GaxiolaCalvo

Notice of Privacy

GaxiolaCalvo — SC
Av. Eugenia 807, Col. Del Valle
03100 Mexico City

Gaxiola Calvo, S.C. (the “Firm”) (formerly Gaxiola, Calvo Sobrino y Asociados, SC, between 2011 and 2015), is committed to providing certainty and security to its clients and potential clients regarding the confidentiality with which their personal information will be treated as well as the information derived from and related to their affairs.

Personal Data and Form of Collection
The Firm provides its services mainly to legal entities and/or as Representative of our clients; however, in some cases, either as a client or for other reasons, we collect data from individuals.

The data will be collected by the Partners or the Firm's staff, directly from you or, as necessary, from documents of any nature that are delivered to us.

The personal data that will be collected will be determined, in each case, according to the services provided to the client and may include, among others, name and contact information (including address, telephone numbers, personal email, among others); family information and patrimonial data, such as information on movable and immovable property, banking information and income, as well as any other information required by the applicable regulations.

The Firm will not collect sensitive personal data, except when they are essential to provide the services. In this case, the Firm will only keep the data for as long as it is necessary to provide the service and/or for the time required in accordance with applicable laws.

The data of individuals who provide their services for a legal entity consisting of their name and surname, the functions or positions held, as well as the following work data (address, email, telephone and fax number) that are processed for representation purposes of the employer or contractor, are excluded from the scope of this Privacy Notice, in accordance with the provisions of the Regulations of the Federal Law on Protection of Personal Data Held by Individuals.

Purposes and Transfer of Personal Data
In those cases in which we collect personal data, through this or any other means, these will be used for the development of legal consultations and the provision of legal services by the Firm, research and market analysis, for the sending of information of issues relevant to the services provided, as well as to comply with legal requirements that, where appropriate, are applicable.

The Firm will not transmit your personal data to third parties except as necessary to comply with the services you have requested from the Firm, when we have your prior consent or instructions from your clients or potential clients or in the cases established and in accordance with the applicable regulations. Also, you can be confident that your personal data will be processed exclusively by those people who carry out activities that require knowledge of said data.

In order to prevent unauthorized access to your personal data and in order to ensure that the information is used for the purposes established in this Privacy Notice, we have established physical, electronic and administrative procedures, which limit the use or disclosure of your data, allowing us to treat them properly.

Secondary purposes
Your basic contact details (name, address, email, telephone and fax) may be processed by the Firm for marketing, advertising or commercial prospecting purposes, for academic analysis and research and to send you information of interest or our newsletter.

Request for Access, Rectification, Cancellation or Opposition of Personal Data and Revocation of Consent.
You have at all times the right to access, rectify, cancel or oppose the treatment that we give to your personal data (the "ARCO Rights"), as well as to revoke the consent granted for the treatment thereof; you may enforce this right through the Firm’s Special Unit for Personal Data Protection, whose details appear below. It is important to mention that although the exercise of your ARCO Rights is free, the Firm may request the payment of justified shipping costs, among others.

In order to protect your personal data, we may ask you for documentation proving your personality as well as supporting your request to rectify, oppose and/or cancel personal data. We also ask you to consider that the Firm may not be able to cancel or block all of your personal data in accordance with the applicable laws, including legal or regulatory provisions on employment matters.

Revocation of Consent
If you do not want us to process your personal data for any of the secondary purposes indicated in this Privacy Notice, you can tell us by email, and you should receive a response to your request. Where appropriate, we will inform such revocation to third parties that may have access to your data.

Limitation of the use
In order to limit the use of your personal data, you may request, through the Special Unit for Personal Data Protection, the inclusion of your data within the Firm's exclusion lists, in which case the Firm will provide you with a certificate. Your inclusion in such list will be free.

Modifications
This privacy notice may be modified from time to time by the Firm. Said modifications will be duly informed through our website www.gaxiolacalvo.com.mx, or any other means of oral, printed or electronic communication that the Firm determines for that purpose.

For any questions or clarification, as well as for the exercise of your ARCO Rights, please contact Martha Robles, from the Special Unit for Personal Data Protection. Telephone: 56826178. Hours: 09:00 to 14:00. Email: mrobles@gcsa.com.mx.

Last updated March 20, 2019.

Privacy Notice for candidates, employees and partners

GaxiolaCalvo — SC
Av. Eugenia 807, Col. Del Valle
03100 Mexico City

Gaxiola Calvo, S.C. (the “Firm”) (formerly Gaxiola, Calvo Sobrino y Asociados, SC, between 2011 and 2015), is committed to providing certainty and security to its clients, potential clients, employee candidates, employees and partners regarding the confidentiality with which their personal information will be treated.

