In compliance with the Federal Law on Protection of Personal Data Held by Private Parties, we want to inform the following:

RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

GRAN ARMEE DEL CABO S.A. DE C.V. and its affiliates and/or subsidiaries hereinafter GRAN ARMEE , residing in Conocido SN SN Paraíso, Cabo San Lucas, BCS, CP 23450; is responsible for the personal data, the use to be given to it and its  protection in accordance with this Privacy Notice.

PURPOSE OF THE PROCESSING OF PERSONAL DATA

Your personal data hold by GRAN ARMEE will be used for the next services:

Information services with news, and updates regarding Copala at Quivira Los Cabos Real Estate Complex. • E-mails or phone calls for data confirmation regarding any, offers received or to request identity of the client. Memberships. • Evaluate quality and service. • Internal analysis services. • Performance Evaluation in Personnel Recruitment, through interviews, contracts, reports to the Ministry of Labor and Social Welfare, Records Management, Payroll, letters of recommendation or any other internal documents related to the workplace. • Maintain a good communication with staff, customers and suppliers. PURPOSES THAT DONT GIVE ORIGIN TO THE LEGAL RELATIONSHIP, NOR ARE REQUIRED FOR THE SERVICE PROVISION:

Report on new services, products and events related to the above services, including advertising and newsletters, surveys, and changes.

PROFILE For the purposes described in this Privacy Notice, GRAN ARMEE may collect personal information in several ways: 1. When information is provided directly by you. 2. When you visit the Copala Los Cabos websites. 3. When you use the services offered by Gran Armee online. 4. When we get information through means other than those already mentioned, which are permitted by law. 5. Personal data obtained by the aforementioned means, may include: name, address, email address, phone number and any other required for the purposes set out in this Notice of Privacy.

SENSITIVE DATA

GRAN ARMEE will collect and process certain sensitive data. It´s considered Sensitive personal data that which affects the most intimate sphere of the proprietor, or whose misuse can lead to discrimination or involves a serious risk. In particular, those that might reveal sensitive issues such as racial or ethnic origin, health status, present or future, genetic, religious, philosophical and moral beliefs, union membership, political opinions, sexual preferences and such information may be collected by GRAN ARMEE from the clients, suppliers and probable employees; and may be used to improve or meet the needs of clients and the services that are provided to them, make payments and transfers to suppliers and analyze and evaluate the staff hiring. GRAN ARMEE agrees that sensitive personal data will be treated with strict security and confidentiality.

TRANSFER

GRAN ARMEE may transfer the personal data in its possession to companies belonging to the same corporate group. Also transfer personal data to third parties or subcontractors related to the provision of services, marketing purposes and market research within and outside the country.

If you do not object to your personal data being transferred, it will be understood you have consented to this. Therefore, if you do not accept this agreement, we ask you send an e-mail to  info@copalaloscabos.com or written notice to GRAN ARMEE DEL CABO S.A. DE C.V., established at Conocido SN SN Paraíso, Cabo San Lucas, BCS, CP 23450, to the Personal Data department in which you stipulate that you disagree on your personal data will being transferred.

LIMITATION OF USE AND DISCLOSURE OF PERSONAL INFORMATION

At any time you may express your refusal to treat the purposes that do not give origin to the legal relationship nor are required for the service provision, or the withdrawal of your consent you have given us in the processing of personal data, by application that must be submitted in writing to the Personal Data department at the following address: Conocido SN SN Paraíso, Cabo San Lucas, BCS, CP 23450, from 9:00 to 18:00 hours, Monday to Friday or email to  info@copalaloscabos.com . The application must contain at least the following: (i) Name of the owner of the personal data; (ii) e-mail to receive notifications; (iii) Documents proving your identity and, if applicable, the owner´s legal representative; (iv) A clear and accurate description of the personal data of which you seek to exercise the right and the right to be exercised. (v) Any other item or document that facilitates the location of the personal data. If the application does not satisfy any of the requirements listed above, the Personal Data department may require them within 5 days of receiving the request to provide the items or documents needed to process it. You will have 10 days to meet the requirement, if you should not respond within that period, the request or application should be considered not received.

