Comprehensive Privacy Notice
1. Identity and address of the controller
TOP AIRWAYS LATAM, S.A.P.I. DE C.V. (“TOP DRIVE MX” or the “Controller”), Mexican tax ID (RFC) TAL220310T1A, operating under the trade name TOP DRIVE MX, with its address at Avenida San Jerónimo 310, 21st floor, interior 2A, Torre Altreca, colonia San Jerónimo, Monterrey, Nuevo León, ZIP 64640, Mexico, is responsible for processing your personal data under Mexico’s Federal Law on the Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation (DOF) on March 20, 2025 (the “Law”), and other applicable provisions.
TOP FLY MX is the brand under which TOP AIRWAYS LATAM, S.A.P.I. DE C.V. offers private aviation services; when your service includes air coordination, the controller of your data remains the same company and this notice applies. Tregua Group is the trade identity under which several brands are presented; it is not a data controller.
2. Personal data we process
Depending on how you interact with us, we may process the following categories of data:
- Identification and contact: name, company or organization, position where applicable, email address, phone and WhatsApp number.
- Commercial request: type of service, cities and destinations, estimated dates, number of passengers where necessary, general mobility needs, operational preferences and the description you share with us.
- Contractual relationship: data of representatives or authorized persons, quotes, engagement, and administrative, tax and invoicing information (for example, legal name, RFC, tax regime and tax address).
- Service operations: logistics data needed to coordinate vehicles, chauffeurs, providers, airports, private terminals and, where applicable, air services through TOP FLY MX (for example, passenger names, schedules, pick-up and drop-off points and flight details).
- Website technical data: IP address, browser and device type, date and time of submission, referring page and records associated with the form, as well as the technical cookies described in section 11.
The website form does not request sensitive personal data, official identification, or biometric, medical or financial data. Please do not send personal documents or confidential itineraries through the initial form; if your service requires them, we will indicate an appropriate means to share them.
If you provide us with data about other people (for example, passengers, colleagues or a principal’s staff), you confirm that you are authorized to do so and that you will inform them of this notice.
3. Primary purposes
We process your data for the following purposes, which are necessary to handle your request and, where applicable, your relationship with us:
- Responding to requests for information and quotes.
- Assessing executive, private and corporate mobility needs.
- Preparing commercial proposals.
- Coordinating ground mobility services and the related domestic and international logistics.
- Coordinating connections with airports, private terminals and private aviation.
- Managing the authorized providers and collaborators involved in the service.
- Providing operational follow-up and handling inquiries, clarifications and incidents.
- Complying with contractual, administrative and tax obligations, including invoicing.
- Protecting the security and operation of the website and our systems.
4. Secondary purposes and how to opt out
With your authorization, we may also use your contact details to:
- Send you promotional communications and information about new services.
- Send you invitations and institutional information.
- Invite you to take part in non-essential satisfaction surveys.
- Carry out later commercial follow-up that is not necessary for a specific request.
These purposes are not necessary to serve you. On the website form they are collected through a separate, optional checkbox that is not pre-selected. You may refuse or withdraw your authorization at any time by writing to privacidad@topdrivemx.com or by replying “UNSUBSCRIBE” to any promotional message. Refusing will not affect how we handle your requests or the services you engage.
Photos and video. TOP DRIVE MX does not use photos or videos in which you or other people can be identified for advertising purposes without first obtaining a specific, separate authorization. This notice does not replace that authorization.
5. Transfers and processors
Processors. Some providers process data on behalf of TOP DRIVE MX and only under our instructions; this is not a transfer (Articles 2, section XX, and 35 of the Law) and does not require your consent. They currently are:
- GreenGeeks, as the provider of website hosting, of the database where form submissions are recorded, and of the email service.
- Administrative, accounting and tax providers that support invoicing and compliance.
- Ground mobility providers and operational collaborators, when acting on behalf of and under the instructions of TOP DRIVE MX.
Data shared between TOP DRIVE MX and TOP FLY MX is internal, because both are brands of the same controller, and is not a transfer.
Transfers. We may transfer your data without requiring your consent in the cases set out in Article 36 of the Law:
- To the air operators performing the flight, airports, private terminals and service providers acting on their own behalf, when necessary to perform the service you request or engage (Article 36, sections IV and VII).
- To competent authorities, where there is a legal obligation or a duly grounded request (Article 36, sections I, V and VI).
Under Article 35 of the Law, TOP DRIVE MX will provide recipients of transferred data with this privacy notice and the purposes to which you subjected the processing of your data; those third parties assume the same obligations as TOP DRIVE MX. TOP DRIVE MX does not sell, rent or assign personal databases.
