Welcome, Board Members!
CEMEX (“CEMEX”, “we” or “us”) recognizes that individuals need to understand how their privacy is protected, so we have established the following privacy statement (this “Privacy Statement”) for our users. This Privacy Statement describes how CEMEX will collect, access, use and disclose your personal information and information related to your use of the Sustainable Construction Academy website hosted in Cemex University (the “Website”).
For purposes of this Privacy Statement, “Personal Information” is data specifically about you, which you typically provide on a voluntary basis. Aggregate or combined information includes data that is related to you but studied as a group and does not identify you specifically. You cannot “opt-out” from having aggregate information collected except as otherwise specified in this Privacy Statement.
CEMEX, S.A.B. de C.V. (“CEMEX SAB”), a Mexican stock corporation with variable capital that has a registered address at Avenida Ricardo Margain Zozaya #325, Colonia Valle del Campestre, San Pedro Garza Garcia, Nuevo Leon, 66265, Mexico, is the controller of your Personal Information. This means that it determines the purpose for which, and the means by which, your Personal Information is used and it is responsible for handling your information in accordance with Mexican and European Union (“EU”) law, as well as any other applicable data protection law.
You may review, correct and update your Personal Information by contacting us using the information in the “Contact Us” section below.
Under certain circumstances, you can also:
1. Request access to your Personal Information. You can request to receive a copy of the Personal Information we hold about you.
2. Request correction of your Personal Information. You can ask us to correct any incomplete or inaccurate information we hold about you. We encourage you to provide us with accurate Personal Information and to let us know if your Personal Information changes. We will not assume any liability in respect of incorrect Personal Information you provide to us.
3. Request erasure of your Personal Information. You can request to delete or remove Personal Information where there is no good reason for us to continue using or storing it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to us using it, as described below.
4. Object to our use of your Personal Information where we are relying on our legitimate interest (or those of a third party) to do so and there is something about your particular situation which makes you want to object to us using it on this ground.
5. Request restriction of the use of your Personal Information. You can ask us to suspend the use of your Personal Information, for example, if you want us to determine its accuracy.
6. Request the transfer of your Personal Information in an accessible format to you or another organization.
7. Withdraw your consent to the use of your Personal Information. Where you have consented to our use of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific use at any time. Once you have withdrawn your consent, we will no longer process your Personal Information for the purpose(s) you originally consented to, unless we are required to keep it to comply with the applicable law. Please note that the withdrawal of your consent will not affect the lawfulness of our use of your Personal Information before you withdraw your consent.
In order to exercise any of the rights mentioned above, you should send us a request, through any of the means mentioned in the “Contact Us” section, that includes the following:
(i) your name, address, phone number and e-mail address (our response to your request will be sent to this e-mail address);
(ii) when applicable, the name of your legal representative including a copy of the document evidencing the validity of such legal representation;
(iii) an indication of the right(s) mentioned above you wish to exercise as well as a clear and precise description of the Personal Information upon which such rights will be exercised, including any changes to be made to your Personal Information if applicable, and
(iv) any other element or document which relates to your request and/or which may help us in locating your Personal Information.
Exercising one of your rights mentioned above is not a prerequisite for and does not preclude you from exercising any other right. We will not discriminate against you for exercising your rights, including, but not limited to those rights under the GDPR and the California Consumer Privacy Act when applicable.
In case the information provided is erroneous or insufficient, or the required documentation in order to confirm your identity are not attached, within 5 business days following the receipt of your request, we may solicit that you provide us the necessary elements or documents to process your request. You will have 10 business days from the date in which you receive our solicitation in order to fulfill it. If you do not respond in the aforementioned period, your request will be considered as not submitted.
CEMEX will inform you of the resolution within 20 business days (or the period established by applicable law, if shorter) from the date in which we received your request, so that, if resolved favorably, it is executed within 15 business days from the date in which we inform you of the resolution.
For more information on the process or requirements to exercise any of the abovementioned rights, as well as for any questions you may have in relation to the processing of your Personal Information, please contact us by using the information in the “Contact Us” section below.
In order to provide you with the benefits of utilizing the Website, CEMEX and certain third parties as described below collect certain information from you and your devices.
1. Information that You Provide to CEMEX
When creating an account on the Website, uploading any information or document to the Website or communicating with us in relation to such Website, you may provide certain Personal Information to CEMEX, including your name, last name, telephone number, e-mail address, company, job position, in addition to any Personal Information that you voluntarily provide to us through your profile on the Website.
We do not intend to collect through the Website any Personal Information deemed sensible by Law, as it is not necessary for fulfilling any of the purposes for using your Personal Information described below.
