Privacy Policy

Introduction

In TPC GROUP CONSULTING S.A.C.  (hereinafter “TPC GROUP“), we ensure maximum confidentiality and protection of the customers personal data who enter our website, located at the following e-mail address: https://tpcgroup-int.com.

This document describes the “Privacy Policy” that regulates the personal data processing provided by customers.

Owner: TPC GROUP CONSULTING S.A.C.

Single Taxpayer Registration: N° 20545452406.

Registration data: Registry of Legal Entities of Lima, electronic item N° 12743846.

Address: Av Manuel Olguin 335 Of 505, Edificio Link Tower, Surco, Lima Perú.

Contact: contacto@tpcgroup-int.com

Scope

This Policy applies to all personal data processing by TPC GROUP and to those persons or companies to whom TPC GROUP entrusts the processing of personal data for which it is responsible.

Target

The purpose of this Policy is to inform the public of TPC GROUP‘s commitment to personal data protection, the processing performed under the guidelines, the purpose of the operations, as well as the procedures for the owners of such data may exercise their rights of access, rectification, cancellation, and opposition provided in the Regulations of the Personal Data Protection.

Legislation

This policy is regulated by the Peruvian legislation and particularly by:

• Law N° 29733, Personal Data Protection Law and its amendments.
• Supreme Decree N°. 003-2013-JUS, which approves the Regulations of Law N°. 29733 and its amendments.
• Information Security Directive, approved by Directorial Resolution No. 019-2013-JUS/DGPDP.

According to Law N. 29733 – Law of the Personal Data Protection and its Regulation approved by Supreme Decree N. 003-2013-JUS, personal data is understood as whether numerical, alphabetical, graphic, photographic, acoustic, personal habits, or any other type of information concerning a natural person who identifies him/her or makes him/her identifiable through reasonably means.

Likewise, personal data processing is understood as any operation or technical procedure, automated or not, that allows the collection, recording, organization, storage, conservation, elaboration, modification, extraction, consultation, use, blocking, suppression, communication by transfer or diffusion, or any other processing form that facilitates the access, correlation, or interconnection of personal data.

TPC GROUP develops its personal data processing policy following the guiding principles outlined in Law No. 29733 – Personal Data Protection Law and, therefore:

• Principle of legality: Personal data processing is done in accordance with the set forth by the law, being prohibited the personal data collected by fraudulent, faithless, or unlawful means. 
• Principle of consent: For personal data processing, the consent of the owner must be obtained. 
• Principle of purpose: Personal data must be collected for a specific, explicit, and lawful purpose, and its processing must not be extended to a different purpose than that for which it was collected. 
• Principle of proportionality: Personal data processing must be accurate, relevant, and not excessive to the purpose for which they were collected. 
• Principle of Quality: The personal data to be processed must be truthful, accurate, and, as far as possible, updated, necessary, relevant, and appropriate concerning the purpose for which they were collected. 
• Principle of Security: The owner of the personal data bank and the person in charge of its processing must adopt the necessary technical, organizational, and legal measures to guarantee the security of the personal data. 
• Principle of availability means: The owner of personal data must have the necessary administrative or jurisdictional means to claim and enforce their rights when these are violated by the processing of their personal data. 
• Principle of an adequate level of protection: For the transborder flow of personal data, a sufficient level of protection must be guaranteed for the personal data to be processed or, at least, comparable to that provided by the Personal Data Protection Law or by international standards on the matter.
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Consent to the Personal Data Processing

In compliance with the personal data protection regulations in force, (hereinafter the Law), it is granted consciously and freely the consent to TPC GROUP to carry out the processing, destination, flow, and transfer, in any of its modalities, means, or supports, local or cross-border transactions, of the information, personal data, and identification that may have been provided directly or indirectly under any means or modality.

The grantor has been duly informed that the personal data that he/she consents to in this act for its processing or that eventually could have during the relations or commercial approaches have optional character. But personal identification data destined and necessary for the entering and performing of the contractual relations that he/she could sustain for which consent is not required according to the law.

