App

All legal documents

Draft, waiting for legal review

DRAFT TRANSLATION FROM SPANISH, NEEDS LEGAL REVIEW. This English version follows the Spanish (Mexico) draft sentence by sentence. It has not been adapted to any other country's law; the law references below are Mexican law, and Swiss law where it says so.

DRAFT, NOT LEGAL ADVICE, FOR REVIEW BY A LAWYER

Format MX-2, Spanish (Mexico). Draft 0.1, 7 October 2026. Written under the Federal Law on the Protection of Personal Data Held by Private Parties published in the DOF (Official Gazette) on 20 March 2025 (current text, last amended DOF 14 November 2025), hereinafter "the Law". Items marked [TO CONFIRM: ...] must be resolved before publication.

Full Privacy Notice

1618 Robotics: recording contributors, candidates and sites in Mexico

Last updated: [TO CONFIRM: publication date]

1. Who the controller is (art. 15, fraction I)

The Memeplex Weaving Company Sàrl, trading as 1618 Robotics ("1618", "we"), a Swiss company with company number CHE-290.862.749.

2. Who this notice applies to

(a) People who write to us or fill in a form to take part ("candidates").

(b) People who sign the Terms for Independent Recording Contributors (Format MX-1) ("contributors").

(c) Owners, managers and representatives of businesses who sign the Site Permission (Format MX-3), and customers who sign the permission for work in a home (Annex B of Format MX-3).

What this notice does not cover: the videos. Contributors record in the app of a client of 1618 ([BUYER]). The videos, and the personal data in them (image, voice, place), go straight from the phone to the client. 1618 does not receive, store or see them. The client processes them as controller, under its own privacy notice: [TO CONFIRM: link to the client's notice].

3. What personal data we process (art. 15, fraction II)

Category Data From whom
Identification Name, year of birth, confirmation of legal age, city and state, trade. We check your official ID by video call or in person, but we do not keep a copy or the number: we only note the type of ID, that it is valid and that you are 18 or older. Candidates, contributors
Contact WhatsApp number, email, address to send you the strap Candidates, contributors, sites
Financial and property CLABE, bank, account holder's name, payments made Contributors, sites that receive a payment
Tax RFC and tax regime [TO CONFIRM: whether requested] Contributors, sites
Phone Phone model. To check it, we ask you for a screenshot of the "About phone" screen. Cover the IMEI and serial number before you send it. We delete the screenshot after checking and keep only the model. Candidates
Activity in the client's app Your app account email, contributor ID, dates, duration and task type of each session, accepted hours, quality or fraud flags, suspensions. We receive them from the client through its partner portal. Contributors
Communications WhatsApp messages, voice messages, photos and documents you send us, call notes Everyone
Sites Business name and RFC, site address, name and position of the signer, allowed areas and hours, authorized contributors Sites
Signature Handwritten or electronic signature and its record (date, time, IP address, email) Contributors, sites

Sensitive data. We do not ask you for sensitive data (art. 2, fraction VI). Do not send health, religious, ethnic origin or other sensitive data. If you tell us about an accident during recording, we use only what is essential to deal with it [TO CONFIRM: legal basis, art. 9, fraction V, or express written consent, art. 8].

Minors. We do not process data of people under 18. If we find out that a candidate is a minor, we delete their data.

4. What we use your data for (art. 15, fraction III)

Necessary purposes for our relationship with you (they do not require your consent when they are necessary to fulfil the legal relationship, art. 9, fraction IV):

(a) responding to your interest in taking part, checking that you meet the requirements (age, city, trade, phone model) and deciding whether we can work with you;

(b) giving you the training and the recording guide, giving you the organization code for the client's app and sending you the strap;

(c) coordinating the sites where you record and checking that they have signed permission;

(d) recording your accepted hours, calculating and making your payments, and sending you the breakdown of each payment;

(e) presenting to the client your disputes about rejections or suspensions of your account;

(f) preventing fraud, shared accounts and scams that use our name, and handling security incidents;

(g) meeting legal and tax obligations, and responding to authorities; and

(h) defending our rights in the event of a claim.

