PRIVACY NOTICE

I. Identity and Domicile of the Data Controller.

DISRUPTIVE CITIES SAPI DE C.V. (hereinafter referred to as “AIWIFI”), domiciled at Insurgentes Sur 64, TA, Floor 14, Colonia Juárez, Alcaldía Cuauhtémoc, C.P. 06600, Mexico City, Mexico, is the entity responsible (Data Controller) for the processing of your personal data, the use given to it, and its protection, in compliance with the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), its Regulations, and other applicable regulations.  

II. Personal Data We Collect and Use.

To carry out the purposes described in this Privacy Notice, AIWIFI may collect and use the following personal data:

  1. Identification Data: Full name, Federal Taxpayers Registry (RFC).
  2. Contact Data: Tax or business address, work or personal email address, landline or mobile phone number.
  3. Billing Data: Information necessary for issuing tax invoices.
  4. Platform and Service Usage Data: Information about how you interact with our SaaS platform, applied configurations, technical support history, IP address, unique device identifiers (such as MAC address, when necessary for service provision or support), browser type, and operating system.
  5. End-User Data (processed as Data Processor): When you contract AIWIFI’s services to offer WiFi connectivity and associated services to your own customers (end-users), AIWIFI, acting as a Data Processor under your instructions, may process personal data of such end-users, such as: name, email address, phone number, survey responses (including NPS), authentication data (e.g., social media logins, if applicable), device MAC address, IP address assigned during connection, and aggregated or session-associated Browse data within the captive portal, according to the configuration you, as the Data Controller, determine. The lawfulness of the processing of this data is the responsibility of the AIWIFI contracting client (Data Controller).

III. Sensitive Personal Data.

AIWIFI DOES NOT collect sensitive personal data (such as racial or ethnic origin, present or future health status, genetic information, religious, philosophical, or moral beliefs, union membership, political opinions, sexual preference) through its website or for contracting its main services. In the event that you, as a client (Data Controller), configure surveys through our platform that could collect data considered sensitive from end-users, it will be your responsibility to obtain explicit consent and comply with the applicable obligations under the LFPDPPP.  

IV. Purposes of Personal Data Processing.

We use the personal data we collect for the following purposes:

A. Primary Purposes (Necessary for the legal relationship):

  1. To verify and confirm your identity as a prospect or client.
  2. To create and manage your account on the AIWIFI platform.
  3. To provide, operate, and maintain the contracted SaaS services, including the captive portal, data analytics, and marketing tools configured by you.
  4. To process end-user data as a Data Processor, following your instructions as the Data Controller, to show you analytics and allow you to manage your service.
  5. To provide technical support and customer service.
  6. To manage billing and collection for services.
  7. To comply with legal and contractual obligations arising from the relationship with you.
  8. To maintain the security of our platform, networks, and systems.
  9. To contact you to follow up on the contractual or pre-contractual relationship.

B. Secondary Purposes (Not necessary, but allow us to provide better service):

  1. To send you informational communications, newsletters, promotions, and advertising about AIWIFI’s products, services, events, or news.
  2. To conduct quality surveys about our services and customer care.
  3. To generate aggregated statistics and internal analyses to improve our products and services (using dissociated or anonymized data whenever possible).

V. Refusal for the Processing of Secondary Purposes.

You have the right to object to the processing of your personal data for secondary purposes. If you do not want your data to be processed for any or all secondary purposes, you can express your refusal at this time by sending an email to: [email protected], clearly indicating which secondary purposes you object to.

Your refusal to allow the use of your personal data for these secondary purposes will not be a reason for us to deny you the services and products you request or contract with us (primary purposes).  

VI. Use of Cookies, Web Beacons, and Similar Technologies.

We inform you that on our website www.aiwifi.io and potentially on our platform, we use cookies, web beacons, and other similar technologies through which it is possible to monitor your behavior as an Internet user, provide you with better service and experience when Browse our site, and offer you new products and services based on your preferences.  

The personal data we may obtain from these tracking technologies include: Browse time, duration of time spent on our website, sections consulted, websites accessed prior to ours, IP address, browser type, and operating system.

