1. Introduction

VCA Perú is the commercial name of IT-Orval SAC, a software service provider company specialized in automating contact and communication processes with clients, through various channels such as VoIP, WhatsApp Business API, Chatbot Web, SMS and others, being able to create and manage campaigns from any channel and allowing you to connect more efficiently with customers.

To provide information about the type of personal data that is collected, how it is obtained and what it is used for, this Privacy Policy (hereinafter, the “Policy”) has been drafted. VCA Perú ensures the maximum confidentiality and protection of personal data that clients or potential clients, in order to use the services, provide us through our website (https://laraigo.com/, https://laraigo.com/es/bloges/, https://contacto.laraigo.com/) and other documents, forms, social networks, fan pages, chatbots, among others.

2.Objective and purpose

VCA Perú is aware of the high importance of the privacy of our users and of all those people who are interested in the products and services offered. Being consistent with this consideration, we are committed to respecting your privacy and protecting the confidentiality of your private information and personal data. For this reason, through this Privacy Policy, we inform our users of the way in which the personal data provided in VCA Perú and Laraigo is collected, processed and protected.

Private personal information does not include information that is available through publicly accessible sources. These are understood to be the means of electronic, optical and other technological communication designed to provide information to the public and open to general consultation, telephone directories, newspapers and magazines, social media, professional lists, repertoires of anonymized jurisprudence, the Public Registries administered by the National Superintendency of Public Records as well as any other registry or data bank qualified as public in accordance with the law, the Public Administration entities in relation to the information that must be delivered in application of the Law No. 27806, Law on Transparency and Access to Public Information.

3.Legislation

In accordance with Law No. 29733 – Personal Data Protection Law (hereinafter, the “Law”) and its Regulations, approved by Supreme Decree No. 003-2013-JUS, personal data is understood as any information about a natural person who identifies or makes identifiable through means that can reasonably be used.

On the other hand, the processing of personal data is understood as any technical operation or procedure, automated or not, that allows the collection, registration, organization, storage, conservation, processing, modification, extraction, consultation, use, blocking, deletion, communication by transfer or dissemination or any other form of processing that facilitates access, correlation or interconnection of personal data.

VCA Perú develops its Personal Data Processing Policy in accordance with the guiding principles established in Law No. 29733 – Personal Data Protection Law mentioned below:

• Principle of legality: the collection of personal data of our users by fraudulent, unfair or illicit means is rejected.
• Principle of consent: the processing of our users' personal data will involve their consent.
• Principle of purpose: The personal data of our users will be collected for a specific, explicit and lawful purpose, and will not be extended to another purpose other than the one unequivocally established as such at the time of its collection.
• Principle of proportionality: all processing of personal data of our users will be appropriate, relevant and not excessive to the purpose for which they were collected.
• Quality principle: Personal data will be true, accurate and, as far as possible, updated, necessary, relevant and appropriate with respect to the purpose for which it was collected.
• Security principle: they will be kept in a way that guarantees their security and only for the time necessary to fulfill the purpose of the treatment.

VCA Perú and, where applicable, those in charge of processing, have appropriate security measures consistent with the processing to be carried out, as well as adopting the necessary technical, organizational and legal measures to guarantee the confidentiality of personal data.

4.Information about personal data

The user is informed and freely and voluntarily authorizes VCA Perú to collect, store, conserve, access, use, delete or update their Personal Data for its activities in Peru. In that sense, the personal data to which VCA Perú has access as a result of the services it provides or by filling out different forms such as the one displayed when clicking on the “Contact” tab on the website https://laraigo.com/ , https://contacto.laraigo.com/ or its chatbot, will be incorporated into the corresponding “Web Users Personal Data Bank”, making up the organized set of users' personal data, created by VCA Perú and registered in the National Registry for the Protection of Personal Data.

The personal data provided by users will be treated with complete confidentiality and can only be known and handled by VCA Perú staff who need to know said information to provide the services offered. VCA Perú undertakes to maintain professional secrecy regarding these and guarantees the duty to keep them by adopting all necessary security measures. Authorization will not be necessary when the personal data is necessary for the execution of a contractual relationship in which the Personal Data Owner is a party.

If the registered data is inaccurate, in whole or in part, or incomplete, VCA Perú may update it and/or replace it with the corresponding rectified or completed data.

The personal data requested from users through different forms on the website, chatbot or physical, are basic contact data and are adequate, relevant and not excessive in relation to the purpose for which they are collected.

5.Purpose of the processing of personal data

The user expressly authorizes VCA Perú to use their data for the following purposes:

* For the purposes of providing our services.

* For purposes of access and use of our products.

* Provide technical support.

* To notify changes to our service.

* Validate the information provided and its veracity.

* Customize, develop and improve our services and user experience at VCA Peru.

* Resolve and respond to complaints and problems regarding the service, as well as respond to queries, requests, suggestions and other types of information that are required through our communication channels.

* Provide any information that VCA Perú believes may be of interest to the user.

* Send relevant or exclusive communications corresponding to the provision of our services.

* Send advertising about our products/services; news; updates; information from the articles we publish on our blog; information and invitations to workshops, courses, webinars, bootcamps and similar, if the user has expressly consented.

* To coordinate demonstrations.

* Provide free access to download digital content offered on our website.

* Investigate and detect possible fraud or other violations of our Terms and Conditions or against this Privacy Policy, and/or attempts to harm our users or visitors. We also use the personal data provided if we believe it is necessary for security reasons.

