Legal
Sección de documentos, normas y políticas legales relacionadas al rubro de Inteligo SAB.
At Inteligo SAB, we care about the privacy of your personal data. Therefore, we want to inform you and explain how we treat your information in accordance with our current regulations.. To that end, we have created this Privacy Policy, which details our practices for collecting and using your personal data, as well as the actions you can take in relation to them.
1. Identity and address
Inteligo Stock Brokerage Company S.A. (hereinafter, Inteligo SBA), with RUC No. 20338205261, with address at Av. Rivera Navarrete 501, 21st Floor, San Isidro, Lima, Peru.
2. Who is this Privacy Policy addressed to?
This Policy is aimed at our clients, non-clients, legal representatives, guardians or curators, as well as users who visit our website, our applications and those who have had any contact with us, including through our social networks.
3. Who must comply with this Privacy Policy?
Both our collaborators, suppliers and partners, as well as our clients and non-clients, are required to comply with the guidelines established in this Privacy Policy.
4. Regulatory framework
At Inteligo SAB, we are committed to protecting your privacy by following the security standards established by Peruvian regulations, in particular:
- Law No. . 29733, Personal Data Protection Law.
- Supreme Decree No. 003-2013-JUS, Regulation of Law No. 29733.
- . Information Security Directive, approved by Directorial Resolution No. 019-2013-JUS/DGPDP.
- Directive for Treatment . of personal data through Video Surveillance Systems, approved by Directorial Resolution No. 02-2020-JUS/ DGTAIPD.
5. When and how do we collect your data?
We collect your information in a variety of ways, whether you provide it directly to us or we collect it from you. Some examples include:
- When you contact us through our various channels, such as our offices, telephone, email, and secure zone on our website.
- When you contract and use products and services offered by Inteligo SAB.
- If you install our applications and give us permission to gather necessary information such as geolocation or data from your device.
- When you browse our website or use our applications.
- If you are a beneficiary or have an interest in a stock or non-stock transaction involving another client, such as the purchase and sale of securities.
- If you are a partner, administrator, lawyer, or legal representative of a company that is a client or has any other relationship with Inteligo SAB.
- We may also obtain your data from public and lawful sources.
- When you contact us through our various channels, such as our offices, telephone, email, and secure zone on our website.
- When you contract and use products and services offered by Inteligo SAB.
- If you install our applications and give us permission to gather necessary information such as geolocation or data from your device.
- When you browse our website or use our applications.
- If you are a beneficiary or have an interest in a stock or non-stock transaction involving another client, such as the purchase and sale of securities.
- If you are a partner, administrator, lawyer, or legal representative of a company that is a client or has any other relationship with Inteligo SAB.
- We may also obtain your data from public and lawful sources.
6. Mandatory Personal Data
In order to carry out the necessary purposes described in this Privacy Policy and depending on the type of service or product to be contracted, it is mandatory for you to provide us with the following personal data:
Identifying information: Names, surnames, ID/Passport/RUC, home address, telephone, email, voice, photographic or video image – regardless of the medium (video surveillance or video call), signature, and electronic signature.
Personal characteristics data: Marital status, date of birth, nationality, gender, age, occupation.
Economic and financial data: Bank information, credits, loans, guarantees, credit history, tax information, insurance, credit cards, assets, mortgages, benefits received from social programs, and debts.
Social data: Housing characteristics.
Sensitive data: Economic income and biometric data (such as fingerprints and facial recognition). We would like to clarify that the processing of this sensitive data is necessary for the preparation, celebration, and execution of the contractual relationship, as its purpose is to evaluate credit risks (economic income) and may also be used to validate identity and document the expression of will (biometric data).
Personal data of minors: At Inteligo SAB, we understand the importance of protecting the personal data of minors. Therefore, we will only use the personal data of minors with the prior consent of their parents, guardians, or legal representatives, in situations where the products and services involve minors. If a minor enters their personal data through our channels, they must request the corresponding permission from their parents, guardians, or legal representatives, who will be held responsible for all acts carried out by minors under their care.
Device data: Device identifier (such as IMEI or UDID, depending on the device's system version).
Network data and service usage: IP address, IMSI, registration log, login/logout, and usage activities. Inteligo SAB will collect device and network data and service usage when the client operates through our digital channels, such as the
Identifying information: Names, surnames, ID/Passport/RUC, home address, telephone, email, voice, photographic or video image – regardless of the medium (video surveillance or video call), signature, and electronic signature.
Personal characteristics data: Marital status, date of birth, nationality, gender, age, occupation.
Economic and financial data: Bank information, credits, loans, guarantees, credit history, tax information, insurance, credit cards, assets, mortgages, benefits received from social programs, and debts.
Social data: Housing characteristics.
Sensitive data: Economic income and biometric data (such as fingerprints and facial recognition). We would like to clarify that the processing of this sensitive data is necessary for the preparation, celebration, and execution of the contractual relationship, as its purpose is to evaluate credit risks (economic income) and may also be used to validate identity and document the expression of will (biometric data).
Personal data of minors: At Inteligo SAB, we understand the importance of protecting the personal data of minors. Therefore, we will only use the personal data of minors with the prior consent of their parents, guardians, or legal representatives, in situations where the products and services involve minors. If a minor enters their personal data through our channels, they must request the corresponding permission from their parents, guardians, or legal representatives, who will be held responsible for all acts carried out by minors under their care.
Device data: Device identifier (such as IMEI or UDID, depending on the device's system version).
