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PRIVACY POLICY ON THE MANAGEMENT OF PERSONAL DATA
This document (hereinafter referred to as the "Privacy Policy") is intended to inform visitors and clients of the commercial zones managed by Administradora Jockey Plaza Shopping Center S.A. with Tax ID No. 20306841506 (hereinafter "We") domiciled in Avenida Javier Prado Oeste No. 4200, Jockey Plaza Shopping Center Administrative Offices, Santiago de Surco district, on the use and management of personal data ("Personal Data") we collect or is generated in case of visits and use of the services we provide, downloads and/or registrations on our website, as well as through our different available mobile applications, digital platforms, apps, and social networks, existing and to be created later (hereinafter, "Digital Tools").
Our web pages are: www.jockey-plaza.com.pe
www.yoylimaboxpark.pe
The personal data that you provide or that is generated as a result of the aforementioned interactions will be incorporated into our Customer Data Bank, which is protected with the technical and organizational measures to guarantee its security and prevent corruption, loss, unauthorized processing or access.
We reserve the right to modify this Privacy Policy to adapt it to the applicable statutory and legal regulations within the framework of Law No. 29733, Personal Data Protection Law, and Supreme Decree No. 003-2013-JUS, Law Regulation No. 29733 (collectively, "Personal Data Protection Regulations"), so we recommend you to frequently review this Privacy Policy in case we make updates or changes to it.
Our digital tools include campaigns and offers that also involve our strategic trading partners, who may access the personal data you share with us to send advertising information. Our website or digital tools may contain links to websites and services of other companies with their privacy policies. We recommend you to read the privacy policy of such third party services. We are not responsible for the privacy practices or the content of such third party services.
By using this website or submitting your data to us, you accept the processing and handling of your data as explained in this Policy. If you provide us with your data, it is because you have read and accepted this Policy in its entirety.
1. Personal data storage
We are the legal entity responsible for Personal Data provided by customers or users collected from other sources allowed by applicable laws.
2. Personal Data supervisors
As part of the Personal Data handling, we may entrust part or all of such handling to other natural and/or legal persons, who are referred to as "Personal Data Supervisors", by following the Personal Data Protection Regulations. These people in charge of the treatment may be allies, suppliers or third parties hired to contribute to the execution of the services offered to the users or to help us in the improvement of our services and digital tools made available to the users. Likewise, they may be providers of data analysis and search engines that assist us in the improvement and optimization of the services provided.
3. Personal Data transfer
As part of the Personal Data handling, we may carry out the national or international transfer of these data obtained to natural and/or legal persons other than the Supervisor of the Personal Data handling (for example, subcontracted third parties, databases or servers, located in Peru or abroad).
In the case of transfers of Personal Data abroad, we will inform the National Personal Data Protection Authority (ANPDP) in due time of such transfers so that they may be registered in the National Register of Personal Data Protection, by following the Personal Data Protection Regulations.
4. About the data we collect
Generally, we collect your personal data when you make a purchase, register on our website, download our App and/or use our digital tools, take part in a campaign, fill out a survey or otherwise interact with us. The following are examples of the categories of data we collect.
4.1 Use of our digital tools and services
When you use our digital tools, we automatically collect information about your IP address, access times, the website from which you logged in, pages you visit, links you use, content you review and other information your browser provides to us. Some of our mobile services may obtain your unique mobile device identifiers, subscriber identity information, specific network service provider identifiers, network settings, and other such information. When you interact with us using our digital tools and/or services or otherwise through telecommunications networks, your mobile network provider may transmit to us certain additional information such as your mobile subscription number.
4.2 Email marketing
Sending of information, advertising content, and campaigns, new launches, discounts, among others, both our own and those of the different brands operating within our commercial zones (hereinafter, our "strategic partners").
4.3 Information you provide to us
We may ask you to provide us with the following information: name, email address, postal address, user codes and password for access to our digital tools, acceptances, preferences, and comments, information regarding your devices, age, gender, postal code and language preferences. Please note that certain non-identifiable information collected from you may become identifiable when providing us with your personal data. Also, following the applicable regulations, we may collect some personal data from credit bureaus and other publicly available sources. Some of our services may allow you to send information about other people, for example, if you place an order for a product that you want us to send directly to another recipient.
4.4 Transactions with us
We collect information regarding the services you use and/or the use of our digital tools and other interactions with us. Such information may include details of any enquiries or requests you have made, products supplied, delivery details, bank account number, credit card details, billing address, verifications of credit capacity and other similar financial information, contact and communication records, information and details relating to the content you have provided to us and other similar transaction information.
4.5 Location data
Due to the characteristics of the digital services and tools that we make available to you, it may be necessary for us to access and use your location data like an IP address from satellite, Wi-Fi or other networks. For example, when you search by location or use weather characteristics by location or request data from a map, we can receive your location data to provide you with the correct content. This may include location-based advertising. Some location-based services may allow us to relate your personal data to your location.