Non-necessary purposes (they require your consent and you can refuse without affecting your participation or your payments):

(i) contacting you about future 1618 projects; and

(ii) sending you surveys to improve the project.

If you do not want us to use your data for (i) or (ii), tick the box in section 15 or write to us at any time at sales@1618robotics.com or by WhatsApp.

Automated decisions. We do not make decisions about you by automated means alone. If we use an automatic tool to read the phone model screenshot [TO CONFIRM], a person reviews each rejection. The client decides whether your videos are accepted.

5. Consent

5.1 When we give you this notice and you do not object, you tacitly consent to the processing of your identification, contact, phone, activity and communications data for the necessary purposes (art. 7).

5.2 For your financial and property data (CLABE and payments), we ask for your express consent through your signature on Format MX-1 or MX-3 (art. 7), in addition to the fact that we need them to pay you (art. 9, fraction IV).

5.3 You can withdraw your consent as explained in section 13.

6. Who processes your data on our behalf (processors)

The following processors process your data only on behalf of 1618 and according to our instructions (art. 2, fraction XII). Sharing data with a processor is not a transfer (art. 2, fraction XX). [TO CONFIRM for each: contracting company, signed processing agreement, country where it processes the data.]

Processor What for Country
WhatsApp / Meta Platforms [TO CONFIRM: WhatsApp Business app or a provider's platform] Messages with candidates, contributors and sites [TO CONFIRM: United States, Ireland]
Wise [TO CONFIRM: entity] Sending payments to your CLABE. Wise also processes data as a controller in its own right to meet its financial obligations. [TO CONFIRM: United Kingdom, Belgium, United States]
[TO CONFIRM: email and document provider] Email and archive of signed forms [TO CONFIRM]
[TO CONFIRM: electronic signature service] Signing Formats MX-1 and MX-3 [TO CONFIRM]
Hetzner [TO CONFIRM: whether the contributor register is stored there] Servers and backup of the contributor and payment register Finland (European Union)
Local coordinators hired by 1618 [TO CONFIRM] Recruitment, training, site visits, WhatsApp support Mexico
[TO CONFIRM: courier] Sending the strap Mexico
[TO CONFIRM: automatic screenshot reading tool, if used] Reading the phone model from the screenshot [TO CONFIRM]

7. Transfers (arts. 35 and 36)

7.1 We make the following transfers, which do not require your consent:

To whom What data What for Legal basis
The client of 1618 ([BUYER]), in [TO CONFIRM: country] Your app account email, contributor ID, your explanation in a dispute, notice of a video with a minor Resolving rejections or suspensions, and removing videos that must not be used Art. 36, fractions IV and VII
The business where you record Your name and contributor ID So the site knows who has permission to record Art. 36, fraction VII
Competent authorities Whatever they request under the law Meeting legal obligations and requests Art. 36, fractions I, V and VI

7.2 When we transfer data, we communicate this notice and its purposes to the third party, which takes on the same obligations as 1618 (art. 35).

7.3 Today we make no transfers that require your consent. If in the future we wanted to make them, for example to a buyer of the 1618 business, we will ask for your consent first. [TO CONFIRM: whether art. 35 requires an acceptance clause even when there are no transfers that require consent; see section 15.]

8. Where your data is stored

Your data is processed in Mexico, in Switzerland (where 1618 is based), in the European Union and in the United States, depending on the processors in section 6. The data protection laws of those countries may differ from Mexican law. [TO CONFIRM: contractual safeguards with each processor.]