Personal Data and Form of Collection
The data will be collected by the Partners or the Firm's staff, directly from you or, as necessary, from documents of any nature that are delivered to us.

The personal data that will be collected shall include name and contact information (including address, telephone numbers, personal email, among others); family information and patrimonial data, such as information on movable and immovable property, banking information and income, data about your work, credit or criminal history, as the case may be, as well as any other information required by the applicable regulations.

The Firm will collect the following sensitive personal data, as necessary: biometric data for access and security records of the firm; medical data in order to address medical emergencies that occur in the workplace; data about your religion, in case you decide to share them, for the purpose of providing assistance and/or special conditions that said religion requires. In this case, the Firm will only keep the data for as long as it is necessary to provide the service and/or for the time required in accordance with applicable laws.

Purposes and Transfer of Personal Data
In the case of employees, the personal data you provide us will be used for all purposes related to training, development, payment of employment benefits, employment relationship and compliance with tax obligations. In the case of candidates, the personal data that you provide us directly or through a third party when sending your curriculum vitae will be used to contact you in the event that your profile is of interest to the firm and, where appropriate, to initiate the selection and recruitment process.

The Firm will not transmit your personal data to third parties except when it is necessary to comply with the aforementioned purposes as well as to provide benefits, such as medical insurance, among others, or in the cases provided by and in accordance with the applicable regulations.

In order to prevent unauthorized access to your personal data and in order to ensure that the information is used for the purposes established in this Privacy Notice, we have established physical, electronic and administrative procedures, which limit the use or disclosure of your data, allowing us to treat them properly.

Secondary purposes
Your basic contact details (name, address, email, telephone and fax) may be processed by the Firm for marketing, advertising or commercial prospecting purposes, for academic analysis and research and to send you information of interest or our newsletter.

Request for Access, Rectification, Cancellation or Opposition of Personal Data and Revocation of Consent
You have at all times the right to access, rectify, cancel or oppose the treatment that we give to your personal data (the "ARCO Rights"), as well as to revoke the consent granted for the treatment thereof; you may enforce this right through the Firm’s Special Unit for Personal Data Protection, whose details appear below. It is important to mention that although the exercise of your ARCO Rights is free, the Firm may request the payment of justified shipping costs, among others.

In order to protect your personal data, we may ask you for documentation proving your personality as well as supporting your request to rectify, oppose and/or cancel personal data. We also ask you to consider that the Firm may not be able to cancel or block all of your personal data in accordance with the applicable laws, including legal or regulatory provisions on employment matters.

Revocation of Consent
If you do not want us to process your personal data for any of the secondary purposes indicated in this Privacy Notice, you can tell us by email, and you should receive a response to your request. Where appropriate, we will inform such revocation to third parties that may have access to your data.

Limitation on Use
In order to limit the use of your personal data, you may request, through the Special Unit for Personal Data Protection, the inclusion of your data within the Firm's exclusion lists, in which case the Firm will provide you with a certificate. Your inclusion in such list will be free.

Modifications
This privacy notice may be modified from time to time by the Firm. Said modifications will be duly informed through our website www.gaxiolacalvo.com.mx, or any other means of oral, printed or electronic communication that the Firm determines for that purpose.

For any questions or clarification, as well as for the exercise of your ARCO Rights, please contact Martha Robles, from the Special Unit for Personal Data Protection. Telephone: 56826178. Hours: 09:00 to 14:00. Email: mrobles@gcsa.com.mx.

Last updated March 20, 2019.

Partners

F. Jorge Gaxiola Moraila

F. Jorge Gaxiola Moraila

Jorge is one of the main legal advisers for the leading financial institutions in Mexico, the Mexican Association of Banks and the Business Coordinating Council. He has participated in several of the most relevant legal reforms in constitutional and commercial matters on behalf of his clients, including the Fintech Law, the Financial Reform, the Amparo Law and the new Federal Competition Law, among others. He has acted as an advisor to the federal government in the constitutionalization of indigenous rights and the design and implementation of Round Zero of the energy reform, for example, and as an arbitrator in commercial disputes or advisor in commercial bankruptcies. Jorge has been a consultant on constitutional and financial aspects during litigation and has coordinated multidisciplinary teams. He was appointed by the President of Mexico as a counselor of PRODECON and has been a counselor of the National Bioethics Council (2010-2016). Jorge has consistently been ranked highly in international guides, such as Chambers and Partners.

He was Chairman of the Rule of Law Commission of the Business Coordinating Council. He is Chairman of the Disciplinary Committee for the Mexican Stock Exchange and a member of the Board of Directors of AXA Seguros and Chairman of its Audit Committee.

