Privacy Notice

ICR Inmobiliario

This notice is still being completed. Two items are not published yet — the data controller's registered legal name and the email designated for ARCO requests, both highlighted below. Until they are, we do not ask for checkbox consent to process property and financial data: if you want a valuation, message us on WhatsApp or call. For anything concerning your data, reach us at the phone number and email published on our contact page.

This is a courtesy translation. The binding privacy notice is the Spanish version, which is the instrument required under Mexican law. If anything here differs from it, the Spanish text governs. You can read it at inmobiliariaicr.com/privacidad.

1. Identity and address of the data controller

[Full legal name — e.g. «Grupo Inmobiliario ICR, S.A. de C.V.» or «First Last (individual with business activity)»], hereinafter «ICR Inmobiliario», with an address for service of notice at Blvd. Sánchez Taboada 9531, Office 101-A, Zona Urbana Río, C.P. 22010, Tijuana, Baja California, Mexico, is the party responsible for the processing of your personal data under this Privacy Notice, and undertakes that such data will be processed under the principles of lawfulness, consent, information, quality, purpose, loyalty, proportionality, and accountability set out in the Federal Law on the Protection of Personal Data Held by Private Parties (published in the Official Journal of the Federation on 20 March 2025, hereinafter the «Law»), its implementing regulations, and other applicable provisions.

This privacy notice is made available to you from the moment your personal data is collected, through our website inmobiliariaicr.com/privacidad, in a freely accessible electronic format.

2. Personal data that will be processed

ICR Inmobiliario collects the following categories of personal data, directly when you provide it to us through the forms on our website (inmobiliariaicr.com), by WhatsApp, telephone, email, social media, or in person at our offices:

a) Identification and contact data:

b) Financial and property data related to real-estate services:

c) Data collected automatically as you browse our site:

Sensitive personal data: ICR Inmobiliario does NOT collect sensitive personal data (data capable of revealing racial or ethnic origin, health status, genetic information, religious, philosophical, or moral beliefs, union membership, political opinions, or sexual preference). We ask that you refrain from providing such data through any of our channels.

Data of minors: Our services are directed at adults. We do not knowingly collect data from minors. If we detect data provided by a minor without the consent of the person holding parental authority, it will be deleted.

3. Purposes of processing

A) Primary purposes (necessary for the legal relationship and for providing the services you request):

  1. To identify and contact you in order to respond to your request for information about properties for sale or rent.
  2. To carry out the valuation of properties you wish to sell or rent through our services.
  3. To schedule and follow up on property showings.
  4. To prepare proposals, quotations, and real-estate service agreements.
  5. To manage the purchase or lease processes in which you take part, including coordination with notaries and the advisors involved.
  6. To maintain the communication necessary throughout the commercial relationship.
  7. To comply with the legal obligations applicable to ICR Inmobiliario, including those arising from anti-money-laundering regulations, where applicable.

B) Secondary purposes (not necessary for the legal relationship, but which allow us to serve you better):

  1. To send you information about properties matching your search.
  2. To send you promotions, news, and marketing communications from ICR Inmobiliario.
  3. To carry out service-quality surveys.
  4. To compile internal statistics and market studies on an aggregate basis.

Refusing the secondary purposes: If you do not wish your data to be processed for the secondary purposes, you may say so at any time by writing to [designated email — e.g. Info@GrupoICR.mx] with the subject «Negativa de finalidades secundarias», stating your full name and the purposes you wish to object to. Refusing these purposes will not be grounds for denying you the services you request.

4. Consent

By providing your personal data through our forms, our contact channels, or in person, you consent to its processing for the purposes described in this notice. In the case of financial or property-related data (such as information about your property and your price expectations), we will request your express consent, which may be given by means of the corresponding acceptance checkbox in our electronic forms, in writing, or by equivalent electronic means.

If ICR Inmobiliario were to intend to process your data for a purpose that is different from and not compatible with those set out in this notice, it will obtain your consent again.