Assisted device positioning methods, e.g. A-GPS, give you faster and more accurate location data. Using assisted positioning methods may involve exchanging your location data, wireless network identifiers along with the unique identifiers of your network service provider or the device.
We process this information anonymously. Depending on your positioning settings and your use of the location services of other service providers, your device may connect to the other service providers' servers that are not under our control or operation. We recommend you to check the privacy policies of those service providers to understand how they process your location data. You can modify the positioning definitions of your device in its settings, for example, you can change or disable positioning methods or location servers or modify the accuracy of your location data.
4.6 Acquired products
We reserve the right to change the web content and digital tools that we make available to you.
All photos are referential and both the color and specifications of the products we can offer through our digital tools may vary from those published on the web. It is important to mention that the resolution of each screen is different and therefore the color of the product can have slight differences.
The models and pieces on which the products are shown, in no case and under no circumstances are included in the sale; the sale of products is limited to the specification of the product description.
5. Use of the mobile device in areas managed by us
Depending on your device, when you use it for the first time you can create an account on our website and/or app or it may be necessary to log in with the email account you already have. During the activation process we will receive your user code, email address; unique mobile device identifier and subscriber identity information and we may link these data to your Account. This combined information may be used to activate account warranties and certain software licenses, as well as to send you customized messages, such as e-mail, text, and others. These messages may contain information about our services and products or services offered by our strategic business partners, such as campaigns, tips and marketing offers.
You may unsubscribe from these messages at any time by clicking on the unsubscribe link at the bottom of any email we send you, which gives you the option to “Unsubscribe”.
You will automatically no longer be subscribed to our subscriptions or marketing emails.
6. We share your personal data
We do not sell or otherwise disclose or share your personal data to third parties except in the following cases:
6.1 With your approval and to shared social services
We may share your personal information if we have your approval, which is materialized with the acceptance of the terms and conditions expressed in this Policy through a check-box and in the authorization that we request when you register to any of our digital tools. Some services may allow you to share your personal data with other service users or with other services and their users. Please consider carefully before disclosing any personal data or other information that may be accessed by other users.
6.2 Companies related to us and authorized third parties
We may share your personal data with other companies related to us or with authorized third parties who process personal data for us for the purposes described in this Policy. This may include, for example, billing through your network or another service provider, delivery of your purchases, provision of services including customer service, management, and analysis of consumer data, verification of credit capacity, market research and management of marketing and other campaigns, etc.
We can make joint marketing and other communications with our partners; for example, with operators of the commercial zones we manage. To avoid any duplicate or unnecessary communication and to adapt the message to your needs, it may be necessary for us to match the data we have recorded with those handled by our strategic partners, in which case we are governed by regulatory provisions governing the personal data processing.
Such authorized third parties are not permitted to use your personal data for any other purpose. We require them to act following this Policy and to use appropriate security measures to protect your personal data.
6.3 Mandatory disclosures
We may be forced by mandatory laws to disclose your personal data to certain authorities or other third parties. Also, we may disclose and otherwise process your personal data following the applicable regulations to defend our legitimate interests, for example, in legal, civil or criminal proceedings or administrative proceedings.
6.4 Mergers and acquisitions
If we decide to sell, buy, merge or otherwise reorganize our business, it may be necessary for us to share personal data with leads or actual purchasers and their advisors or to receive personal data from sellers and their advisors.
7. Children’s privacy processing
The digital tools and services we offer are aimed at the general public. We do not collect information from minors without the consent of parents or guardians.
8. Quality assurance of personal data
We take the necessary steps to keep your personal data private and secure. Only authorized members of our staff or authorized personnel of third parties (e.g. service providers) or authorized personnel of our trading partners (who have a legal and contractual obligation to keep all information secure) have access to your personal data.
We require the commitment of all our staff having access to your personal data to respect this privacy policy and data protection regulations. We also require third parties who have access to your personal data to enter into confidentiality agreements with their employees concerning the information to which they have access, under the terms set out in current legislation. In addition, we contractually ensure that third party companies with access to your personal data will keep it secure.
To ensure the protection of your personal data, we have an Information Technology security environment and take the necessary steps to prevent unauthorised access (e.g. through piracy).
As certain digital tools and services we offer may allow you to manage your profile, we invite you to access your personal data regularly to ensure that they are correct, update them or delete your user, if appropriate.
Before deleting your data or removing your user from any of our digital tools, you must consider that your personal data required, on a mandatory basis, are important and necessary for us to provide the services requested by you or you can use our digital tools, so that, if you refuse to provide the information we request, as appropriate, we reserve the right not to continue with the execution of the services and/or invalidate your access to digital tools, in accordance with these conditions and applicable laws.
