changes to This Privacy Policy

DIMEM reserves the right to modify or update this Privacy Policy at any time, in response to legislative changes, internal policies, or new requirements for the provision or offering of our services or products.

Modifications will be made available to the public through the following means:

• Publication on our website: https://dimem.mx/en/privacy-policy.html
• Communication by email to the address registered by the data subject.
• Visible notice at our corporate offices.

We recommend that you periodically review this Privacy Policy to stay informed about how your personal data is protected.

XII. Guarantor Authority — National Transparency Institute (INAI)

If you believe that your right to personal data protection has been violated by any conduct or omission by DIMEM, or you suspect any violation of the provisions of the LFPDPPP and its Regulations, you may file the corresponding complaint or report with the National Institute of Transparency, Access to Information and Personal Data Protection (INAI).

For more information, visit https://home.inai.org.mx/ or call 800 835 4324 (toll-free within Mexico).

XIII. Applicable Law and Jurisdiction

This Privacy Policy is governed by the following legal provisions in force in the United Mexican States:

• Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) — published in the Official Gazette on July 5, 2010.
• Regulations of the Federal Law on Protection of Personal Data Held by Private Parties — published in the Official Gazette on December 21, 2011.
• Privacy Notice Guidelines — published in the Official Gazette on January 17, 2013.
• Self-Regulation Parameters for Personal Data Protection — published in the Official Gazette on January 17, 2014.
• Commercial Code.
• Federal Civil Code.
• Federal Labor Law (as applicable to employee and candidate data).
• Federal Tax Code and applicable tax legislation (regarding tax data).

For any dispute arising from this Privacy Policy, the parties submit to the jurisdiction of the competent courts in Mexico City, expressly waiving any other jurisdiction that may correspond to them by reason of their present or future domiciles or for any other cause.

XIV. Consent

By providing your personal data through any of our service channels (website, email, WhatsApp, physical forms, phone calls, or in-person visits), you consent to DIMEM processing your personal data in accordance with this Privacy Policy.

If you do not express your opposition to the transfer or processing of your personal data for the secondary purposes described in Section III, subsection B, it shall be understood that you have granted your tacit consent thereto, in accordance with Article 8 of the LFPDPPP.

XV. Personal Data Protection Department Contact Information