5. Transfers of personal data

ICR Inmobiliario does not sell, rent, or assign your personal data to third parties for commercial or marketing purposes unrelated to the company.

Your data may be disclosed, only to the extent necessary for the primary purposes, to:

  1. Public notaries, for the formalization of purchase transactions to which you are a party.
  2. External advisors (legal, tax, or mortgage-lending) taking part in a transaction you have requested.
  3. Competent authorities, where there is a duly founded and reasoned request, a court order, or where the disclosure is required by applicable legislation.

In cases 1 and 2, the disclosure takes place as part of the service you have engaged and with your knowledge. Outside these cases, any transfer requiring your consent will be notified to you in advance.

6. Data processors and technology providers

To operate our website and manage contacts, ICR Inmobiliario uses technology service providers that act as data processors and that store information on servers which may be located outside Mexico (currently, web hosting and database services with industry security standards, such as encryption in transit and at rest). Those processors handle the data exclusively on behalf of ICR Inmobiliario, in accordance with this notice, and acquire no rights over it.

7. Means and procedure for exercising your ARCO rights

You or your legal representative may exercise at any time your rights of Access (to know what personal data we hold and the conditions of its processing), Rectification (to request the correction of inaccurate or incomplete data), Cancellation (to request its deletion where you consider it is not required for the purposes of this notice), and Opposition (to object to processing for specific purposes) — known collectively in Mexico as ARCO rights.

Procedure:

  1. Send your request to the email address [email designated for ARCO — e.g. Info@GrupoICR.mx] or submit it in writing at our address.
  2. The request must contain: (a) the full name of the data subject and a means of communicating the reply; (b) a document proving your identity (official ID) or legal representation, where applicable; (c) a clear and precise description of the data in respect of which you seek to exercise the right; (d) any element that helps locate the data.
  3. ICR Inmobiliario will answer your request within a maximum of 20 business days from receipt and, where the request is well founded, will give effect to it within the following 15 business days after the reply is communicated. These periods may be extended once, for an equal period, where justified.
  4. Exercising ARCO rights is free of charge; only justified shipping costs or the cost of reproduction in copies or other formats may be charged, where applicable.

Personal data officer: [Name of the person designated within ICR Inmobiliario who will handle requests]

8. Withdrawal of consent and limitation of use or disclosure

You may withdraw the consent given for the processing of your personal data by following the same procedure as in section 7. Please note that withdrawal will not have retroactive effect and that, in certain cases, processing may continue where a legal obligation requires it (for example, retention of documentation for formalized transactions).

In addition, you may limit the use or disclosure of your data by asking to be added to our marketing-communications exclusion list, by writing to [designated email].

9. Cookies and tracking technologies

Our website uses first-party and third-party cookies for the following purposes: (a) technical, necessary for the site to function; (b) analytical, to measure site use on an aggregate basis and improve the browsing experience [adjust depending on whether an analytics tool is enabled].

You can disable or delete cookies from your browser settings. Disabling technical cookies may affect how some sections of the site work.

10. Security measures and retention

ICR Inmobiliario has implemented and maintains reasonable administrative, technical, and physical security measures to protect your personal data against damage, loss, alteration, destruction, or unauthorized use, access, or processing, including: credential-restricted access to the systems that store data, encryption of the website's communications (HTTPS), and limiting the personnel with access to contact and client information.

Your data will be retained only for as long as necessary to fulfil the purposes described and the applicable legal obligations; once those periods end, it will be deleted or anonymized.

11. Competent authority

If you consider that your right to the protection of personal data has been infringed, you may turn to the Secretaría de Anticorrupción y Buen Gobierno, the authority competent in Mexico for the protection of personal data held by private parties.

12. Changes to the privacy notice

ICR Inmobiliario may modify or update this privacy notice at any time to address legislative developments, changes in our privacy practices, or changes in the services offered. Any modification will be published at inmobiliariaicr.com/privacidad, stating the date of last update. Where the changes involve new purposes that are not compatible with those set out here, your consent will be obtained again.

Date of last update: [publication date]