Comprehensive privacy notice: use of the internal apps

Transformación Puebla, S.A. de C.V. · Staff in Mexico · Version 0.5 · November 6, 2026

In short

• Transformación Puebla, S.A. de C.V. («TP») is responsible for your data when you use its internal apps.
• To run the apps we use your account, what you enter, the log of your sign-ins and technical errors.
• To improve them we measure how you use them, only if you choose «Yes, measure my use». Today that measurement is switched on only in Hub (hub.transformacionpuebla.com). Another app is added only after this notice is updated.
• What we measure is personal data: it carries a code instead of your name and email, and TP can link that code to you.
• You can say no, or change your mind, whenever you want. It has no effect on you. We do not use the measurement to evaluate you.
• What we measure is deleted automatically after 3 months.
• Separately, Cloudflare counts visits to Hub's pages for everyone, without your name or your code (section 2.3).

What this text covers

It is the section of TP's comprehensive privacy notice about the use of its internal apps. It can be read on its own: it contains everything the law requires for this data. The rest of your employment relationship is covered by TP's other notices for staff.

1. Who is responsible for your data

Transformación Puebla, S.A. de C.V., with its address at Av. Hidalgo 105, Col. Rafael Ávila Camacho, San Pedro Cholula, Puebla, C.P. 72757, Mexico.

For any question about this text or your data:

TP runs its apps itself: there is no other company between TP and its providers.

2. What data we process

2.1 To run the apps

2.2 Usage measurement (optional; today only in Hub)

Only if you choose «Yes, measure my use» (section 6).

What is kept:

What your device sends and is not kept today. Hub's measurement also sends, for each screen, how long it was open, visible and in use, how far you scrolled, how many clicks you made, how many fields you used (not their content), how many errors there were and, on the first screen, the site you came from (its domain only). For each click it sends which element it was on, by its technical name, and at what point of it. It also sends your time zone, your connection type (for example 4G) and your contrast preference. Everything goes through Hub's server, which replaces your identifier with the code, and reaches the measurement service, which today discards it without keeping it.

What Hub does not measure today. The privacy message is the same in every app. Hub does not record completed actions, task durations, searches or your type of role today.

What the measurement does not collect: your name, your email, your IP address, what you type in forms (passwords included), what you see on screen or recordings of your screen. Nor does it keep pointer movement: your device only uses it to know whether the screen is in use.

Your browser and your IP. Hub does not pass your IP to the measurement service. It does pass the string your browser identifies itself with («user agent»). The service uses it to discard robots and does not keep it, neither with the measurement nor in its technical log. In addition, each submission, like any request to Hub, is recorded in the access log of section 2.1, with your IP and your browser.

Sensitive data. The measurement does not ask for or look for sensitive, financial or property data. The two accessibility settings it keeps with your code are used only to know how the app looks: TP does not use them to infer anything about your health or about you.

A code is not anonymity. TP can link your code back to you from each app's server. That is why it treats this data as personal data.

2.3 Cloudflare's visit counter (everyone)

Cloudflare, which hosts Hub, adds its visit counter (Cloudflare Web Analytics) to Hub's pages. It runs for everyone, including people who say no to the measurement in section 2.2.

• According to Cloudflare, it records the page, where you came from, your country, your browser, your system, your device type and the loading speed. It does not record what follows «?» in the address and does not track people across sites.
• TP sees only aggregate figures in Cloudflare's dashboard, without your name or your code.
• Cloudflare keeps the detail for 7 days and then a summarized sample. Its dashboard shows the last 6 months.

Source: Cloudflare Web Analytics documentation (developers.cloudflare.com/web-analytics), read on November 6, 2026.

3. What we use your data for

3.1 Primary purposes: needed for your work

They are needed for the employment relationship or to comply with the law, so they do not require your consent:

1. Giving you access to the apps with your work account and showing you what corresponds to your role.
2. Making the features you use work, load properly and save what you enter.
3. Protecting the apps and keeping the access log.
4. Fixing errors and handling the reports you send us.
5. Complying with legal obligations, responding to requests from authorities and defending rights.

3.2 Secondary purpose: improving the apps (optional)

6. Improving the design and experience of the apps with the measurement in section 2.2: knowing on which screens and devices people work, what is slow and where people get stuck, in order to fix it and decide what to improve first.

This purpose is not needed for your work. We only measure if you choose «Yes, measure my use». If you close the message without choosing, we do not measure. You can say no or withdraw your yes at any time (section 6).

Saying no has no consequence for your employment, pay, benefits or evaluation, and the apps work the same.

What TP does not do with this measurement:

• It does not use it to evaluate your performance, productivity, punctuality or attendance, or to decide anything about you.
• It does not build profiles of people: it analyzes by app, screen and device type.
• It does not look up who is behind a code, except to handle a rights request from you (section 7) or, with your permission, a problem you report.
• It does not combine it with payroll data or with your Human Resources file.
• It does not use it for advertising, does not sell it and does not share it for commercial purposes.
• Hub does not use Google Analytics, Google Tag Manager or Microsoft Clarity. The only counter outside TP is Cloudflare's (section 2.3).

