Privacy Policy

Last updated: 11 December 2025
  1. Introduction

At Logística Aduanero Internacional Fray Bernardino de Sahagún S.A. de C.V., American Customs & Logistics Services S.A. de C.V., and Clearway Global Trading Services LLC («the Company»), we are committed to protecting our customers’ privacy and personal information, partners, suppliers and users of our services. This Privacy Policy describes how we collect, use, protect and share personal data as part of our logistics activities, international trade, international consulting, implementation of multi-brand point of sale terminals, banking integration and eCommerce solutions.

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

  1. 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 (where legally required).

Contact details (telephone, e-mail).

2.2 Financial and Transaction Data

Information required for international trade transactions.

Data related to payments, invoicing and bank accounts.

Information processed through point-of-sale terminals and banking integrations.

2.3 Operational and commercial data

Information needed for logistics, customs clearance, international transport and tracking services.

Data provided in contracting international consulting services.

Information related to eCommerce operations and platform integration.

2.3 Operational and commercial data

Information needed for logistics, customs clearance, international transport and tracking services.

Data provided in contracting international consulting services.

Information related to eCommerce operations and platform integration.

2.4 Technological data

IP addresses, device identifiers, cookies, geolocation (when the user authorizes it).

Logs of access to platforms, control panels or operating systems that the Company provides.

  1. Purposes of the Processing

Personal data will be used for the following purposes:

3.1 Primary Purposes

Provision of logistics and international trade services.

Processing of customs operations, transport, storage and tracking.

Implementation, management and maintenance of multi-brand point of sale terminals.

Banking integration and electronic payment processing.

Provision of international consultancy and foreign trade analysis services.

Management of eCommerce operations and related technology solutions.

Compliance with contractual, regulatory and tax obligations.

3.2 Secondary purposes

  • Statistical, operational and performance analysis.
  • Continuous improvement of our services and platforms.
  • Sending of commercial or promotional information (only in case of express authorization by the holder).
  1. Transfer of personal data

The Company may transfer personal data only in the following cases:

Customs, tax and regulatory authorities for compliance with international trade rules.

Banking institutions, exclusively for authorized operations and under certified security environments.

Technology platforms and service providers, necessary for the operation of POS, eCommerce developments and logistics systems.

Transport, storage or business partners only to perform the contracted services.

In no case will data be transferred for purposes other than those set out in this Policy without prior consent.

  1. Safety measures

The Company takes administrative, physical and technical measures to protect personal data, including:

Encryption of information in transit and storage.

Access control and advanced authentication.

Regular audits of systems and compliance.

Internal confidentiality, privacy and restricted use policies.

  1. ARC Rights

Holders of personal data may exercise their rights of access, rectification, cancellation and opposition (ARCO) by sending a request to:

📧 operations@clearway.com.mx

📞 +52 56 6152 7154

The application shall include:

Full name of holder.

Official identification.

Clear description of the right to exercise.

Documents related to the application (where applicable).

The Company will respond within the time limits set by law.

  1. Retention of Data

Personal data will be kept only for the time strictly necessary to comply with:

The provision of services.

Tax, customs and regulatory obligations.

Contractual responsibilities.

Legitimate business interests of the Company.

After the retention period, the data will be securely deleted.

  1. Use of Cookies and Similar Technologies

Our website and platforms may use:

Essential cookies

Performance cookies

Web beacons

Traffic analysis tools

You can disable cookies from your browser. However, certain functions may be affected.

  1. Changes to the Privacy Policy

The Company reserves the right to make changes to this Policy to comply with legal, regulatory or internal improvements updates. Such changes will be made available on our website or by direct notice to the holders, where applicable.

  1. Contact

For any questions related to this Policy or the processing of your personal data, you may contact our Privacy Officer:

Contact:

Telephone

📞 +52 56 6152 7154

E-mail

✉️ operations@clearway.com.mx

Address – Mexico

📍 Prado Sur 150, Office 1, Building P

Lomas de Chapultepec V Section

Miguel Hidalgo, C.P. 11000

Mexico City, Mexico

Address – Pachuca

📍 Nicolas Bravo 100, Centro, CP 42000,

Pachuca de Soto, Hidalgo

Address – United States

📍 33 SW 2nd Ave, Suite 1202

Miami, FL 33130-1585

United States

Website

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