PERSONAL DATA PROTECTION POLICY - Xtreme Tourbulencia
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PERSONAL DATA PROTECTION POLICY

INTRODUCTION

Grupo Tourbulencia in Peru SCRL is a company in the tourism sector dedicated to the sale of tourist services at the national level through service intermediation, which includes: traditional tourist services, cultural tourism service, lodging and food services, tourism service of adventure, tour packages and full days , is located on the street May 3 – Manahuañuncca in the district of Santiago, Cusco.

Grupo Tourbulencia in Peru SCRL is obliged to comply with current Peruvian legislation on the protection of personal data, Law No. 29733 Protection of Personal Data and its complementary provisions.

Therefore, Grupo Tourbulencia in Peru SCRL commits to:

• Ensure the quality and security of the information.

• Respect the rights of people with respect to information about themselves.

Grupo Tourbulencia in Peru SCRL is committed to the protection, handling and proper treatment of personal data to which it has access in the regular operation of its business. This commitment includes the review and continuous improvement of the organization’s processes in order to guarantee adequate protection of said personal data and the guidelines established by Grupo Tourbulencia en Perú SCRL for the collection and processing of personal data in order to ensure respect for the rights of their owners and compliance with the current regulatory framework. The Policy may be supplemented with procedures, regulations and/or additional guidelines that develop what is established in this document, provided that they are aligned with its guiding principles.

RESPONSIBLE FOR COMPLIANCE

Grupo Tourbulencia in Peru SCRL will assign and communicate the corresponding responsibilities to all personnel and suppliers, for compliance with this Policy.

The area responsible for annually reviewing this Policy and making the respective adjustments within Grupo Tourbulencia en Perú SCRL will be the General Management. Likewise, said Management will be in charge of answering any query related to the application and scope of this Policy.

Notwithstanding the foregoing, all employees of Grupo Tourbulencia en Perú SCRL as well as all suppliers and third parties with whom Grupo Tourbulencia en Perú SCRL is linked in the regular exercise of its business and have access to or process personal data are subject to the compliance with the Policy. Finally, no employee of Grupo Tourbulencia en Perú SCRL should carry out, on behalf of the Company, actions or incur in omissions that imply a breach of the Law.

CONFIDENTIALITY

This Policy will be for the internal and exclusive use of Grupo Tourbulencia en Perú SCRL and, therefore, is confidential. Any use other than that indicated is prohibited and must be authorized expressly and in writing by the General Management.

The personal data to which both the employees of Grupo Tourbulencia en Perú SCRL and related third parties have access or participate in their processing may not be processed or used in any way without the prior consent of the owner of the personal data, even after the termination of the processing. its relationship with Grupo Tourbulencia in Peru SCRL, except for the exceptions regulated by law.

In the case of workers who, due to the nature of their duties, have access to confidential and sensitive personal information, the company will seek to develop specific training and awareness actions. The people who intervene in the processing of personal data are obliged to keep professional secrecy and maintain confidentiality with respect to them. Said obligation will be maintained even after the termination of its relationship with Grupo Tourbulencia in Peru SCRL.

PERSONAL DATA TRANSFERS

The personal data subject to treatment by Grupo Tourbulencia en Perú SCRL may only be assigned or transferred to third parties for the fulfillment of the purposes related to the legitimate interest of the assignor and the assignee and with the prior, express, free, unequivocal and informed consent of the owner of the personal data. Such consent will not be required in the cases permitted by law.

SENSITIVE DATA COLLECTION

Grupo Tourbulencia en Perú SCRL will only collect personal data and/or sensitive data when strictly necessary and in compliance with the principles of purpose and proportionality. When the collection and processing of said data derives from the fulfillment of a legal obligation, Grupo Tourbulencia en Perú SCRL will inform the owner of the data of such a situation prior to its collection.

DISCLOSURE OF PERSONAL DATA

Grupo Tourbulencia en Perú SCRL will not disclose personal data to third parties except when: a) It is necessary for the purpose for which the personal data was collected; as in the provision of services through third parties and suppliers. b) The owner of the personal data is informed before the disclosure or at the time of the collection of the personal data. c) The owner of the personal data gives his prior and express consent. d) Consent is not required by law. e) Personal data is required by public entities within the scope of their legal powers and powers. f) The personal data is necessary to satisfy the legitimate requirements of any company interested in acquiring any of the operations of Grupo Tourbulencia in Peru SCRL, with the prior consent of its owner; or, g) Access to personal data is by auditors and lawyers and other professionals obliged to keep professional secrecy.

DELETION OF PERSONAL DATA

Once the processing of personal data has been completed and the principle of purpose has been fulfilled, and provided that there is no legal mandate or reason that justifies the conservation of personal data, Grupo Tourbulencia en Perú SCRL will proceed to eliminate them from its records. Alternatively, Grupo Tourbulencia en Perú SCRL may apply dissociation processes, or equivalent when for any commercial, statistical or market analysis reason they justify the convenience of keeping such data. Grupo Tourbulencia en Perú SCRL will opportunely define the respective procedures that are necessary for the elimination of personal data.

SANCTIONS REGIME

An employee who commits any infraction of the provisions established in this Policy will be considered a serious offense and liable to sanction. Grupo Tourbulencia en Perú SCRL will take the disciplinary measures it deems appropriate in cases of non-compliance with the obligations stipulated herein by employees.

DISSEMINATION AND COMPLIANCE WITH THE POLICY

Grupo Tourbulencia en Perú SCRL will ensure compliance with the provisions of this Policy; make known, observe and respect this Policy by each employee; publish this Policy in easily accessible places and sign confidentiality obligations with employees, users, contractors and third parties who access the personal data included in the databases.

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