* Use duly anonymized or dissociated information in order to develop our services, investigate trends in our sector or carry out any type of activities of historical or statistical value.

* Conduct polls and surveys about our services, as well as measure their performance.

* Store information in cloud storage services abroad. This is essential for the provision of Securitec services.

In summary, the legal basis that VCA Perú uses to use the personal data collected is as follows:

* User consent.

* To provide our services and improve user experience.

* For purposes of functionality and operation of the website.

* To be able to provide support, resolve any questions or queries and resolve complaints.

* To protect the security of our users, website and products.

* To satisfy a legitimate interest (which does not override our duty to protect the personal data collected) such as research and development of our services, promoting the website and protecting our legal rights and interests.

* To process data in order to comply with a legal obligation.

* To process data in order to comply with a contractual obligation.

6.Online chat

Users authorize VCA Perú to process their personal data in order to provide answers to queries made through the “Online Chat”, WhatsApp Business Api or other communication channel, so the measures adopted in the this Privacy Policy.

7.Transfer of personal data nationally or internationally

The user authorizes the transfer of their data to companies at a national or international level (cross-border flow) related and/or associated with VCA Perú in order to properly manage the products and services requested by users and the procedures that arise subsequently, in relation for the purpose indicated in the previous sections, extending to them the express authorization for their use. VCA Perú guarantees the adequate level of protection of users' personal data for the transfer of personal data, in accordance with protection comparable to that provided for by this Law or by international standards on the matter.

These personal data may also be communicated to administrative entities, judicial and/or police authorities, as long as it is established by Law or when they require it.

8.Security of personal data

In compliance with current regulations, the Information Security Directive approved by Directorial Resolution No. 019-2013-JUS/DGPDP of the National Authority for the Protection of Personal Data, VCA Peru has adopted technical and organizational security measures and confidentiality appropriate to the category of personal data, necessary to maintain the required level of security, with the aim of avoiding, to the extent possible, alteration, loss or unauthorized treatment or access that may affect or affect the integrity, confidentiality and availability of information.

However, although VCA Peru makes efforts to protect the personal data collected through the use of various security techniques, the transmission of information through communication networks and the Internet is not completely secure due to illicit acts such as cyberattacks. or actions attributable to the user themselves by not being careful with their own data.

In this sense, all information provided will be sent at the user's expense and risk. VCA Perú is not responsible for illegal interceptions or violation of its systems or databases by unauthorized persons, as well as the improper use of information obtained by these means, or any illegitimate interference that escapes its control and that is not attributable to him.

Additionally, although VCA Perú ensures the protection of the personal information of its users, they are responsible for not disclosing data that allows third parties to have access to them (for example, password and user identification). The user is the only one who knows this information, so they should not reveal it to third parties.

If the user considers that there was some type of security violation or identifies that someone accessed their account, they must immediately notify VCA Perú through the email provided in point 11 of this Policy.

Likewise, if VCA Perú detects a violation of the security of the personal data provided, and this entails a high risk for the rights and freedoms of the user, VCA Perú will inform you in clear and simple language, so that you can easily understand the nature of the infringement committed against your personal data.

Such communication will not be necessary when VCA Perú has adopted appropriate technical and organizational protection measures applied to the personal data affected, so that they are unintelligible to whoever tried to access them (e.g. encryption). Nor will it be necessary when it involves a disproportionate effort for VCA Perú, since in the case of several affected users it is easier to opt for public communication or other options.

10.Exercise of the Rights of Access, Rectification, Cancellation and Opposition

Internet Users who have provided personal data to VCA Perú can contact it, in order to exercise their rights of information, access, updating, inclusion, rectification and deletion, to prevent the provision of their personal data, to opposition to the processing or objective processing of the data, in the terms set forth in current legislation. These rights may only be exercised by the owner of the personal data or his or her representative, in accordance with the law.

In order to exercise these rights, users must contact the following email address: @vcaperu.com, with the reference “Personal Data Protection”, specifying their data, proving their identity and the reasons for their request. Whoever signs the request must attach a simple copy of the documents that prove the identity of the owner (National Identity Document or equivalent document) or, where appropriate, that of the attorney-in-fact, as well as a simple copy of the power granted by notarial means when applicable.

Likewise, VCA Perú informs its users of the existence of administrative means to assert their rights to exercise before the National Data Protection Authority or jurisdictional rights before the Judiciary for the purposes of the corresponding habeas data action.

11.Others

As it is a virtual tool, which does not allow direct physical treatment between VCA Perú and the owner of the personal data, VCA Perú will collect and process the personal data based on the good faith presumption that the person providing it is of legal age before the law, is proficient in the Spanish or English language, is in full use of his mental faculties, has full civil capacity and is the owner of the personal data or acts as a representative of the owner of the data he provides. , in case they are owned by third parties.

To make any type of query regarding this Policy, you can contact the following email address: @vcaperu.com

12. Validity and modification of this Personal Data Protection Policy

VCA Perú's Personal Data Protection Policy is constantly updated, so VCA Perú reserves the right to modify its Policy in the event that there is a change in current legislation, doctrinal, jurisprudential or due to its own business criteria. If any change is made to this Policy, the new text will be published on this same website. All users are recommended to periodically access this Privacy Policy, which they will find on the website www.laraigo.com

Last Update November 8, 2022