These technologies can be disabled by following the procedures of the internet browser you use. You can consult the cookie configuration options in your browser’s preferences or settings menus. For more information, consult your browser’s help section.

VII. Data Transfers.

AIWIFI may transfer your personal data, without requiring your consent, in the following cases provided for by Article 37 of the LFPDPPP:

  • To holding companies, subsidiaries, or affiliates under the common control of AIWIFI, or to a parent company or any company of the same group operating under the same internal processes and policies.
  • When necessary by virtue of a contract concluded or to be concluded in your interest, by AIWIFI and a third party (e.g., service providers necessary to fulfill our contractual obligations).  
  • When the transfer is necessary for the maintenance or fulfillment of the legal relationship between AIWIFI and you (e.g., to billing or collection providers).
  • When the transfer is legally required for the safeguarding of public interest, or for the procurement or administration of justice.
  • To competent authorities in legally foreseen cases.

Furthermore, AIWIFI may transfer your personal data to third-party service providers (Data Processors) acting on behalf of AIWIFI to fulfill primary purposes, such as providers of technological infrastructure and cloud storage (including Amazon Web Services (AWS) whose servers may be located in the United States of America), email delivery service providers, or customer relationship management platforms, among others. AIWIFI ensures, through the signing of contracts and/or data protection clauses, that these third parties maintain adequate security measures and process the data exclusively for the purposes instructed by AIWIFI.

AIWIFI WILL NOT transfer your personal data to third parties for their own marketing or advertising purposes unless we obtain your prior explicit consent.

VIII. Means to Exercise ARCO Rights (Access, Rectification, Cancellation, and Opposition).

You have the right to know what personal data we hold about you, why we use it, and the conditions of its use (Access). Likewise, it is your right to request the correction of your personal information if it is outdated, inaccurate, or incomplete (Rectification); that we delete it from our records or databases when you consider that it is not being used in accordance with the principles, duties, and obligations provided for in the regulations (Cancellation); as well as to oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.  

To exercise any of the ARCO rights, you must submit the respective request by sending an email to [email protected]. Your request must contain and be accompanied by the following:  

  1. Your full name and address or other means to communicate the response to your request.
  2. Documents proving your identity (copy of valid official identification) or, where applicable, the legal representation of the data subject.
  3. A clear and precise description of the personal data with respect to which you seek to exercise any of the aforementioned rights.
  4. Any other element or document that facilitates the location of the personal data.  

AIWIFI will communicate the decision adopted to you within a maximum period of twenty (20) business days from the date the request was received. If the request is deemed appropriate, it will become effective within fifteen (15) business days following the date on which the response is communicated.

You can request the “ARCO Rights Request Form” via email at [email protected].

IX. Mechanism to Revoke Consent.

You may revoke the consent that you have granted us for the processing of your personal data at any time. However, it is important to note that we may not always be able to attend to your request or conclude the use immediately, as it is possible that due to some legal obligation, we may need to continue processing your personal data. Likewise, you should consider that for certain purposes, revoking your consent may imply that we can no longer provide the service you requested or the termination of your relationship with us.  

To revoke your consent, you must submit your request by sending an email to [email protected], following the same procedure and requirements as for exercising ARCO rights.  

X. Security Measures.

AIWIFI 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 the LFPDPPP and its Regulations.  

XI. Changes to the Privacy Notice.

This Privacy Notice may undergo modifications, changes, or updates arising from new legal requirements; our own needs for the products or services we offer; our privacy practices; changes in our business model, or other causes.  

We commit to keeping you informed about the changes that this Privacy Notice may undergo through our website www.aiwifi.io, in the corresponding Privacy section, or via direct communication to your email address if we have it.  

XII. Consent.

It will be understood that you grant your consent for the processing of your personal data under the terms of this Privacy Notice if you do not expressly state your opposition to it through the indicated means. For the processing of billing data and potentially others that may require it, consent will be understood as granted at the moment you actively provide them for the required purpose.

Last Updated Date: April 25, 2025.