GENERAL PRIVACY POLICY

1. Introduction

The Grupo T&C, consisting of different companies detailed in Appendix II of this document (hereinafter, “T&C”), all located at Av. Javier Prado Oeste No. 769, San Isidro District, province and department of Lima; make available this Privacy Policy, the conditions for the general processing of personal data of its customers and/or users who access the website: https://www.grupotyc.com/

2. Objective and Purpose

In T&C we are particularly interested in offering to the personal data owners the highest level of security and protect the confidentiality of their information. For such purpose, commercial relations are carried out in a secure server environment under SSL (Secure Socket Layer) protocol, which means that the information is kept encrypted and secure, currently used by the most important companies in the world to process secure electronic transactions. This website was created and designed to provide all kinds of information that we believe may be of interest and, thus, create a space of communication for the personal data owners.

3. Legislation

This policy is regulated by Peruvian law and in particular by:

• Law N° 29733 – Personal Data Protection Law.
• Supreme Decree No. 003-2013-JUS, Regulation No. 29733.

According to Law No. 29733 – Personal Data Protection Law and its Regulation approved by Supreme Decree No. 003-2013-JUS, personal data is considered to be any numerical, alphabetical, graphic, photographic, acoustic, personal habits, or any other type of information concerning a natural person that identifies them or makes them identifiable through means that can be reasonably used.

Furthermore, the Processing of Personal Data is considered as any operation or technical procedure, automated or not, that allows the compilation, registration, organization, storage, conservation, elaboration, modification, extraction, consultation, use, blocking, suppression, communication by transfer or diffusion or any other form of processing that facilitates the access, correlation or interconnection of personal data.

4. Storage of information

The personal data provided through our website https://www.grupotyc.com/ will be stored in the data banks called “Clients” and “Prospects”, for the term indicated in each privacy notice or consent. It is important to inform our customers that our data banks are duly registered at the General Management of Personal Data Protection, as required by the current regulations in force.

The information provided by the owners of the personal data may only be known and handled by T&C staff who need to know this information in order to send or answer the requests of the holders of the personal data. This personal data will be treated in a fair and lawful manner and will not be used for other purposes not compatible with those specified.

5. Practice of Law

The owners of personal data who provided us with their information may contact T&C, in order to execute their rights of information, access, update, inclusion, rectification and deletion, to prevent the disclosure of their personal data, to oppose the processing or objective processing of the data, under the terms set forth in the Peruvian legislation in force.

The owners of personal data may execute their rights by submitting a written request at our main office, located at Av. Javier Prado Oeste N°769, San Isidro, during the hours established for customer service or e-mail address servicioalcliente@grupotyc.com (with subject ” Personal Data Protection”), specifying their information, proving their identity and the reasons for their request. Other channels may be established to process these requests, which will be informed in due course by T&C.

6. Quality of Personal Data

The information requested from the owners of the personal data are basic contact information and are adequate, relevant and not excessive regarding the purpose for which they are collected.

The personal data, that T&C will have access to, will be those that the owners of the personal data voluntarily provide by registering in the forms provided for that purpose.

T&C provides to the owners of personal data the proper technical resources to make them aware of this Privacy Policy.

The personal data provided by the owners must be truthful to their current situation, otherwise these data will be canceled.

The personal data will be deleted when they are no longer necessary for the purposes for which they were collected. However, they will be kept for an indefinite period of time.

7. Purpose of the Processing of Personal Information

The personal information you provide to us through many contact points of T&C will be used for the following purposes:

7.1. About the personal data of our Customers:  

• Register personal data for statistical and historical purposes.
• Attend all the requirements and formalities derived from the contractual relationship with T&C;
• If it is expressly authorized, communicate information about deals, benefits, contests, offers and, in general, advertise new projects of T&C.
• Conduct satisfaction surveys, demand studies, media effectiveness, among others, related to the activities of T&C.

7.2. About the personal data of our Prospects:

• Record personal data for statistical and historical purposes.
• To establish an effective channel of communication to obtain a response to the quotations made about new T&C projects.
• If it is expressly authorized, report about offers, deals, benefits, contests and advertising in general that T&C may offer.

7.3. About the Claim Book Data:

• Establish a communication channel to answer management requests, complaints and claims that have been registered by the user and / or consumer.
• Keep a record of the people who file grievances and complaints through the Claims Book in order to comply with consumer protection regulations.