If there is a change in your personal data, it is your responsibility to update the data you have already provided to us.
9. Steps to protect personal data
Privacy and security are fundamental to the creation and optimal functioning of our digital tools and services. We have assigned specific responsibilities to address privacy and security issues. We enforce our internal policies through appropriate choice of activities. We take appropriate steps to address online security, physical security, risk of data loss and other similar risks taking into account the risk involved in the processing and the nature of the data under protection. Besides, access to our databases containing personal data is restricted to authorized persons who need access to such information.
10. Use of cookies and hit counter
In addition, our platform collects information through the use of cookies to improve the user experience, as well as to better understand how the user interacts with the platform and the digital tools made available to them.
A cookie is a unique, random number that is stored in your computer's browser and does not identify the user browsing the web page, only the computer you are using to visit the site. Cookies allow us to collect non-personally identifiable (i.e., completely anonymous) navigational information from the user. For example, through the use of cookies, we can learn how many users visit our website, which sections they access, or which web browser they use when they visit our website.
They may also be used to display targeted ads and recommendations, for example, not to show you the same ads several times or to show you ads that we think interest you based on your browsing on our website. Cookies are also used to determine the effectiveness of our offers and advertising campaigns, as well as to improve our services, digital tools, and your browsing experience.
Nevertheless, if you do not want information collected through the use of cookies, you can disable their use by modifying the settings of your browser (check your browser’s instructions). The disabling does not prevent the display of the website content or interfere with your navigation.
Some of our websites or applications may use what are called locally stored objects, such as local shared Flash objects ("Flash cookies") or local HTML5 storage. Locally stored objects are used for purposes similar to cookies but may generally contain a greater amount of data than browser cookies. For example, in Flash you can use the Flash Player Settings Manager to control the storage of shared local objects, including disabling shared local objects only for certain websites or disabling the storage of shared local objects for all websites entirely.
Some of our websites use third-party advertising technologies such as DoubleClick to show ads. DoubleClick uses a cookie to collect information about your visits to our websites and from third parties. This information is used to display ads on our and third party websites. The information collected will not be directly identifiable and DoubleClick will not share the information with third parties. You can disable the DoubleClick cookie at any time by using the DoubleClick opt-out cookie. You can also go to http://networkadvertising.org/ to set an opt-out cookie.
Most browsers allow you to disable or allow the use of cookies. You can also delete cookies from your computer if your browser allows it. If you disable cookies, you may not be able to use certain parts of our services and the rejection cookie may need to be reinstalled.
11. Exercise of Rights of Access, Rectification, Cancellation and Opposition (ARCO Rights)
As the holder, you have the right to access your Personal Data in our Personal Data Bank. Likewise, you have the right to know the characteristics of the treatment of your data, rectify them if they are inaccurate or incomplete, request their elimination or cancellation when the Personal Data collected are no longer necessary or relevant for the purposes previously informed or oppose their processing for specific purposes.
To exercise these rights and others that the Personal Data Protection Regulations recognize, you may contact our offices located at Avenida Javier Prado Oeste No. 4200, Jockey Plaza Shopping Center Administrative Offices, Santiago de Surco district, and submit the application form corresponding to the right you want to exercise: Access, Rectification, Cancellation or Opposition and you must attach a copy of your identity card or equivalent document if you are a foreigner. In the case of legal representatives, the title accrediting such representation must also be submitted.
Such request must contain the requirements of the Regulation of Law No. 29733: names and surnames, e-mail address to receive the response, specific request and supporting documents, copy of national identity card or other document that accredits powers of representation, in the case of the holder representative of the personal data, date and signature of the applicant.
The exercise of rights is free of charge and we will reply to the request within the appropriate legal period. If you consider that you have not been properly attended or the request has been denied without any justification, you can file a complaint with the National Authority for the Personal Data Protection.
In some cases, especially if you want us to delete your personal data or stop processing it, we may no longer be able to provide you with services or allow access to our digital tools. Please note that it may be necessary for us to identify and ask you for additional information to fulfill your request. In addition, note that relevant regulations may include restrictions and other provisions relating to your rights.
12. Personal data storage time
The Personal Data provided will be kept for as long as the purpose for which they were provided remains in force, unless there is a request for cancellation by you, except where it may require any liability arising from the business relationship or legal obligations to retain documents and information, as well as for historical, statistical or scientific reasons when using a procedure of dissociation or anonymization.
13. Additional information
Managed by Personal Data Banks, approved by Directorial Resolution No. 0192013-JUS/DGPDP of the National Authority for the Personal Data Protection (ANPDP).
We also confirm that we respect the principles of legality, consent, purpose, proportionality, quality, disposition of an appeal, and proper level of protection set out in the Personal Data Protection Regulations.
Lima, September 2019.