2. Information Collected by Cookies and Similar Technologies
In addition to the information that you provide to CEMEX, the Website may gather and store certain information about you or your visit, through the use of cookies or similar technologies, as described below.
a) What is a cookie?
A cookie is a small file of letters and numbers that is stored by a web server on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. When you return to websites, or visit website that use the same cookies, the cookie will be sent back to the web server so that the website can remember you and/or your preferences.
b) How we use cookies
In order to provide you with a better experience on this Website we provide the option to set certain preferences for how this Website runs when you use it, for example if you have agreed or not to the use of cookies by the Website. Additionally, we may automatically collect Personal Information by using cookies and similar technologies to provide you with a more personalized experience on this Website, for example to set the language in which the Website is displayed. In order to remember or set such preferences, we need to use cookies and similar technologies so that this information can be collected or recalled.
We also use cookies to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
Additionally, the Website may use third party cookies to provide advertisements that are relevant to your interests. Such online adverts are based on third party cookies that are placed on your browser in order to remember other websites you have visited.
c) Personal Information collected by cookies
Our Website uses cookies and other technologies that distinguish you from other users and processes certain information that, alone or combined with other data, may be deemed Personal Information in some countries or regions, such as IP addresses, cookie identifiers or other identifiers. Below please find additional information on such cookies:
| Source | Cookie Name | Expiration | Collected Information | Purpose | Opt-out link |
|---|---|---|---|---|---|
| _ga | 2 years | Random ID number and time stamp | Registers a unique ID that is used to generate statistical data on how the visitor uses the Website. | https://tools.google.com/dlpage/gaoptout | |
| _gid | 24 hours | Random ID number | Registers a unique ID that is used to generate statistical data on how the visitor uses the Website. | https://tools.google.com/dlpage/gaoptout | |
| _ga_ |
2 years | Random ID number | Store and count pageviews. | https://tools.google.com/dlpage/gaoptout | |
| _gat_gtag_UA |
90 days | Random ID number | Limit the number of requests made on the Website. | https://tools.google.com/dlpage/gaoptout |
In addition to the foregoing, we may use other analytical, functional or advertising cookies which do not process any Personal Information to understand user behavior, customize your experience within the Website or measure the effectiveness of advertisements.
d) Third party cookies
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
e) Blocking cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Additionally, you can also block specific cookies for all websites by clicking on the opt-out links provided in the table above and following the instructions therein. For cookies that do not collect Personal Information, we will issue such cookies unless you have adjusted your browser setting to refuse cookies.
1. Use of Personal Information
CEMEX may use your Personal Information to give you access to the Website and the courses provided therein, as well as to track your process in such courses., to communicate with you in relation to your questions, comments or requests made through the Website, as well as for other purposes and activities as set forth in the table below. Additionally, CEMEX may use your Personal Information collected through cookies or similar technologies as mentioned above, for performance, analysis and marketing purposes. You are not obligated to provide us with any Personal Information but please note that this may affect our capacity to give you access to the Website and prevent us from effectively responding to your comments or questions made through the Website.
We rely on a number of legal bases to process the Personal Information of users in the European Economic Area (“EEA”) as described in the table below. We have also identified what our legitimate interests are where appropriate.
| Purpose / Activity | Lawful basis for processing including basis of legitimate interest |
|---|---|
|
(a) To give you access to the Website and the courses provided therein (b) To monitor your progress on such courses. |
(a) Data subject consent (b) Necessary for our legitimate interests (to study how users take our courses and keep a record of courses completed) |
|
To manage our relationship with you which may include: (a) Answering any questions or comments you make through the Website (b) Notifying you about changes to our terms or privacy statement (c) Asking you to leave a review or take a survey |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services and network security) (b) Necessary to comply with a legal obligation |
| To send you marketing campaigns, such as information about products and promotions. | Data subject consent |
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the “Contact Us” information below if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table above. CEMEX will not sell your personal data.
Additionally, if you are an EEA user and wish to learn more about our legitimate interests in using the Personal Information and how we have balanced our interests against your fundamental rights and interests, please contact us using the “Contact Us” information below.
If you provide Personal Information to CEMEX, you agree to the use, collection and disclosure of the Personal Information by CEMEX for the purposes described in this Privacy Statement.