9. How long we keep it

Data Period
Phone model screenshot Deleted after checking, no later than [TO CONFIRM: 7] days after we receive it
Candidates who do not start [TO CONFIRM: 6] months after the last contact
WhatsApp messages [TO CONFIRM: 12] months after the relationship ends
Activity in the client's app While the relationship lasts and [TO CONFIRM: 12] months afterwards, for disputes
Signed forms, payment records, tax data [TO CONFIRM: 10] years after the relationship ends (accounting retention period in Switzerland, Swiss Code of Obligations, art. 958f; in Mexico, the Federal Tax Code, art. 30, sets 5 years for accounting records)

At the end of each period, the data is blocked and then deleted (arts. 10 and 24). While blocked, it is kept only to deal with liabilities arising from the processing.

10. Security

We apply administrative, technical and physical measures to protect your data (art. 18): access only for those who need it, accounts with two-factor authentication, separation between payment data and other data [TO CONFIRM: actual measures]. Everyone who processes your data keeps it confidential (art. 20). If a breach occurs that significantly affects your property or moral rights, we tell you immediately (art. 19).

11. How to limit the use or disclosure of your data (art. 15, fraction IV)

12. ARCO rights (art. 15, fraction V; arts. 21 to 34)

12.1 You have the right to access your data, rectify it, cancel it and object to its processing.

12.2 How. Send your request to sales@1618robotics.com or by WhatsApp [TO CONFIRM: number], with (art. 28):

(a) your name and a way to reply to you;

(b) a document proving your identity or your representative's (we will ask you to show it by video call, without keeping a copy);

(c) a clear description of the data, except for the right of access;

(d) the right you want to exercise or what you are asking for; and

(e) any information that helps locate your data.

To rectify, state the change and send the document that supports it (art. 30).

12.3 Deadlines. We reply within 20 business days at most from when we receive the request. If it is granted, we carry it out within the following 15 business days. We can extend each deadline once by an equal period, if the circumstances justify it (art. 31).

12.4 Cost. It is free. We could only charge reproduction or shipping costs (art. 34).

12.5 Limits. We can refuse a request in the cases in art. 33, and keep data we must keep by law or to fulfil a current contract with you (art. 25). We always explain the reason to you.

13. Withdrawing consent (art. 7)

You can withdraw your consent at any time, through the same channels as in section 12, without retroactive effect. If you withdraw consent to process your CLABE, we will not be able to pay you by transfer until you give us another means of payment. Withdrawal does not affect data we must keep by law.

14. Changes to this notice (art. 15, fraction VI)

We publish changes at [TO CONFIRM: web address] and tell you about them by WhatsApp or email before they apply. If a change adds a new purpose, we will ask for your consent again (art. 11).

15. Your choices

{{Checkbox}} I do not want 1618 to contact me about future projects (purpose i).

{{Checkbox}} I do not want to receive surveys (purpose ii).

[TO CONFIRM: art. 35 transfer acceptance clause, if the lawyer considers it necessary.]

16. Authority

If you think we did not deal with your request or that we broke the Law, you can file a request for protection of rights with the Ministry of Anti-Corruption and Good Government (art. 2, fraction XV; arts. 38 to 40), within 15 business days after our reply, or from when the deadline to reply expired if we did not reply (art. 40). [TO CONFIRM: the Ministry's current address and electronic channel.]

17. Swiss law

1618 is a Swiss company. It also complies with the Swiss Federal Act on Data Protection (FADP): duty to inform (arts. 19 to 21), right of access and other rights (arts. 25 to 28) and rules for disclosing data abroad (arts. 16 and 17). You can file a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, edoeb.admin.ch. [TO CONFIRM: Mexico is not on the list of countries with adequate protection in Annex 1 of the Swiss Data Protection Ordinance (DPO/FODP) (checked on 7 October 2026). Choose the safeguard for disclosing data from Switzerland to the coordinators in Mexico (standard contractual clauses, art. 16, paragraph 2, FADP) or the applicable exception (art. 17 FADP), and state it here.]

18. Website and ads

[TO CONFIRM: whether the recruitment site uses cookies, Meta pixels or ad forms; if so, add what data they collect, what for and how to turn them off.]

DRAFT, NOT LEGAL ADVICE, FOR REVIEW BY A LAWYER