Acceptance of transfers. The transfers described above fall under the cases in Article 36 of the Law and therefore do not require your consent. TOP DRIVE MX does not carry out transfers that require it. If it intends to do so in the future, it will first ask you to state whether you accept them or not through a specific mechanism, separate from the promotional communications checkbox, and refusing will not affect how we handle your requests or the services you engage.
6. Security measures
We apply reasonable administrative, technical and physical measures to protect your data against damage, loss, alteration, destruction, or unauthorized use, access or processing: encrypted connection (HTTPS) on the website, access to the administration panel restricted to authorized staff, protection of the form against automated submissions, backups, and access to information only by those involved in each operation. No measure is infallible; if a breach significantly affects your rights, we will inform you as required by the Law.
7. Retention, blocking and deletion
- Requests that do not lead to an engagement: kept for up to twelve months from our last communication with you and then deleted from the form records and email. Deletion is not automatic: it is carried out through a documented quarterly review supervised by General Management through the person designated for personal data protection, which removes those records from the website and email.
- Contractual and operational information: kept during the relationship and, once it ends, blocked for the limitation period of any actions arising from it; after that period, it is deleted.
- Tax records: kept for the period required by tax law (five years under Article 30 of the Federal Tax Code, unless a longer period applies).
While blocked, data is not processed for any other purpose.
8. ARCO rights
You may access your data, rectify it if inaccurate or incomplete, cancel it, or object to its processing for specific purposes. To exercise these rights, send your request to privacidad@topdrivemx.com including:
- Your name and an address or email to receive the response.
- How you will verify your identity or, where applicable, that of your representative and their authority.
- A clear description of the data and the right you wish to exercise (except for access requests).
- Any information that helps locate your data and, for rectification requests, the correction and its support.
Identity verification. You do not need to send a copy of your ID by email. When we receive your request, we will offer a reasonably secure method: verification of your ID by video call or at our address, or submission through a private, temporary link we will provide. A representative must prove their identity and authority.
Deadlines. Under Article 31 of the Law, we will communicate our decision within a maximum of twenty business days from receipt of your request and, if it is granted, we will carry it out within the following fifteen business days. Both periods may be extended once for an equal period when justified by the circumstances, in which case we will inform you. Under Article 2, section VIII, of the Law, these periods are counted in business days. The response will be sent through the means you indicate.
If you disagree with the response or do not receive one, you may file a rights-protection proceeding with the Ministry of Anti-Corruption and Good Governance (Secretaría Anticorrupción y Buen Gobierno) within fifteen business days after the response is communicated to you or after the response period expires.
9. Withdrawal of consent
You may withdraw any consent you have given by writing to privacidad@topdrivemx.com, following the same procedure and deadlines as in section 8. Withdrawal has no retroactive effect and, in some cases, we may not be able to apply it immediately when we must keep processing certain data to comply with a legal obligation or a service in progress; if so, we will explain why.
10. Limiting use and disclosure
In addition, you may ask us at any time to stop sending you promotional communications or to limit the use of your data by writing to privacidad@topdrivemx.com. We will record your request in an internal exclusion list so that you no longer receive those communications.
11. Cookies and similar technologies
According to the technical review of the website carried out on November 3, 2026, only the following technologies are used, all of them necessary for the website to work:
- Consent cookies (Complianz, prefix “cmplz_”): store your cookie preferences for up to 365 days.
- Browser local storage (Elementor): may store technical page-display data that does not identify you.
- WordPress session cookies: only for authorized staff who sign in to the administration panel.
The website does not use analytics, advertising or tracking cookies, and does not load third-party scripts. Links to WhatsApp and social media do not set cookies while you remain on the website. If optional cookies are added in the future, they will be activated only with your consent through the banner, and this notice will be updated. You can delete or block cookies in your browser settings; some features may be affected.
12. Third-party sites and platforms
The website contains links to WhatsApp, Instagram and Facebook, which are Meta platforms, and to TOP FLY MX. If you choose to contact us through WhatsApp or social media, the platform will process your data under its own terms and privacy notices; TOP DRIVE MX will process the messages it receives through those channels in accordance with this notice.
13. Changes to this notice
This notice may change due to legal developments or changes in our services or practices. The current version, with its update date, will always be available at www.topdrivemx.com/en/privacy-notice/. When a change affects purposes that require your consent, we will ask for it again.
14. Data protection contact
Email: privacidad@topdrivemx.com
Phone: +52 81 2071 1379
Address: Avenida San Jerónimo 310, 21st floor, interior 2A, Torre Altreca, colonia San Jerónimo, Monterrey, Nuevo León, ZIP 64640, Mexico.
15. Effective date and update
This notice takes effect on the date it is published on the website. Last updated: November 5, 2026. It replaces the previously published notice.