If TP wanted to use this data for anything else, it will tell you and ask for your consent first.

4. Who sees your data and with whom it is shared

Within TP:

• The Strategy Manager (Gerente de Estrategia) sees all of the measurement.
• General Management and the person responsible for each app see only summaries, with figures of at least 5 people, and never anyone's code.
• The measurement is read through technical access to TP's Cloudflare account and its monitoring dashboard. Besides the Strategy Manager, the systems staff who run that service have it, only to run it.
• To diagnose an error, the Strategy Manager can review what happened in one tab, by its random number, without your name.

AI assistant. TP uses Claude, the artificial intelligence assistant of Anthropic, PBC, to analyze the measurement. Claude receives only figures for groups of at least 5 people, without your code or the tab number, and never what happened in a tab.

Those who process it on TP's behalf. They use your data only to provide the service to TP, under their contracts with TP:

• Cloudflare, Inc. hosts Hub and other apps, carries and protects the traffic of all of them, and keeps the measurement and the visit counter. It does so under its data processing agreement (version 6.4, in force since April 3, 2026): it follows TP's instructions, does not use the data for marketing and deletes or returns it when the service ends. That agreement also says Cloudflare processes some data about TP's account and the network on its own behalf, to run and protect its service. Its servers may be outside Mexico, for example in the United States.
• Microsoft: only so you can sign in with your work account. It does not receive the usage measurement.

No one else. The usage measurement is not shared with anyone else. Other data is only disclosed without your consent in the cases the law allows, for example when a law or a treaty provides for it, for the administration of justice, or to defend a right in court.

5. How long we keep your data

6. How to say no to the measurement or withdraw your yes

• The first time you open Hub with the measurement switched on you will see the privacy message with «Yes, measure my use», «Don't measure my use» and «Close». Nothing is measured before you choose «Yes».
• If you close it without choosing, we do not measure, and we show it again when you open Hub in a new tab.
• Later, whenever you want: in Hub's page footer, under «Medición de uso» (usage measurement); by writing to privacidad@tpu.mx; or in person, at Human Resources or Legal, during the hours in section 1. If you ask by email or in person, we confirm when it has been recorded.
• What happens: your answer is saved in your account, for Hub, and applies on all your devices. From that moment Hub stops sending the measurement, Hub's server discards any submission and your browser deletes what the measurement stored in that tab.
• What was already kept cannot be deleted item by item: it is deleted automatically after 3 months. Until then it may still count in aggregate figures. If you ask, we tell you when it has been deleted.
• Saying no changes nothing you need for your work.

7. Your ARCO rights (access, rectification, cancellation and objection)

You can ask to see your data (access), correct it if it is wrong (rectification), have us delete it (cancellation) or object to a use when you have a legitimate reason (objection). For the usage measurement you do not need to give any reason: just say no (section 6).

How to ask. Write to privacidad@tpu.mx or hand in a letter at Legal, at TP's address, Monday to Friday, 9:00 to 18:00 (central Mexico time), on business days. Include:

1. Your name and an email or address for our reply.
2. An official ID, or the document that proves your representative's authority.
3. Which data and which right you want to exercise.
4. Anything that helps find it, for example which apps you use.

Your measurement. To find it we need to compute your code from Hub's server. We only do this to handle your request. We give you your records with a plain-language explanation of each data point.

Deadlines:

• We reply within 20 business days at most.
• If your request is granted, we carry it out within the following 15 business days.
• Each deadline can be extended once, for an equal period, if there is a justified reason.
• It is free; only copies or shipping could be charged.

If you ask us to delete your measurement: Cloudflare offers no way to delete single data points earlier, so it is deleted automatically after 3 months, as in section 6, and we tell you when it has been deleted.

Withdrawing your consent. You can withdraw it at any time, through the channels in section 6, without retroactive effect. If you ask, we confirm that we have stopped measuring, and we notify those who process the measurement on TP's behalf.

If you disagree or we do not reply, you can file a data protection request with the Secretaría Anticorrupción y Buen Gobierno, the personal data authority since 2025 (formerly the INAI):

• If you disagree with the reply: within the 15 business days after you receive it.
• If we do not reply in time: once the reply deadline has passed (20 business days, or 40 if we told you of an extension), with proof of the date you made your request.

8. What the measurement stores in your browser

The measurement does not use cookies. It stores the following in the tab's memory, which is cleared when you close the tab:

If you say no, your browser immediately deletes the first three.

9. How we protect this data

• The app's server replaces your identifier with the code before it leaves; each app's secret key lives only on that server and cannot be read.
• Your codes from different apps are only joined to handle an ARCO rights request from you.
• The app does not pass your IP address to the measurement service.
• Connections are encrypted, and only the people in section 4 read the measurement.

If a security breach significantly affects your property or moral rights, TP will tell you immediately so you can protect your rights.

10. Changes to this text

TP will tell you about each change:

• with a new version of the privacy message in the apps, which you will see again;
• in this notice, published at www.transformacionpuebla.com, in Spanish and English.

Before switching the measurement on in another app, TP updates this notice and shows you the message in that app. A new purpose would only be activated after telling you and, where the law requires it, obtaining your consent.