Jorge Gaxiola has been a professor at the Escuela Libre de Derecho since 1987, where he was Rector from 2008 to 2010. Author of various studies on legal-financial matters, as well as Philosophy of Law, and is a member of the Editorial Board of the magazine Isonomía. He is a member of the Mexican Academy of Jurisprudence and Legislation and also of the Barra Mexicana, Colegio de Abogados.

Lawyer from the Escuela Libre de Derecho (honorable mention and awarded thesis).

jgaxiola@gcsa.com.mx

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José Antonio Calvo Díaz

José Antonio Calvo Díaz

Antonio Calvo has been classified by CHAMBERS and Partners, Who’s Who Legal and Best Lawyers Mexico as a distinguished lawyer in Project Financing. He has extensive experience in administrative concessions, public works and services contracts, public-private partnerships and public tenders (bidding) in general.

He is also a specialist in subnational debt. He has led complex restructuring of state public debt, including that of the States of Mexico, Coahuila and Michoacán. He has participated in major credit restructurings and as a bank advisor in complex bankruptcies.

Before joining the firm in 2000, Antonio Calvo worked for banking institutions, where he developed mainly in the area of credit recovery (workout).

With over twenty years’ experience in project finance, Antonio has acted as an advisor to banking institutions, concession companies, construction companies, state governments and rating agencies.

He has successfully participated in the phases of design, risk assessment, tenders (bidding), concession, contracts, financing, securitization, rebalancing and restructuring of public and private projects of various kinds, especially in operations related to the communications and transportation sector, as well as in states and municipalities’ financing operations.

He has a law degree from Escuela Libre de Derecho.

Languages: Spanish and English.

jacalvo@gcsa.com.mx

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Alexis León Trueba

Alexis León Trueba

He has a law degree from Universidad Latinoamericana and a master's degree in business law from the Universidad Panamericana (UP).

Alexis specializes in the areas of financial and regulatory law, banking, real estate, project financing and consulting on legal and regulatory reforms. He has acted as an advisor to several Mexican banks, including some of the largest and most specialized, regarding digital integration, electronic banking and investments in Fintech.

He has also participated as an advisor in the incorporation, purchase and sale of financial entities, including insurance companies.

In legal and regulatory matters, he has acted as advisor to the Mexican Association of Banks and various credit institutions during the negotiations and development of the Financial Reform, the Fintech Law, regulations on APIs and, currently, the drafting of the Law of Indigenous Consultation for the Business Coordinating Council.

In transactional matters, he has structured various financing operations by financial entities in several branches including hotels and hydrocarbons and he has participated in public financing operations.

aleon@gcsa.com.mx

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Gabriel Franco Fernández

Gabriel Franco Fernández

He has a law degree from the Instituto Tecnológico Autónomo de México (ITAM). He also has a master's degree from the University of Toronto focused on corporate and constitutional law.

He specializes in research, including regulation of financial entities, electronic means, protection of personal data, administrative law and financial operations. Gabriel has worked with various financial groups and financial technology entities in local and cross-border consulting. Within the firm, he has provided advice to union groups such as the Association of Banks of Mexico and the Business Coordinating Council.

In regulatory matters, he has participated in the incorporation of financial entities and groups and provided advice on corporate governance, internal control, communication with authorities, regulatory compliance, prevention of money laundering and contracts and operations with clients. As part of the support to trade associations, he has carried out research and studies related to the issuance of regulations in different matters, including electoral law, antitrust law and corporate law.

In transactional matters, he has structured various financing operations by financial entities and he has participated in public financing operations.

gfranco@gcsa.com.mx

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Yazmín Yohana Aquino Barrueta

Yazmín Yohana Aquino Barrueta

She has a law degree from Escuela Libre de Derecho, with diplomas in Environmental Law and Natural Resources and in Corporate Law from the Instituto Tecnológico Autónomo de México.

Before joining the firm, she worked at Banco de México and at Cárdenas, Munive, Domínguez y Medal, S.C. law firm.

Areas of expertise: instrumentation of project financing operations through banks and the stock market, administrative law and public debt operations.

She has participated, among others, in various asset securitizations, indebtedness and restructuring operations of states and municipalities, administrative procedures for obtaining and/or modifying concessions in terms of infrastructure, the financing of the first Comprehensive Sustainable Urban Development in Mexico, municipal, state and federal public-private associations and environmental audits.

Languages: Spanish and English.

yaquino@gcsa.com.mx

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Associates

Jesús E. García López

Jesús E. García López

He has a law degree from the Universidad Tecnológica de México. He also has a postgraduate degree from the Universidad Panamericana regarding constitutional reforms and financial reform.

Areas of expertise: consultations related to the banking, financial, mortgage and social security sectors. Audits for the sale of companies, as well as regularization of companies.

Analysis and preparation of proposals for legislative projects related to the banking sector.

