V y V Privacy

Introduction:

At V y V we care about the protection and privacy of our clients’ personal data. Therefore, we guarantee their absolute confidentiality and we employ adequate security standards in accordance with the provisions of the Personal Data Protection Law – Law No. 29733 and by its Regulations approved by Supreme Decree No. 003-2013-JUS.

The objective of this policy is to publicize the guidelines for the processing of personal data on the V y V page, in compliance with the current regulatory framework.1

Privacy Policy and Protection of Personal Data of V y V:

This document sets out our “Privacy Policy and Protection of Personal Data” that regulates the processing of personal data that is carried out in V y V for the fulfillment and development of our commercial activities.

Because it is important to be informed, definitions related to data protection are as follows:

Personal Data Bank: Organized set of personal data, automated or not, regardless of the mean, be it physical, magnetic, digital, optical or others that are created, whatever the form or modality of its creation, training, storage, organization, and access.

Personal Data: It is that numerical, alphabetical, graphic, photographic, acoustic information, about personal habits, or of any other type concerning natural persons that identifies them or makes them identifiable through means that can be reasonably used.

Sensitive Data: It is that information related to personal data referring to the physical, moral, or emotional characteristics, facts, or circumstances of their affective or family life, the personal habits that correspond to the most intimate sphere, the information related to physical or mental health or other similar ones that affect privacy.

Responsible for the Processing: Any natural person, legal person of private law or public entity that alone or acting together with another processes personal data on behalf of the owner of the personal data bank by virtue of a legal relationship and delimits the scope of action. It includes whoever performs the processing without the existence of a personal data bank.

Information Security: Systematic and continuous process that aims to preserve the confidentiality, integrity, and availability of information

Holder of Personal Data: Natural person to whom the personal data corresponds. It refers to clients, collaborators, suppliers, users, visitors, and the general public whose personal data are processed by V y V.

Holder of the Personal Data Bank: Natural person, legal person under private law or public entity that determines the purpose and content of the personal data bank, its processing and security measures.

Transfer of personal data: Any transmission, supply, or manifestation of personal data, of a national or international nature, to a legal person under private law, to a public entity or to a natural person other than the owner of personal data.

Processing of personal data: Any technical operation or procedure, automated or not, that allows the collection, registration, organization, storage, conservation, elaboration, modification, extraction, consultation, use, blocking, deletion, communication by transfer or by diffusion or any another form of processing that facilitates the access, correlation, or interconnection of personal data.

1. What are our principles?

In accordance with the principle of legality, it rejects the collection of personal data by fraudulent, unfair, or illegal means.

The processing of personal data will be carried out under the consent of the owner, excluding the exceptions provided by law.

Personal data will be collected for a specific, explicit, and lawful purpose, and will not be extended to another purpose other than that unequivocally established at the time of its collection, excluding cases of activities of historical, statistical, or scientific value that include a dissociation or anonymization procedure.

All processing of personal data will be adequate, relevant, and not excessive for the purpose for which it was collected.

The personal data will be truthful and exact, implementing, as far as possible, update procedures.

Personal data will be kept for the time necessary to fulfill the purpose of the processing, except for subsequent storage provisions in accordance with the law.

V y V and, where appropriate, those in charge of processing will adopt the technical, organizational, and legal measures necessary to guarantee the security of personal data.

Through this policy, V y V informs the holders of personal data who can exercise their rights contained in the constitutional right to the protection of personal data in administrative headquarters before the National Data Protection Authority and in jurisdictional headquarters before the Judicial Branch.

V y V guarantees an adequate level of security in the processing of personal data, with a minimum of protection comparable to that provided by current regulations, or by international standards on the matter.

2. Because it is important to always have your prior, express, and informed consent …

V y V requests the prior, express, and informed consent of the owners of the personal data on which it is required to carry out the processing; however, … What does a prior, express, and informed consent mean?

Prior: It means that consent must be granted by the Holder prior to the collection of personal data.

Express: The consent of the Holder must be explicit and concrete, open or non-specific authorizations are invalid. The Holder is required to express willingness to authorize V y V to process personal data.

Informed: The Holder of personal data must be clearly informed about the following:

1. The identity and address or address of the holder of the personal data bank who can be contacted to revoke consent or exercise your rights;
2. The purpose or purposes of the processing to which your data will be submitted;
3. The identity of those who are or may be its recipients, if applicable;
4. The existence of the personal data bank in which they will be stored, when appropriate;
5. The mandatory or optional nature of responses to the questionnaire proposed, when applicable;
6. The consequences of providing personal data and of refusal to do so; and
7. If applicable, the national and international transfer of data to be processed.

V y V may obtain said consent through various means, including physical and electronic documents, voice messages, websites, or in any other format that allows it to be unequivocally obtained.

3. Processing and transfer of Personal Data

If V y V had authorization from its clients, it may offer, through any written, verbal, electronic and / or computer means, any of the products or services of its own, of the group company or of the commercial partners, transferring the personal data to any of the group companies or business partners or third-party companies for each of them may offer their products or services through any written, verbal, electronic and / or computer means.

The Personal Data obtained will be incorporated into the Database of Web Users and Prospects of Clients of V y V, pursuant Law No. 29733, Law on Protection of Personal Data, and Supreme Decree No. 003-2013 -JUS, which will be stored on the Microsoft Azure web server located in the United States; in this sense, the User declares to know and accept that V y V may transfer User Information to the companies that make up the Group and outsourcing companies that provide processing services based on cloud infrastructure abroad, for hosting purposes, information storage and processing. It should be noted that said processing is necessary for the execution of the contractual relationship or potential contractual relationship of the Group with the User.

The companies that make up the Group are the following:

In V y V, sensitive data have special consideration. That is why their processing is strictly restricted and is subjected to reinforced levels of security that allow guaranteeing their confidentiality. Likewise, V y V prohibits its suppliers and direct or indirect workers from partially or totally disclosing sensitive data without the authorization of its owners, except for the exceptions provided by law.

4. Quality of Personal Data

The personal data requested will be adequate, relevant, and not excessive in relation to the purpose for which they are collected. These must be accurate and correct so that they respond truthfully to current situation.

Personal data will be canceled when they are no longer necessary for the purposes associated with their collection, or until consent is revoked. However, they will be kept for as long as some type of responsibility of the V y V derived from this relationship or the result of any provision as required by law.

5. Why do we process personal data?

The processing of personal data of the holders with whom V y V establishes a relationship, permanent or occasional, may be collected and processed, among other purposes, for:

Comply with current Peruvian regulations.

Comply with the requirements of the competent authorities.

Attention to inquiries, claims and requests.

Develop selection processes for the incorporation of new collaborators.

Management of the human resources of the company.

Comply with contractual commitments of various kinds.

Ensure corporate security.

Carry out statistical studies.

Implement improvements in the quality of the processes.

In the process of collecting personal data, the specific purpose in each case will be informed, requiring consent for any additional purpose of processing.

6. What are your arc rights as the owner of personal data?

The current regulations on data protection grant the owner of personal data a set of rights that guarantee control over them. Within this group, there are rights that must be taken care of in times strictly provisioned by law, these are:

1. Right of access: Right to obtain information about the personal data that are subject to processing by V y V.
2. Right to information: Right to be informed in simple detail and prior to the collection of data about: the purpose for which your personal data are processed, the existence of the data bank in which they are stored, the identity and address of the owner of the data bank that collects personal data, and where appropriate the person in charge of processing personal data.
3. Right of rectification or update: Right to request V y V to correct the personal data being processed, either due to inaccuracy or omission. It incorporates the right to update and inclusion.
4. 4. Right of cancellation or deletion: Right to request the deletion of personal data, canceling their processing.
5. Right of opposition: Right to oppose the processing of personal data based on well-founded and legitimate reasons.

In order to exercise these rights, V y V makes two service channels available:

Via email: Sending an email addressed to protecciondedatos@vyv.pe, with the reference “Protection of Personal Data”, proving identity, specifying the type of request and reasons. If additional information is required, it will be communicated in a timely manner by the same means.

In person: Approaching our offices in the district of Miraflores, national document of identity (DNI / CE / Passport) must be submitted, validating ownership, if a legal representative appears, it must be accredited as such, that is, power of attorney or title that confirms authorization to act on behalf of the owner to exercise any of the ARCO rights, the owner or representative must fill out a request for attention and submit the documents that support request, if applicable.

Requests will be attended by V y V at no cost in the following terms from the date the request is submitted:

Right to information: 8 business days.

Right of access: 20 business days.

Right of rectification, update, cancellation, deletion, or opposition: 10 business days.

Modification of the Privacy Policy

V y V reserves the right to modify this Policy at any time and without prior notice. Any modification will take effect and will have effects against related third parties from its publication on this website.

For any questions related to this Policy, you can contact us through the email protecciondedatos@vyv.pe or approach our offices located in Miraflores.

