Responsible Business Policy


Ma | ni | fes | to

Four words: Public Declaration Of Intent. Definition of Intent: determination of the will in regard to an end.

This manifesto is an introduction to the definition of our culture. The attitudes, purposes, principles and values that define us as a company and as individuals. The company is a moral entity that comes to life whose quality of life depends upon its culture and those who form it. The company’s culture is what defines the company. Culture is a structured system built on behaviors that people are expected to follow, hence our culture is of paramount importance. However, we are aware that there is no such thing as a perfect culture, but building a clear path for knowing how to do the things that need to be done will make us realize what we can be, what we want to be, and therefore the intentions.

This manifesto declares that we want to be a company with a strong foundation in ethics, with cornerstones based on our principles and values, and a purpose that really achieves to provide value to our customers, simply because they have trusted us. For this reason, trust is fundamental. 

Under the value of trust we build relationships. We look for long term relationships, first amongst ourselves from the moment we become part of the team and then with our clients because they have believed in us, so we respond with a genuine interest in creating value. We owe ourselves to our clients. 

Hexagon Data has grown not through individual work efforts but through collaborative team effort. Hexagon Data is one, and as such, the team will always come first. Therefore the prosperity of the company and a good working environment is a topic that concerns us all and begins with each of us. We are not opportunists nor do we take advantage of failures, we all have the same opportunity and we always treat our customers and suppliers as we would like to be treated. Coherence in being and doing.

We work to win, to grow and to be better. However we are aware that when we win, there has been the possibility of losing thus we are always prepared. Moreover, losing also makes us learn. Learning will make us grow, will make us add more value, but it is our responsibility to do so.

“Be true to yourself always”; we act genuinely. We all belong to, without distinction or differences of thought or belief. Whoever is part of Hexagon Data, directly or indirectly, should feel welcome because everyone has a unique perspective that creates value. We want to be heard and valued, thus we all have to take the time to do so.


Eduardo Carbia



We want to create strong personal, professional and business bonds that contribute positively to each other’s lives. We believe in human warmth and in the importance of the well-being of each person whom we interact with. This Responsible Business Policy (“Policy”) is written to share our principles and values. We consider that the commitment must be mutual: let us work together for an excellent business environment!.

We undertake to make every possible effort to meet and exceed the expectations of our services, which address the needs of customers, users and suppliers. We want the companies that hire us to have successful data management that grows their business. Similarly, we want to do business with people who share our principles and values aimed at a responsible business conduct. 

Communication is paramount to any human relationship, so from our side it will be clear, direct and continuous. We are interested in your opinion and we believe that any doubt or suggestion is very valuable. It is also important to remember the “art of giving and receiving”. We encourage you to have the confidence to open the channel of communication.  

This Policy applies to entities related directly or indirectly to Hexagon Data S.A.P.I. de C.V. hereinafter “Hexagon Data” or “our company”. We invite you to read this Policy carefully and commit to it!


Hexagon Data’s mission is to make consumer data the foundation of great experiences.


Our vision is to be a benchmark company with the best practices in consumer data that provides transparency to the entire marketing value chain. We want to improve the results of advertising investment in every channel and enable the delivery of quality content, both with a truly user-focused experience.


At Hexagon Data these values are the cornerstones of our people and company. We believe that all of our activities must be guided by these values in order to create strong personal and professional bonds. 

a. Respect

We listen before we speak. No one is more or less important than anyone. We respect different points  of view, sexual orientation, cultural, racial and social differences. Being respectful also includes doing things right, being well-intentioned, being on time (respecting other’s time), completing tasks and expressing ourselves correctly towards the team members and our customers.

Treat others as you would like to be treated.  Given the volume and type of data we work with, we must always bear in mind the respect for privacy.

b. Responsibility and honesty

We are responsible and honest with our work. We are transparent and we never disguise reality. Honesty is part of our culture, so we must have the ability and peace of mind of acting honestly. That includes expressing ourselves in a direct but always well-intentioned way. 

c. Dynamism and flexibility

We are flexible but focused. There is always something we can improve on. We like to make things happen instead of waiting for them. We must be able to adapt to the business needs as individuals, team and company. 

d. Trust 

We are in the business of trust. We understand that trust is earned every day and lost in a single action. Our customers require a company that they can trust to reach their goals and expand their knowledge. When we make decisions on their behalf, they must always have the peace of mind of knowing that we are acting in the best of their interests including those in the long term. Their interests go beyond ours.