7.4. About the personal data of Employees:

• Properly execute contractual relationship.
• Verify the information provided through public or private access source (it is possible to verify criminal, judicial and police records).
• Comply with legal obligations, manage payments, administrate and execute benefits.
• Evaluate the employee’s performance, as well as compliance with obligations, rules and internal policies.
• For the compliance with safety standards and occupational risk prevention.
• Investigate incidents and take disciplinary or corrective actions.
• Conduct appropriate medical check-ups such as occupational medical exams
• Perform activities related to knowledge management (training, workshops, courses, conferences).
• Carry out internal audits and surveys
• If authorized by the employee, use the image and voice of T&C for commercial and internal activities.
• If authorized by the employee, send communications by e-mail, telephone and/or physical address about deals, benefits, contests, offers and, in general, advertising T&C products and services.

7.5. About personal data of Applicants:

• Participate in recruitment processes for available positions in T&C.
• Establish a communication channel regarding the personnel selection process.
• In case of not being selected, contact the applicant about future openings.
• Verify the information provided through public or private access sources.
• Keep a record for statistical and historical purposes.

7.6. About personal data of Video Surveillance:

• Enterprise control and security of T&C projects.
• Security and access control to the projects.

In order to send you advertising information, you must give us your express authorization through the check boxes implemented in our forms of consent, because without your authorization, T&C will be unable to send you this type of communication.

8. Transfer of Personal Data Communication

In T&C we respect the privacy of the owners of personal data, we do not transfer your information to third parties if you do not expressly give us your consent to do so. Likewise, it is convenient that the owners of the personal data know that their information may be disclosed to administrative entities, judicial authorities and/or police, as long as it is established by law.

Without prejudice to the foregoing, we inform the owners of personal data that in order to process their information more efficiently, T&C may use service providers in order to carry out certain activities of the business. Consequently, regarding the information of the owners of personal data, these providers will have the status of data processors in accordance with the provisions of the Law and its regulations. The details of these third parties are detailed in APPENDIX I of this policy.

Likewise, if it is authorized, T&C will transfer your information to the related companies of the group, for advertising purposes. The details about the companies to which T&C will transfer your information can be found in APPENDIX II of this policy.

9. Personal Data Confidentiality

The information provided by the owners of the personal data will be treated with total confidentiality. T&C is committed to maintain professional secrecy indefinitely regarding them and guarantees the duty to keep them using all the necessary security measures.

10. Personal Data Security

In compliance with current legislation, T&C has adopted technical security and confidentiality measures adequate to the category of personal data, necessary to maintain the required level of security in order to prevent alteration, loss or unauthorized access or processing that may affect the integrity, confidentiality and availability of the information.

T&C has implemented all legal, technical and organizational measures necessary to ensure the security of personal data and avoid its alteration, loss and treatment and/or unauthorized access, taking into consideration the state of technology, the nature of the data stored and the risks they are exposed to, whether from human action, the physical or natural environment, as established by current Peruvian legislation for the protection of personal data.

The company has also implemented additional security measures to reinforce the confidentiality and integrity of the information and continuously monitors, controls and evaluates the process to ensure the privacy of personal data. However, the transmission of information via communication networks and the Internet is not completely secure; therefore, while T&C will use its best efforts to protect personal data, it cannot guarantee the security of personal data during transit to the Website.

To this effect, all information provided by the owners of the personal data will be sent at their own risk. Therefore, T&C recommends the highest diligence to the owners of personal data when transferring to third parties or publish personal information to avoid putting at risk their personal data, avoiding T&C any responsibility in case of theft, modification or loss of illicit data.

11. Underage Users

T&C understands the importance of protecting the privacy of children, especially in an online environment. That is why the Website is not designed for or directed to children under the age of 14.

T&C will not voluntarily process personal data relating to undergage users. In the event that it becomes known that the personal data collected corresponds to a underage without authorization, appropriate measures will be taken to delete this data as soon as possible.

12. Period and Modification of this Privacy Policy

T&C reserves the right to modify its Web Privacy Policy in the event that there is a change in current legislation, doctrinal, case law or business criteria. If any change is made in this Policy, the new text will be published in this website.

13. Other

If you have any questions regarding this policy, please contact us at the following e-mail address: servicioalcliente@grupotyc.com

It is recommended that the owners of personal data periodically access this Privacy Policy, which can be found on this Web site.

APPENDIX I – THIRD PARTIES WITH ACCESS TO PERSONAL DATA

APPENDIX II – COMPANIES OF THE REAL ESTATE GROUP T&C

The company mentioned below is located at Av. Javier Prado Oeste No. 769, San Isidro District, Province and Department of Lima:

• T&C HOLDING SAC