The granting of the personal data made voluntarily and consciously by this document will consequently have the possibility to be processed with truthfulness, quality, and proportionality for the purposes indicated above and for the contractual relations performing obtained between the grantor and the company.

Purpose of Personal Information Processing

The purposes of the personal data processing reflected in the forms and fields by our users are found on the website, oriented to receive information related to the service provided by TPC GROUP and make inquiries, evaluations related to transfer pricing obligations, as well as manage the service supervising them.

The personal data provided by our customers will be stored in the “CUSTOMER” databases that are part of the TPC GROUP information system and will be processed to carry out the purposes set out above.

The databases containing personal data have been registered in the Data Protection Register of the Personal Data Protection Authority.

The personal data provided by our customers may be known and handled by TPC GROUP personnel who need to know such information to send it or answer the requests of our customers and transfer the data and information collected to related companies, subsidiaries, branches, or economic group of TPC GROUP to respond to requests for information made by the user. These personal data will be processed truthfully and lawfully and will not be used for other purposes incompatible with those specified.

In addition, you are informed for declaring your consent that we transfer your data to the company BLUECARI who provides us with their CRM (Customer Relationship Management) for marketing and customer profiling.

Mandatory Personal Data and Consequences of Not Providing the Data or Refusal.

The following personal data must be provided to us mandatorily according to this privacy policy: name and surname, e-mail address, telephone, company, and country.

We will not use sensitive data.

Addressees

Public Administration is required in accordance with the legislation in force.

Information is also transferred with the following companies:

• For Digital CRM service, BLUECARIBU company addressed at # 118-30 Carrera 19 Office 601, provides the data management service through CMR service.
• You can get more information if in doubt at https://irp-cdn.multiscreensite.com/55d07fd3/files/uploaded/BLUECARIBU-SAS_POLITICA-TRATAMIENTO-DE-DATOS-PERSONALES.pdf.

Transfer

Data is transferred to respond to users’ requests to the following companies:

Term of Personal Data Processing

The personal data processed by TPC GROUP will be stored for as long as necessary to comply with the purposes provided for in this Policy. Thereafter the data will be kept for promotional actions until the revoking consent.

Personal Data Confidentiality

Personal data provided by customers will be treated with complete confidentiality. TPC GROUP undertakes to maintain professional secrecy with respect to them and guarantees the duty to keep them by adopting all necessary security measures.

Personal Data Security

In TPC GROUP, we have adopted the appropriate legal, organizational, and technical measures, in compliance with current regulations, to ensure the security of personal data, avoiding its alteration, loss, improper processing, or unauthorized access.

It makes available all the necessary human and technological resources for this purpose, applying them in proportion to the nature of the data stored and the risks to which they are exposed.

TPC GROUP will only process personal data stored in repositories that meet the security conditions required by the Regulations of Personal Data Protection.

Exercise of Rights

Customers who have provided their personal data to TPC GROUP may address the owner company to enforce their information rights, access, updating, inclusion, rectification, and deletion to prevent their personal data provision, to oppose the processing or, data objective processing under the terms set forth in the Peruvian legislation in force.

Customers may contact us to apply them through any accrediting means to send and receive the request to the physical address or e-mail address (contacto@tpcgroup-int.com), for such purposes by the company with the “Personal Data Protection” reference specifying their data, proving their identity and the reasons for their request.

Minors

In TPC GROUP, we understand the importance of protecting the personal data of minors, being processed following the provisions of articles 27° and 28° of the Regulation of the Law on Personal Data Protection.  If we become aware that the personal data collected corresponds to a minor without authorization, we will take appropriate measures to delete this data as soon as possible.

Term and Modification of the Privacy Policy

TPC GROUP reserves the right to modify its Privacy Policy if there is a change in current legislation, doctrinal, jurisprudential, or business criteria. This Policy will publish new texts on its website in case of arising changes.

Updated as of 04-12-2021.