We create a work environment in which we all trust each other. Besides counting on everyone personally, professionally we must rely on each other’s intellectual capacity and commitment. 

e. Customer focus 

We are customer-oriented. We lead by example with intelligence, discipline and focus. Sharing knowledge makes us grow. The more we know, the more value we have.

    f.  Social responsibility

We are a company that cares for the welfare and future of our community. We actively contribute to economic, social and environmental development to preserve the environment and the sustainability of future generations.

   g. Adaptability 

We are aware that we live in a globalized world where technology plays an important role. We have the capability to adapt to changes and new circumstances in an effective and efficient way



At Hexagon Data we do not accept any form of discrimination on any grounds. We are against discrimination and harassment. We base our actions in non-discrimination and equal opportunity principles without distinction as to race, color, gender, sexual orientation, religion, national or social origin, political opinion, age or disability. We treat people equally and fairly, are inclusive and respectful, and do not harass or bully.  


Any kind of harassment or bullying is prohibited, meaning any unwanted or non-reciprocated comments, gestures, actions, suggestion, symbols and/or physical contact. For example, those related to personal, sexual and work harassment, including those acts that could be considered as denigrating, humiliating, intimidating, mistreatment and threats of physical, verbal or psychological nature.  


At Hexagon Data equal opportunity is one of the company’s core values. We have a diverse work environment that is open to different opinions and ideas. Therefore, we encourage the professional development of all team members that, in turn, results in creating greater value for the customer.


We have a policy of zero tolerance for child labour and forced labour. At Hexagon Data we recognize and protect the rights of children in accordance with current legislation as well as the United Nations “International Bill of Human Rights” and the standards on child labour set by the International Labour Organization. 

Forced labour is work done against someone’s will and/or without due remuneration. We duly compensate each worker, as well as recognize and protect each worker’s rights.


Together we take care of the planet!

We strive to reduce our negative impact on the environment. In our physical offices we have guidelines that aim to minimize the environmental impact, such as recycling measures, garbage separation, avoiding single-use plastics, promoting the use of mugs, reusable packaging and sustainable materiales, and prioritizing energy saving. As for the home office, we invite all the team to continue with these measures from their homes.


We respect national laws, regulations and standards, as well as applicable international legislation. We adopt best practices and join proactively the global trend of personal data protection based on the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).


We stand for free competition and applaud fair competition!

Our mission is to be leaders in managing and optimizing consumer data to improve the experience and results of advertising investment, always in compliance with competition laws. In the marketing industry it is of paramount importance to promote transparency on marketing campaigns and market segmentation to respect the user’s privacy while preserving transparency with the customer. 

At Hexagon Data we compete fairly without adopting aggressive practices to obtain a dishonest advantage over our competitors. Even further, we are committed to both our clients and their consumers. We promote data management with respect to the people, bearing in mind the protection of the user’s data.


We undertake to conduct business in accordance with the international laws and regulations applicable to the place where the business is held. This includes compliance with all export control restrictions, embargoes and economic sanctions, anti-boycott, customs, product/country of origin marking and other trade controls in place wherever we do business. We comply with U.S., Canadian, European Union and United Nations regulations.


At Hexagon Data we carry out legal activities and promote an ethical culture amongst all the involved participants. We extend these measures to all individuals and companies with whom we have any kind of commercial and/or business relationship. Please read carefully the following rules that are essential to prevent corruption.

No bribery

We do not allow any kind of bribery at any time. At Hexagon Data we do not offer, promise, deliver, authorize, solicit or accept any improper advantage, financial or otherwise, related to the entire business and within our internal and external relationships. As a company, we do not engage in these types of activities nor do we tolerate our team doing so. 

Bribery is specifically prohibited in relation to government officials, whether international, national or local, as well as political parties, party officials or candidates for political office and in relation to directors, officers or employees of our customers, suppliers and/or interested third parties. Especially if it is related to a project assignment.

Prevention of money laundering and financing of terrorism 

We only do business with individuals, entities and companies that are in compliance with their tax obligations. We do not facilitate operations with resources of illegal origin (money laundering), financing of terrorism and other activities of ilegal origin. In addition, we do not do business with persons, entities and companies that are linked or subject to legal proceedings for committing these crimes.


We avoid conflicts between commercial and personal interests. At Hexagon Data, each member has the responsibility of taking decisions in the best interest of the company and/or the business relationship. A conflict of interest may arise when a customer or supplier works with a family member, friend or acquaintance at Hexagon Data and that fact may be in detriment to the business relationship between the companies. 

If a conflict of interest could or seems to exist, we ask for transparency and communication of the situation to determine the appropriate measures.  On our account, if we are aware of an interest in detriment of the company, customers and/or suppliers, we will immediately inform you.



