clearway.com.mx Privacy Policy - Personal Data Protection

1. Introduction

At clearway.com.mx ("the Company"), we are committed to protecting the privacy and personal information of our clients, collaborators, suppliers, and users of our services. This Privacy Policy describes how we collect, use, protect, and share personal data in the context of our logistics, international trade, international consulting, multi-brand point-of-sale terminal implementation, banking integration, and eCommerce solutions activities.

The processing of personal data is carried out in accordance with the Federal Law on Protection of Personal Data Held by Private Parties (Mexico) and other applicable regulations.

2. Personal Data We Collect

The Company may collect the following categories of information:

2.1 Identification Data

• Name, company name, address, RFC or TIN.
• Official identification (when legally required).
• Contact details (phone, email).

2.2 Financial and Transactional Data

• Information necessary for international trade operations.
• Data related to payments, billing, and bank accounts.
• Information processed through point-of-sale terminals and banking integrations.

2.3 Operational and Commercial Data

• Information necessary for logistics, customs clearance, international transport, and tracking services.
• Data provided when contracting international consulting services.
• Information related to eCommerce operations and platform integration.

2.4 Technological Data

• IP addresses, device identifiers, cookies, geolocation (when authorized by the user).
• Access logs to platforms, control panels, or operating systems provided by the Company.

3. Purposes of Processing Personal Data

Personal data collected will be used for the following purposes:

3.1 Necessary Purposes (Do not require consent)

• Provide logistics, international transport, customs clearance, and foreign trade services.
• Comply with legal obligations before tax, customs, and international trade authorities.
• Perform implementation, configuration, and maintenance of point-of-sale terminals and banking integrations.
• Execute eCommerce operations, payment processing, and digital platform management.
• Billing, collection, and accounting administration.
• International consulting, foreign trade advisory, negotiation, reverse logistics, reshipment, and triangulation.

3.2 Secondary Purposes (Require consent)

• Send commercial information about new services, promotions, and updates.
• Conduct satisfaction surveys and market studies.
• Improve our services through data analysis.

If you do not wish your data to be used for secondary purposes, you may indicate so at: operacion@clearway.com.mx

4. ARCO Rights

As a personal data holder, you have the right to:

• Access: Know what data we have about you and what we use it for.
• Rectify: Request correction if your data is inaccurate or outdated.
• Cancel: Request deletion of your data when you consider it is not being used in accordance with the law.
• Object: Object to the processing of your data for specific purposes.

To exercise your ARCO rights, you may send a written request to:
Email: operacion@clearway.com.mx
Mexico Office: Prado Sur OF 1 ED.P. International Trade Office, C.P. 11000, Mexico City, Mexico
Miami Office: 1390 NW 107th Avenue Suite 200, Doral, Miami, FL 33172, USA

Your request must contain:
1. Full name and address.
2. Copy of your official identification.
3. Clear description of the right you wish to exercise.
4. Any document or information that facilitates the location of your data.

The Company will respond to your request within a maximum period of 20 business days from its receipt.

5. Security Measures

The Company has implemented administrative, technical, and physical security measures to protect your personal data against damage, loss, alteration, destruction, use, unauthorized access, or disclosure. These measures include:

• Encryption of sensitive data (SSL/TLS).
• Restricted access controls to authorized personnel.
• Internal confidentiality policies and staff training.
• Periodic information backups.
• Monitoring of technological platforms and eCommerce systems.

However, no system is 100% secure. The Company commits to notify data holders in case of security breaches that significantly affect their personal data, in accordance with applicable regulations.

6. Transfer of Personal Data

Your personal data may be shared with third parties in the following cases:

• With competent authorities (tax, customs, international trade) when required by law.
• With logistics service providers, transport, customs clearance, customs agents, shipping lines, airlines, and parcel operators.
• With banking institutions and payment processors for point-of-sale terminals, banking integration, and financial operations.
• With eCommerce platforms and technology providers necessary for the operation of our services.
• With corporate group companies (Logística Aduanal Internacional Fray Bernardino de Sahagún S.A. de C.V., American Customs & Logof clearway.com.mx

  All transfers are made under strict security and confidentiality measures. In case of transfers to third parties other than those mentioned, your prior consent will be requested.

7. Data Retention

The Company will retain your personal data only for the time necessary to fulfill the purposes for which it was collected, as well as to comply with legal, tax, accounting, and customs obligations that require information retention for specific periods.

Once the purposes are fulfilled or the legal deadline expires, the data will be deleted or anonymized.

8. Use of Cookies and Tracking Technologies

Our website and digital platforms use cookies and similar technologies to:

• Improve browsing experience.
• Analyze traffic and user behavior.
• Personalize content and services.
• Manage user sessions in eCommerce systems and administrative panels.

You can configure your browser to reject cookies. However, this may affect the operation of certain site functionalities.

9. Modifications to this Privacy Policy

The Company reserves the right to modify this Privacy Policy at any time. Any changes will be communicated through our website and, when appropriate, by email.

Last updated: December 11, 2025

10. Contact Information

For any questions, clarifications, or exercise of ARCO rights, you may contact us: