PERSONAL DATA PROCESSING POLICY
I. SCOPE
“Personal Data Processing Policy” is applied to all activities that CONTE GROUP S.A.C. (hereinafter “CONTE GROUP”) may deal with personal data processing. It will also apply to those persons or companies from which CONTE GROUP requires the personal data processing, for which it is responsible.
II. GENERAL INFORMATION
CONTE GROUP is a company dedicated to the production and distribution of supplies for the Peruvian industry.
As part of our activity, CONTE GROUP process personal data in compliance with Law No. 29733 – Personal Data Protection Law (the Law), its Regulation, approved by Supreme Decree No. 003-2013-JUS (the Regulation), and its complementary and amending rules (hereinafter defined as the “Personal Data Protection Regulation”). The personal data processed are stored in the personal data banks in possession of CONTE GROUP.
III. OBJECTIVE
The purpose of this policy is to make publicly aware of our commitment with the personal data protection; the guidelines to process them in the course of our commercial activities. The procedures under which the data holders can exercise their rights to access, rectification, cancellation and opposition, as provided for in the Personal Data Protection Regulation.
IV. PURPOSE OF THE PERSONAL DATA PROCESSING
CONTE GROUP processes personal data on: applicants, colleagues, clients, potential clients, suppliers and all those who visit our facilities and/or having any legal or commercial relationships with our company. In this regard, CONTE GROUP processes said information in accordance with the current regulation, so that it may execute any and all types of current legal relationships and/or that might exist between the data holders and our company, whether these are due to business, work, civil and/or any other nature, as well as for promotional purposes and/or any other lawful purpose duly informed to said personal data holders.
V. GUIDING PRINCIPLES
CONTE GROUP is committed to observe the following guidelines established in the Personal Data Protection regulations:
a) Legality Principle: Personal data is processed as established by law; personal data obtained through fraudulent, unfair or illegal means is prohibited.
b) Consent Principle: There must be consent from the personal data holder.
c) Purpose Principle: Personal data is to be obtained for a specific, explicit and lawful purpose. Its processing must not extend to any purpose other than that for which it was obtained.
d) Proportionality Principle: The personal data processing must be appropriate, relevant and not excessive to the purpose for which they were obtained.
e) Quality principle: The personal data to be processed must be truthful, accurate and, as far as possible, updated, necessary, pertinent and appropriate respect of the purpose for which it was obtained.
f) Security principle: The personal data holder and the person in charge of its processing, must adopt the necessary technical, organizational and legal measures to guarantee security of the personal data.
g) Legal recourse availability Principle: The personal data holder must have the necessary administrative or jurisdictional means to claim and assert its rights, when its personal data processing is violated.
h) Appropriate Protection Principle: For cross-border flow of personal data, appropriate protection must be guaranteed for the personal data processing or, at least, equivalent to those provided by the Personal Data Protection Law or by the international standards.
VI. CONSENT
CONTE GROUP requires the free, prior, express, unequivocal and informed consent of the personal data holder for the processing thereof, except in cases of exception expressly established by law.
CONTE GROUP does not require consent for the personal data processing obtained from sources accessible to the public, whether free or not. Likewise, it may process your personal data from public sources, in accordance with Art. 17th of the Regulation.
VII. TRANSFER OF PERSONAL DATA
In order to fulfil with the Personal Data Processing Policy, CONTE GROUP may transfer personal data, to local or international companies already forming part of the CONTE GROUP, or companies to be created in the future.
CONTE GROUP may transfer personal data to the police, public prosecutor’s office, tax, customs, the judiciary, the congress authorities, investigation commissions and other public entities, legally empowered under the law, whether in compliance with current regulations and/or at their request.
VIII. PROCESSING BY REQUEST
CONTE GROUP may entrust part of the personal data processing, for which it is responsible, or forms part of the personal data bank, where it is a holder, to legitimate suppliers. The personal data holders shall be previously informed about the name of the company which will be in charge of their data processing, as well as its address and electronic mail.
IX. RIGHTS OF THE HOLDERS
Following are the rights of the personal data holders, in accordance with the Law:
a) Right to Information: The personal data holder has the right to be informed in detail, simply, expressly, unequivocally and prior to its collection, about the purpose of its personal data processing; who is, or may be the addressee and about everything referred to in Article 18 of the Law.
b) Personal Data Holder’s Access Right: The personal data holder has the right to obtain information about himself, that may be the object of CONTE GROUP’s owned data banks processing.
c) Right to Updating, Inclusion and Rectification: The personal data holder has the right to update, include and rectify its personal data which is being processed by CONTE GROUP, when these are partially or totally inaccurate, incomplete or whenever there is an inadvertent omission, error or falseness.
d) Cancellation or Deletion Right: The personal data holder may request the cancellation or deletion of its personal data, not related or necessary for the execution of the obligations in charge of CONTE GROUP, provided in the signed contracts or those provided by current regulations.
e) Right to Objection: The personal data holder may object to processing its personal data at any time. The objection will proceed when such processing has no contractual or legal justification.
X. PROCEDURE TO EXERCISE THE PERSONAL DATA HOLDER’S RIGHTS
Holders may revoke their consent or exercise their legal rights by presenting their ID (DNI) or other official identity document and sending their request and/or enquiries to:
- Electronic mail: recursoshumanos@contegroup.org
- Headquarters: Av. Separadora Industrial 1591, District of Ate, Province and Department of Lima (Customer Service Area).
- Stores at national level. See branches (Customer Service Area).
In the event that the personal data holder needs to exercise his rights through a representative, he must submit a power of attorney legalized by a notary public that authorizes him as such, together with his Identity Document.
XI. DEADLINE FOR PERSONAL DATA PROCESSING
The personal data processed by CONTE GROUP will be stored as long as it may be necessary to fulfill the purpose set forth in this Personal Data Processing Policy.
XII. PERSONAL DATA SECURITY
In compliance with the current regulations, CONTE GROUP adopts the appropriate legal, organizational and technical measures to guarantee the security of personal data, avoiding its alteration, loss, improper processing or unauthorized access.
In this regard, all the necessary human and technological resources are available, applying them in proportion to the nature of the data stored and the risks to which they are exposed.
CONTE GROUP will only process personal data that may be stored in repositories that meet the security conditions required by current regulations on personal data protection.
In addition, CONTE GROUP undertakes to periodically carry out internal training that manages to update and improve the personal data handling in order to offer efficient and greater protection over time.
XIII. MODIFICATIONS
This policy has been updated to July 15, 2019 and may be modified by CONTE GROUP S.A.C. when deemed necessary. If any change or modification to this policy occurs, its current text will be published on our web site: https://contegroup.org
XIV. DATA BANK INFORMATION
Holder: CONTE GROUP S.A.C.
Address: Calle Camino Real N° 166, Urb. Industrial San Francisco, Distrito de Ate.
Through my physical signature on this document or by clicking on the icon or acceptance space on the CONTE GROUP website, I declare that I am providing my personal data freely, previously, expressly, voluntarily and unequivocally and I give my consent so that all the verifications are done of my data, my personal or commercial references, credit risk and all others that are necessary for the purposes indicated in this policy. Likewise, I authorize my personal data to be transferred, as required among the companies making up the CONTE GROUP S.A.C.