Web Cookies Policy – V y V

1. INTRODUCTION

At V y V we are committed to respecting the privacy of our clients and protecting the confidentiality of their private information and personal data; thus being aware of the high consideration that your privacy and of all those people who are interested in our services, we comply respecting the provisions for the processing of your personal data provisioned by Law on Protection of Personal Data – Law No. 29733, its Regulations, approved by Supreme Decree No. 003-2013-JUS, the Security Directive and other related regulations.

Within the framework of this adaptation, V y V has a website https: //www.V y V.pe, which uses cookies, which is why it is necessary to ensure with the maximum reserve and protection, those personal data that Users of the Internet site, can store when entering the aforementioned website, hereinafter the Web.

V y V, describes in this document the “Cookies Policy” that regulates the Web, with the aim of guaranteeing the privacy of Internet Users, hereinafter Users.

We inform Users that on the Web we use cookies, both our own and those of third parties.

These cookies allow us to facilitate the use and navigation, guarantee access to certain functionalities and additionally, help us to improve the quality of the Websites according to the browsing habits and styles of the Users.

V y V uses cookies that are strictly necessary and essential for you to use the Websites and allow you to move freely, use secure areas or personalized options.

1. WHAT ARE COOKIES?

Cookies are small text files that websites store on your computer, smart phone (Smartphone), Tablet or any other Internet access device.

2. WHAT ARE THEY FOR?

Cookies are used to recognize the device of Users when they visit the Web again, facilitating its use, remembering their preferences and navigation settings (e.g., language, country, etc.). They also serve to improve the services we offer and to be able to collect statistical information that allows us to understand how Users use our website and helps us improve its structure and content.

Some cookies are strictly necessary for the website to function properly, and others serve to improve performance and your user experience.

Cookies are only associated with an anonymous User and the Internet access device and do not provide references that allow the User’s personal data to be deduced. Cookies cannot damage your device and are also very useful, since they help us to identify and resolve errors.

Every time you enter the web, we display the information regarding our Cookies Policy at the bottom of the page. Given this information, the User can perform the following actions:

Click on accept the use of cookies and read about our Cookies Policy. By accepting the cookie message, this notice will not be displayed again during this session.

Do not click on accepting the use of cookies and continue browsing the website; however, when accessing any other section of the web, the notice will be displayed again at the bottom.

3. TYPES OF COOKIES

Depending on the entity that manages the website from which the cookies are sent and treats the data obtained, the following can be distinguished:

1. Own cookies: These are those that are sent to the User’s Internet access device from the website managed by the owner of the site and from which the service requested by the Internet User is provided.
2. Third-party cookies: These are those that are sent to the User’s Internet access device from the Web, which is not managed by the owner of the site, but by another entity that processes the data obtained through cookies.

Depending on the period of time that they remain activated on the User’s Internet access device, the following can be distinguished:

1. Session cookies: Type of cookies designed to collect and store data while the User accesses the Web. They are usually used to store information that is only interested in keeping for the provision of the service requested by the User on a single occasion (the session being used at that time).
2. Persistent cookies: Type of cookies in which the data is still stored on the User’s Internet access device and can be accessed and processed during a period defined by the person responsible for the cookies, which can range from a few minutes to several years.

Depending on the purpose for which the data obtained through cookies are processed, the following can be distinguished:

1. Technical cookies: Technical cookies are those essential and strictly necessary for the proper functioning of the Website and the use of the different options and services it offers. Among others, they serve for the maintenance of the session, the management of response time, performance, or validation of options, use security elements or share content with social networks.
2. Personalization cookies: These allow the User to access the service with some predefined general characteristics based on a series of criteria on the User’s device, such as the language, the type of browser used to access the service, the regional configuration from where you access the service, etc.
3. Geo-location cookies: These cookies are used to find out which country you are in when a service is requested. These cookies are completely anonymous and are only used to help guide content to your location.
4. Analysis cookies: These allow the person responsible for them to monitor and analyze User behavior on the Web. The information collected by means of this type of cookies is used in the measurement of the activity of the Web and for the elaboration of navigation profiles of the Users, in order to introduce improvements based on the analysis of the data of use that the Users make.
5. Advertising cookies: These allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the owner has included on the website from which the requested service is provided based on criteria such as content edited or how often the ads are shown.
6. Behavioral advertising cookies: These are those that allow the management, in the most efficient way possible, of the advertising spaces that, where appropriate, the owner has included on the website from which the requested service is provided. These cookies store information on the behavior of the User obtained by the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on it.
7. Registration Cookies: These are generated once the User has registered or subsequently opened session and are used to identify him in the services so that, if a service is closed, the browser or the computer, and in another time or on another day, he enters the service again, he will continue be identified, thus facilitating navigation without having to identify himself again. This functionality can be suppressed if the User presses the “close session” functionality, so that this Cookie is eliminated and the next time the User enters the service, the User will have to log in to be identified.