All members of Hexagon Data have a key position in the company. As a team we materialize the objectives and projections we have planned for Hexagon Data. Together we can make sure that the data generates social and environmental impact, as well as creates real value and economic growth.  

We are a company that seeks the comprehensive development of its participants and encourages proactive and result-based work, sometimes through financial compensation. We want them to have a satisfactory experience of personal and professional growth. The objective is to create an optimal work environment for the whole team; in this sense, the following measures are adopted:

  • Everyone has an employment contract, whether they are hired directly or through a third party.
  • Everyone is treated with respect and dignity. We follow a non-discrimination policy while hiring and throughout the entire relationship. 
  • Each worker is compensated financially for their work. We do not engage in forced labour or slavery for any reason. 
  • We do not employ minors.
  • The working hours are 8 hours a day from Monday to Friday.

For Hexagon Data its team is of utmost importance. We do not tolerate any disrespect or mistreatment directed at any member of the team. Individual principles and values are a priority. If a third party commits a fault in this regard, the relationship with Hexagon Data may be affected.



We are committed to respect and ensure the protection of intellectual property of our customers, suppliers and/or interested third parties, available to us, licensed and/or of which we have knowledge within the contractual relationship and/or business. 

At Hexagon Data our work is protected by intellectual property rights that apply, without limitation, to our trademarks, logos, image, products, trade secrets, software, know-how, confidential information and innovations, as well as any developments, algorithms, models, lines of code made within Hexagon Data. They are part of our most important assets as they represent a competitive advantage and build our reputation.

During your relationship with Hexagon Data, you may be subject to measures to protect our intellectual property. We ask you to respect the intellectual property rights of others as well. For more information please contact our Legal Affairs area.


At Hexagon Data we are committed to protect the interests of the data subject and to provide full transparency and clarity regarding the use we make of their data. Besides complying with applicable laws, we work to develop self-regulatory measures that serve as a reference of good practices in the interactive marketing and digital advertising industry. In this regard, we rely on the highest standards set by international leaders such as the GDPR and the CCPA. In other words, we want to create a culture of data processing, personal and non-personal, reflected on how we would like other companies to treat ours.

We protect personal data and privacy of our customers, consumers, users, suppliers, work team and interested third parties. Our Privacy Policy explains how we process personal data.

Internal measures for data protection

The protection of your data is taken seriously. By the nature of our business we may have access to our customers and their users data. Our commitment is to look after the interests of all stakeholders. To these means the Hexagon Data team is subject to an Internal Data Protection Policy. 


Given the commercial activities, we are constantly in contact with confidential information both internal and external. Therefore, we keep every information shared with us strictly confidential, except as provided by applicable law. At the same time, we ask for the same level of commitment. 

Confidential information may include, but is not limited to, ideas, formulas, databases, standards, articles, studies, brochures, publications, manuals, systems, procedures, reports, technical reports, minutes, know-how, trade secrets, patents, copyrights, software, licenses, data, inventions, algorithms, techniques, processes, marketing plans and projects, advertising, strategies, forecasts, confidential information of third parties, or any other information whether technical, economic, or business related.


The accounts, books, records and financial statements faithfully reflect all transactions made on behalf of the company and comply with the requirements of applicable regulations. Expenses must be supported at all times. Any distortion of the nature of any transaction or document misrepresentation is prohibited. We keep the documents according to the applicable regulations. In the same sense of honesty, this information should never be made-up or modified for the benefit of the company. It is what it is.


At Hexagon Data we trust all the people and companies we do business with. We believe that if we sustain a relationship is because we share the same ethical principles and values. However, it is important to mention that in the event of committing a fault, the same will be evaluated and the consequences may vary in relation to its severity.

If you are subject of, observe or are aware of any conduct that is contrary to the provisions herein, please contact the CFO. She can be reached out at any time at  [email protected]. It is everyone’s responsibility to respect and follow the conducts referred to in this Policy. 

The CFO  will be the first point of contact who will investigate the event, consider the necessary confidentiality measures and analyze the seriousness of the event. Together with the Directors, she will proceed to issue a resolution and take the appropriate measures. We undertake to investigate objectively, responsibly, immediately and thoroughly such events. At all times, the confidentiality of all involved parties will be maintained.  

Hexagon Data reserves the right to determine the applicable consequence to the conduct that is contrary to this Policy and applicable laws. Notwithstanding the foregoing, in the event that the misconduct constitutes a criminal act, it will be referred to the relevant authorities and Hexagon Data will follow their decision. 

You can always approach the responsible of the Legal Affairs area for any concerns regarding this Policy. Please send an email to [email protected].

Together we create more value than we capture!