The response periods in order to inform the decision will be of 15 days, counting from the date the application is received. And if it is positive you can make it effective within 15 days after the response is issued. In order to protect your privacy, GRAN ARMEE will send the response to your application to the email address you provide for this purpose and shall be available for the applicant at the address indicated in the previous paragraph.

MEANS TO EXERCISE RIGHTS (ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION) (ARCO)

To access the personal data that GRAN ARMEE possesses, as well to rectify them, if they are inaccurate or incomplete, or to cancel them or oppose their treatment for certain purposes, please submit a request in writing by e-mail addressed to our Personal Data department to  info@copalaloscabos.com or written notice to GRAN ARMEE DEL CABO S.A. DE C.V., residing at Conocido SN SN Paraíso, Cabo San Lucas, BCS, CP 23450, Monday through Friday from 9:00 to 18:00 hrs., containing the following information: • Name of the owner. Address or email to communicate the response. • Documents proving identity or authorization for representation for the application. • Description of the personal data you wish to exercise any ARCO right. • Any other element allowing the location of personal data.

If the application does not satisfy any of the requirements listed above, the Personal Data department may require within 5 days of receiving the request to provide the items or documents needed to process it. You will have 10 days to meet the requirement, if you should not respond within that period, the request or application should be considered not received.

The response to your request via email will occur within a period of 20 days from receipt, becoming effective within 15 days after the response.

MEANS TO REVOKE CONSENT

At any time, you can withdraw your consent to GRAN ARMEE to treat personal information by sending a written request via email to the Personal Data department to  info@copalaloscabos.com, or by sending a written notice to GRAN ARMEE DEL CABO S.A. DE C.V. with address Conocido SN SN Paraíso, Cabo San Lucas, BCS, CP 23450, Monday through Friday from 9:00 to 18:00 hrs., in which you clearly detail the personal data regarding the consent withdrawal.

Concerning the above, the procedure and terms set in the MEANS TO EXERCISE RIGHTS ARCO (ACCESS, RECTIFICATION, CANCELLATION AND OPPOSITION).

PERSONAL DATA OF MINORS OR PEOPLE IN STATE BAN OR STATUTORY DISABILITY

Some of the data we process include personal data of minors, people in state of ban or statutory disability. For the treatment of the data, we require the consent of the parents or legal guardians.

The exercise of access, the person exercising parental authority or guardianship can carry out rectification, cancellation or opposition rights.

SAFETY

GRAN ARMEE recognizes the value of personal data and so has implemented security measures that prevent its use for purposes other than those authorized, and their alteration, loss, theft or access by third parties. Among the measures the use of specialized computer programs, staff training, and adoption of internal data protection policies are included.

I hereby give my consent so my personal data can be processed by GRAN ARMEE in accordance with this Privacy Notice, same as I read and understand. Otherwise, I will inform emailing the of Personal Data department to info@copalaloscabos.com, or by sending a written notice to GRAN ARMEE DEL CABO S.A. DE C.V., with its address Conocido SN SN Paraíso, Cabo San Lucas, BCS, CP 23450.

NOTIFICATION OF CHANGES TO PRIVACY NOTICE

We reserve the right to make changes at any time or update this Privacy Notice to comply with any legislation, internal policies, and new requirements for the provision of GRAN ARMEE services or any other cause. In this case, the changes are available on the website https://copalaloscabos.com/ Privacy Notice. Therefore, we suggest visiting this Privacy Notice periodically to be aware of any updates.

I agree that my personal data is transmitted so information on products and services and third-party partners can be sent to me, as set out in this Privacy Notice and in case I disagree, I will communicate it to GRAN ARMEE, under the terms stated in this Privacy Notice.