Languages: Spanish and English.

jgarcia@gcsa.com.mx

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Luis Alfredo García Fuentes

Luis Alfredo García Fuentes

Alfredo obtained his law degree (J.D.) from the Escuela Libre de Derecho in 2015.

Alfredo joined the firm in June 2014. Since then, he advises our clients on regulatory issues relating to local financial institutions (AML, digital banking, FinTech regulation, standard form agreements requirements, etc.), as well as on matters including competition/antitrust and personal data protection. He also has experience in project finance and corporate/M&A transactions, as well as in the analysis of bills and secondary regulation drafts with possible effects on the financial sector.

Before joining the Firm, he worked for the Unidad de Evaluación y Control (Evaluation and Control Unit) of the Cámara de Diputados (Chamber of Deputies) and for Goodrich, Riquelme y Asociados (Corporate/M&A).

In the academic field, Alfredo studied a post-graduate course (Diplomado) on Competition/Antitrust Law at the Universidad Panamericana. Additionally, he has attended to several courses taught by the Mexican Bar Association of Lawyers and by the International Chamber of Commerce on digital banking, antitrust, FinTech Reg and administrative responsibilities of individuals.

Languages: Spanish and English.

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María Dolores Manzanero Gaxiola

María Dolores Manzanero Gaxiola

She has a law degree from the Universidad Panamericana and a Master's degree in International Business Law LL.M. from King’s College London.

Before joining the firm, she worked in corporate law, M&A (mergers and acquisitions), real estate, project financing and Infrastructure.

Areas of expertise: currently, her work is focused on the implementation of project financing operations, subnational debt operations, contracts for the development of public works and the provision of public services, contracts under the modality of Public-Private Partnerships (APPs), restructuring and refinancing of private debt, corporate law and legal audits.

Languages: Spanish and English.

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Susana Gabriela Sabido Rodríguez

Susana Gabriela Sabido Rodríguez

She has a law degree from Universidad La Salle. She is also in the process of obtaining a master’s degree in financial law from the Universidad Panamericana.

She has worked with a notary public, as well as in the area of civil litigation and representation of financial institutions before the CONDUSEF.

Areas of expertise: her practice is focused on consulting in financial and banking regulations.

Languages: Spanish and English.

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Rafael García Luna

Rafael García Luna

Bachelor of Law from the Universidad Nacional Autónoma de México (2015). Master’s degree in financial law from Universidad Panamericana (2021).

Prior to joining the firm, Rafael was an associate at a prestigious law firm in Mexico as part of the banking and finance team. His experience also includes the Mexican public sector at the Ministry of Finance and Public Credit specifically in the Banking, Securities and Savings Office.

Areas of expertise: Banking and financial law, regulation of financial institutions (traditional and digital services), Fintech, virtual assets and Anti Money Laundering prevention.

Languages: Spanish and English.

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Carolina Guadalupe Urreola Torrez

Carolina Guadalupe Urreola Torrez

Carolina has a law degree from Escuela Libre de Derecho (2017) and a financial law certificate from Universidad Nacional Autónoma de México (2020).

Before joining the firm, Carolina worked in one of the biggest financial entities in Mexico, structuring loans and securities transactions through the trust sector. In regulatory matters, she has advised different entities in the implementation of regulation on Anti-Money Laundering and Criminal Liability of Corporations (financial and property crimes).

Areas of expertise: Advise on financial and banking regulation, structuring loans and securities transactions.

Languages: Spanish and English.

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Jorge Efraín González Aranda

Jorge Efraín González Aranda

He has a law degree from Escuela Libre de Derecho (honorable mention), with diplomas in banking and financial matters.

Before joining the firm, he worked in a recognized Mexican law firm related to corporate, financial and capital markets operations and later in an international accounting and law firm.

Areas of expertise: Instrumentation of project financing operations through banks and stock market, administrative law and public financing operations.

Languages: English and Spanish.

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Andrés Carrillo Vidal

Andrés Carrillo Vidal

Student at Escuela Libre de Derecho. Accredited by The Entrepreneurial Learning Initiative.

Prior to joining the firm, Andrés worked with a notary public.

Languages: English and Spanish.

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Anahí Lucero Castillo García

Anahí Lucero Castillo García

She has a law degree from Escuela Libre de Derecho (honorable mention).

Prior to joining the firm, she worked at the Supreme Court of Mexico, and as a legal assistant at a Business group.

Areas of expertise: Constitutional law, human rights, corporative and administrative law.

Languages: Spanish and English.

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Marco Antonio Inclan Sánchez

Marco Antonio Inclan Sánchez

Student in the Escuela Libre de Derecho.

Before entering de legal firm, he worked in banking law and in international law.

Languages: English and Spanish.

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