2. Sharing of Personal Information
In order to provide the services related to the Website, CEMEX may share certain Personal Information with third parties acting on our behalf, including:
| Company | Role |
|---|---|
| Provides the tools used for the Website’s behavioural analysis (Cookies) | |
| Mural Táctil | Design and provide support to the Cemex University Website. |
CEMEX may disclose your information (including your Personal Information), as necessary, to regulators, courts, legal advisers and law enforcement authorities: (1) if we determine a policy violation has occurred; (2) if we believe such disclosure is necessary to identify, contact or bring legal action regarding injury or interference with the rights and property of CEMEX, including to enforce CEMEX’s rights against unauthorized access or attempted unauthorized access to CEMEX’s information technology assets or against other inappropriate use of the Website; (3) to comply with laws, regulations, court orders and subpoenas or similar requests for information by authorities, or as otherwise required by law; (4) to protect your safety and the safety of others; and (5) to assist us in fraud prevention or investigation. We have legal obligation and a legitimate interest in sharing the Personal Information of EU users for purposes (1) and (2).
CEMEX will only send you marketing or promotional communications and/or communications about other topics if you have provided your consent to receive these types of communications. To contact you, CEMEX may use the information you provide to us, including email, address, fax or phone. You may, at any time, inform us that you no longer want CEMEX to contact you for marketing purposes by sending your request to us using the contact information in the “Contact Us” section below. You may also opt-out of promotional email communications by clicking on a link provided in the promotional email message. After opting-out, you will no longer receive marketing or promotional communications from us.
Certain web browsers may provide a do-not-track (“DNT”) option. You may be able to ask your browser to inform websites that you do not wish your activities to be tracked, either with cookies or other persistent identifiers, commonly called “DNT signals.”
CEMEX is committed to maintaining the security of the data you provide us. However, please note that there is always some risk in transmitting information over the Internet. CEMEX has implemented several physical, organizational and technical measures as well as outline policies and procedures in order to protect your Personal Information.
CEMEX is a worldwide corporate group. We may transfer and store your information outside of your home country, including in the EEA, for the purposes described in this Privacy Statement and pursuant to its terms. Where we transfer Personal Information from the EEA, or any other country or region which restricts transfer of Personal Information, to a country that does not provide an adequate level of protection, we will only do so under appropriate safeguards put in place to protect your information, such as standard contractual clauses. If you would like more information about these safeguards, please contact us using the information in the “Contact Us” section below.
We do not envisage that any decisions will be taken about you using automated means.
We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable requirements.
When we no longer need to use your Personal Information as mentioned above and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that we cannot identify you.
For further information on retention periods please contact us by using the information in the “Contact Us” section below.
The Website may contain links to external websites that may be subject to a different privacy statement. We recommend that you carefully review the privacy statement of each website you visit. CEMEX is not responsible for the content or privacy practices of websites owned by other companies.
This Privacy Statement addresses CEMEX’s procedures for handling the Personal Information of users who have reached the age of majority. We do not seek to, nor do we knowingly collect, information from minors. If a minor has provided us with Personal Information, a parent or guardian of that minor may contact us to have the information deleted from our records. To do so, contact CEMEX through the information provided below in the “Contact Us” section.
CEMEX has a Chief Privacy Officer located in Mexico, as well as Data Protection Officers in European countries where we have operations. You may contact CEMEX’s data privacy office at any time if you have questions, general concerns about the processing of your personal information, or any data protection issue, by sending an e-mail to dataprivacy@cemex.com.
Additionally, for the benefit of EEA data subjects and pursuant to article 27 of the General Data Protection Regulation, we have appointed CEMEX España, S.A. (“CEMEX España”), a Spanish corporation that has a registered address at Hernandez de Tejada, 1 28027 Madrid, Spain, as our representative in the EU. If you are an EEA data subject, you may address CEMEX España as to any issues relating to the processing of your Personal Information under this Privacy Statement in addition to or instead of the controllers mentioned above which are located in Mexico. Please consider that any information, including Personal Information, sent to CEMEX España under this Privacy Statement may be shared with PwC as CEMEX España’s advisor for personal data protection matters in Europe. You can contact CEMEX España by sending an e-mail to dataprivacyeurope@cemex.com.
If you are a Mexican user and you consider that we have infringed upon your personal data protection rights, you have the right to make a complaint to the Personal Data Transparency, Access and Protection National Institute (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales). For more information, please visit www.inai.org.mx.
If you are an EEA user and you feel that we have not answered your concerns appropriately you have the right to make a complaint to your local data protection authority. Contact details for EU data protection authorities can be found here.
If you are located elsewhere and consider we have infringed upon your personal data protection rights, please contact your local data protection authority for more information on how to exercise your right to file a complaint.
In any case, we would appreciate the chance to deal with your concerns before you approach the corresponding data protection authority, so please contact us in the first instance by sending an e-mail to dataprivacy@cemex.com.
From time to time, we may update this Privacy Statement. If we do, we will note near the top of this page the date that any changes are made and/or when they become effective. If the changes being made are material, we may alert you to the changes in a more prominent way.