4. WHAT KIND OF COOKIES DOES THIS WEBSITE USE?

The following cookies do not personally identify Users, they only provide anonymous statistical information about browsing the Web; however, you can disable them directly by configuring your browser.

The cookies that are being used on the Web are listed below *:

Name                         Yandex

Type               Third-party cookie.

Permanence

Purpose         Obtain user navigation data on the web platform and paint them with colors that differentiate which section of the web is the most viewed by them.

Name                                     Google Tag Manager

Type                           Third-party cookie.

Permanence                        An approximate 30 minutes and two years.

Purpose                    It is an administration system or tag manager that allows us to update all those tags / pixels / codes easily and quickly within its platform without having to directly add the code on the web or apps.

Name                                     Google Analytics

Type                           Third-party cookie.

Permanence                        An approximate 30 minutes and two years.

Purpose                     It is used to monitor the status of a website, basically it is a web analysis service with which you can obtain different types of information from a site, such as its number of visitors or the conversion rate, for example, all of them in real time.

Name                                     Youtube

Type                           Third-party cookie.

Permanence                        An approximate 30 minutes and two years.

Purpose                     Deploy videos on the web using the YouTube video engine.

Note: V y V informs that the servers of the cookies used on this website have a physical location in the United States of America, the information being collected by the cookies is sent outside the national territory for storage.

5. MANAGEMENT OF COOKIES

By providing this Policy, V y V exposes to its Users the commitment acquired on the use of cookies, giving them access to information so that you can understand what type of cookies we use and why we do it. With this, we intend to provide you with transparency regarding the data processed about the navigation carried out from your computer on the Web.

If you accept our cookies, you allow us to improve the V y V website to offer you optimal access and give you a more efficient and personalized service.

In addition, you can configure your browser to set that only trusted websites or pages you are currently browsing can be accessed.

Manage cookies which allows you to select your preferences.

If you as a User decide not to authorize the processing indicating your non-compliance, we will only use technical cookies, since they are essential for browsing our website. In this case, we would not store any cookies. If you continue browsing our website without denying your authorization, it implies that you accept its use.

Keep in mind that, if you reject or delete Web browsing cookies, we will not be able to maintain your preferences, some features of the pages will not be operational, we will not be able to offer you personalized services and every time you browse our Websites, we will have to ask you again your authorization for the use of cookies.

If, even so, you decide to modify the configuration of your access to the Web pages, you should know that it is possible to eliminate cookies or prevent this information from being recorded on your computer at any time by modifying the configuration parameters of your browser.

To block or disable cookies, the User must activate the browser settings, so that the installation of all cookies or some of them is rejected. In practice, most browsers allow to warn of the presence of cookies or to reject them automatically. If they are rejected, you can continue using our website, although the use of some of its services may be limited and, therefore, the User’s experience may be less satisfactory.

The accesses to the cookie settings of the main browsers are the following:

Internet Explorer: Tools -> Internet Options -> Privacy -> Settings.

For more information, you can consult Microsoft support or browser Help. In each browser the operation to be followed is different, but the “Help” function of the Web of each browser will show you how to do it, as it happens, for example, for Internet Explorer: windows.microsoft.com/es-xl/internet- explorer/delete-manage-cookies#ie=”ie-10

Safari: Preferences -> Security. For more information, you can consult Apple support or browser Help at apple.com/es/privacy/use-of-cookies

Firefox: Tools -> Options -> Privacy -> History -> Custom Settings.

For more information, you can consult Mozilla support or browser Help at support.mozilla.org/es/kb/Delete%20cookies

Chrome: Settings -> Show advanced options -> Privacy -> Content settings.

For more information, you can consult Google support or browser Help at support.google.com/chrome/answer/95647?hl=”es ”

ADDITIONAL QUESTIONS

To make any type of query regarding this policy, you can contact the following email address: protecciondedatos@vyv.pe.

VALIDITY AND AMENDMENT OF THIS POLICY

V y V may amend this Cookies Policy based on legislative, regulatory, jurisprudential requirements or with the purpose of adapting said policy to the instructions issued by the National Authority for the Protection of Personal Data, as well as by own business criteria.

For this reason, and given that said policy can be updated periodically, we suggest our Users to review it regularly and that they will find it on the Web “vyv.pe”.