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BLINKËN · Blanco & Garzón
Legal

FULL PRIVACY NOTICE

Last updated: October 27, 2026

This English version is provided for convenience only. In case of discrepancy, the Spanish version prevails.

I. Identity and address of the Controller

BLINKEN, S.C. ("BLINKËN" or the "Controller"), operating under the trade names "Blinkën · Blanco & Garzón" and "blinkën business", with its address at Blvd. Adolfo López Mateos 3395, floor 2, Col. Rincón del Pedregal, Tlalpan Borough, C.P. 14120, Mexico City, is responsible for processing your personal data pursuant to the Federal Law on the Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation on March 20, 2025 (the "Law"). For any matter relating to your personal data, you may write to contacto@blinken.com.mx or call 55 4172 3844.

II. To whom this notice applies

Visitors to blinken.com.mx; persons who contact us or request a quotation or assessment; clients and their representatives, shareholders, directors and employees; users of the client portal; counterparties and third parties connected with the matters we handle; suppliers; and candidates seeking to work with the firm.

III. Personal data we process

  1. a) Identification and contact: name, company, position, email address, telephone number and address.
  2. b) Professional and employment: position, department, career history and, for candidates, curriculum vitae.
  3. c) Tax and billing: Federal Taxpayer Registry (RFC) number, tax regime, tax address and tax status certificate.
  4. d) Asset-related or financial: bank details for payments or reimbursements and asset-related information necessary for the matter (for example, shareholding structure, assets, transactions or contracts).
  5. e) Matter information: documents and information you provide for us to deliver our services, which may include third-party data.
  6. f) Client portal use: username, access logs, messages, comments and requests.

Sensitive personal data: we do not request such data through this website; please do not include it in forms or messages. If a matter requires us to process sensitive data (for example, relating to health, ethnic origin, beliefs, union membership or family life in employment, succession or compliance matters), we will obtain your prior express written consent through a handwritten signature, electronic signature or another authentication mechanism, pursuant to Article 8 of the Law, except where a statutory exception applies.

Third-party data: if you provide us with other persons' data (for example, employees, partners or counterparties), you declare that you have the authority or legal basis to do so and that you have informed them of this notice.

Minors: we do not intentionally collect minors' data through the website. Where a matter requires it, we will process such data with the consent of the person exercising parental authority or guardianship.

IV. Purposes of processing

Primary purposes (necessary for our relationship with you):

  1. 1. Respond to your requests for contact, information, assessments or quotations.
  2. 2. Check for potential conflicts of interest before accepting a matter.
  3. 3. Enter into, document and perform the relationship for the provision of legal and business consulting services.
  4. 4. Provide the contracted services, including advice and representation before courts, administrative authorities, notaries, commercial notaries, public registries, the IMPI and the INDAUTOR.
  5. 5. Issue invoices, collect payments and comply with tax and accounting obligations.
  6. 6. Grant access to and administer the client portal, including status reports, messages and requests.
  7. 7. Comply with legal obligations, including client and controlling-beneficiary identification requirements and, where applicable, those under the Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds.
  8. 8. Protect information security and prevent fraud.
  9. 9. Establish, exercise or defend BLINKËN's rights.

Secondary purposes (not necessary for the relationship):

  1. a) Send you Radar, legal alerts, publications and invitations to events.
  2. b) Conduct satisfaction and quality surveys.
  3. c) Prepare internal statistics using aggregated information.
  4. d) Mention your company's name or logo as a reference for the firm, solely with your prior express authorization.

If you do not wish your data to be processed for any secondary purpose, please leave the corresponding checkbox unselected or email contacto@blinken.com.mx at any time with the subject line "Refusal of secondary purposes". Your refusal will not be grounds for denying you our services.

V. Consent

By making this notice available to you before collecting your data, we understand that you consent to processing for primary purposes unless you express an objection (implied consent, Article 7 of the Law). For asset-related or financial data, we will obtain your express consent unless a statutory exception applies; for sensitive data, we will obtain your express written consent.

VI. Transfers

We may transfer your data without your consent in the circumstances set out in Article 36 of the Law, particularly:

  1. a) to courts, administrative and registry authorities, notaries and commercial notaries, where necessary for the matter or required by law or a competent authority (paragraphs I, V and VI);
  2. b) to collaborating law firms, of counsel or correspondent counsel in Mexico or abroad, experts and translators, where necessary to provide the service you contracted (paragraphs IV and VII).

In all cases, we will communicate this notice to the recipient and the purposes to which the recipient must adhere. We do not sell or assign your data. If we need to make a transfer requiring your consent in the future, we will request it beforehand.

VII. Processors

Providers processing data on behalf of BLINKËN solely to provide their services to us and subject to contractual confidentiality and security obligations: website and portal hosting, email, cloud storage, electronic signatures, external accounting and courier services. Some may be located outside Mexico, for example in the United States.

VIII. ARCO rights

You may access, rectify, cancel or object to the processing of your data (ARCO rights). Please send your request to contacto@blinken.com.mx with:

  1. 1. your name and the means by which we may communicate our response;
  2. 2. documents establishing your identity or, where applicable, your representative's authority (a letter of authorization signed before two witnesses or a notarized power of attorney);
  3. 3. a clear description of the data and the right you wish to exercise, except in the case of the right of access;
  4. 4. any information that facilitates locating your data.

We will respond within a maximum of 20 days from receipt of your request and, if granted, implement it within 15 days following our response. Both periods may be extended once for an equal period where circumstances justify it (Article 31 of the Law). Exercising these rights is free of charge; only reproduction, copying or delivery costs may be charged, where applicable (Article 34). A request may be denied in the circumstances set out in Article 33 of the Law; in that case, we will explain the reason.

IX. Withdrawal of consent

You may withdraw your consent at any time, without retroactive effect, through the same means and subject to the same requirements as in the preceding section. Withdrawal is not available where a legal obligation or an ongoing legal relationship requires us to continue processing your data, and it may mean that we cannot continue providing the service.

X. Limitation of use or disclosure

You may ask us to stop sending communications or limit the use of your data by writing to contacto@blinken.com.mx; we will add you to our internal exclusion list. You may also register with the Public Registry to Avoid Advertising (REPEP) maintained by the Federal Consumer Protection Agency (PROFECO).

XI. Retention

We retain your data during the relationship and thereafter for the periods required by applicable laws (for example, Article 30 of the Federal Tax Code) and the limitation periods for claims that may arise from it. Once those periods expire, we will block and securely delete the data.

XII. Security and professional confidentiality

We apply administrative, technical and physical security measures to protect your data against damage, loss, alteration, destruction or unauthorized use, access or processing. Our clients' information is also protected by the professional duty of confidentiality applicable to lawyers. If a security breach significantly affects your rights, we will inform you without delay so that you can take action.

XIII. Cookies and similar technologies

This website does not use tracking, analytics or advertising cookies. It only stores a local record in your browser indicating that you have already seen the cookie notice and, in the portal, the session data necessary for it to function. Please consult the cookie policy.

XIV. Changes to this notice

We will publish any changes at blinken.com.mx/aviso-de-privacidad, indicating the update date. If a change is substantial, we will also notify our clients by email.

XV. Authority

If you believe your right to personal data protection has been infringed, you may contact the Ministry of Anti-Corruption and Good Governance (Secretaría Anticorrupción y Buen Gobierno), the competent authority under the Law.