Network data and service usage: IP address, IMSI, registration log, login/logout, and usage activities. Inteligo SAB will collect device and network data and service usage when the client operates through our digital channels, such as the
7. What do we use your personal data for?
a) Finalidades Necesarias
En Inteligo SAB, utilizamos tus datos personales para diversas finalidades necesarias relacionadas con el servicio que ofrecemos. A continuación te explicamos cómo utilizamos tus datos:
Respecto del Banco de Datos denominado “Clientes” y/o “Potenciales Clientes”:
Respecto del Banco de Datos denominado “Videovigilancia”:
Para obtener mayor información sobre el tratamiento de los datos personales (imágenes) captados mediante los sistemas de videovigilancia, te invitamos a revisar la “Hoja Informativa sobre el tratamiento de datos personales mediante Sistemas de Videovigilancia” adjunta como Anexo III.
Respecto del Banco de Datos denominado “Datos de audios de llamadas telefónicas”:
b) Finalidades Opcionales (Requiere consentimiento expreso)
3 Financiera Oh! S.A. (Av. Aviación 2405, piso 9, San Borja, Lima, Perú)
En Inteligo SAB, utilizamos tus datos personales para diversas finalidades necesarias relacionadas con el servicio que ofrecemos. A continuación te explicamos cómo utilizamos tus datos:
Respecto del Banco de Datos denominado “Clientes” y/o “Potenciales Clientes”:
- Enviarte, a través de cualquier medio de comunicación (teléfono, correo electrónico, SMS o medios similares), información, cotizaciones y/o propuestas de los productos y/o servicios ofrecidos por Inteligo SAB, solicitados previamente por el cliente y/o potencial cliente.
- Formalización y gestión de los productos y/o servicios a ser contratados con Inteligo SAB. Este aspecto incluye a las evaluaciones financieras y/o de riesgos, procesamiento y actualización de datos, formalizaciones contractuales, cobro de deudas, gestión de operaciones financieras y remisión de correspondencia.
- Enviar los estados de cuenta y/o información relacionada con los productos y/o servicios que quieran ser o hayan sido contratados con Inteligo SAB.
- Evaluar los riesgos de tu crédito (para casos de mutuo de dinero) y llevar a cabo la cobranza de deudas.
- Atender y gestionar los reclamos, requerimientos, quejas, consultas y solicitudes que realice a través de los canales autorizados por Inteligo SAB.
- Prevenir o detectar fraudes o actividades delictivas o para gestionar y resolver cualquier pérdida real o potencial en relación con un delito o fraude.
- Prevenir o detectar actividades relacionadas a delitos como lavado de activos, financiamiento del terrorismo, corrupción o para gestionar cualquier información que soliciten las entidades legitimadas y reguladores nacionales e internacionales.
- Compartir los datos personales con empresas proveedoras para cumplir con las prestaciones a cargo de Inteligo SAB
- Alojar, almacenar y procesar tu información en empresas especializadas, nacionales o internacionales, que brinden servicios basado en infraestructura en la nube.
- Garantizar la seguridad de las instalaciones y de las personas que se encuentran en ellas mediante cámaras de videovigilancia.
- Realizar análisis estadístico para la elaboración de estrategias comerciales, de manera anonimizada o disociada.
- Cumplir con nuestras obligaciones legales.
Respecto del Banco de Datos denominado “Videovigilancia”:
- Garantizar la seguridad de nuestras sedes (instalaciones internas), así como de las personas que se encuentran en ellas, mediante las cámaras de videovigilancia.
- Verificar el cumplimiento de obligaciones y deberes laborales de nuestros colaboradores durante su atención.
Para obtener mayor información sobre el tratamiento de los datos personales (imágenes) captados mediante los sistemas de videovigilancia, te invitamos a revisar la “Hoja Informativa sobre el tratamiento de datos personales mediante Sistemas de Videovigilancia” adjunta como Anexo III.
Respecto del Banco de Datos denominado “Datos de audios de llamadas telefónicas”:
- Verificar y validar la identidad del usuario.
- Brindar asesoría de inversiones para revisar estándares de atención y detalle de órdenes de clientes.
- ocumentar las órdenes de clientes para fines regulatorios.
- Atender y gestionar reclamos y consultas.
b) Finalidades Opcionales (Requiere consentimiento expreso)
- De manera opcional, tus datos personales podrán ser utilizados por Inteligo SAB, previo consentimiento expreso por tu parte para las siguientes finalidades: Como sabes, en Inteligo SAB tratamos de brindarte la mejor asesoría financiera y de inversiones. Para ello analizamos tu posición y/o los productos que posees, así como los intereses que tengas, y te sugerimos alterativas que pueden ser de tu interés, dado tu perfil de riesgo y objetivos de inversión. Para esto necesitamos nos permitas presentarte soluciones financieras como depósitos de ahorro, productos de renta con seguro implícito, etc, que permitan ajustar nuestra propuesta a tus necesidades concretas. Para esto Inteligo SAB podrá compartir tus Datos Personales con IFS - Intercorp Financial Services Inc. y/o sus principales subsidiarias<sup>2</sup> y/o Financiera Oh! S.A.<sup>3</sup> para asegurar que te estamos brindando el mejor servicio posible. Te garantizamos que todo se realizará bajo altos estándares de confidencialidad y seguridad de la información.
- Compartir información publicitaria de los productos y/o servicios de IFS - Intercorp Financial Services Inc.1 y/o sus principales subsidiarias y/o Financiera Oh! S.A. o éstas envíen - de forma directa- ofertas comerciales, publicidad e información en general de los productos y/o servicios que estas ofrecen.
1 Intercorp Financial Services Inc. – IFS (Calles 50 Y 74 San Francisco Edificio P.H. 909, Piso 16, Ciudad de Panamá, República de Panamá).
2 Las principales subsidiarias son: Banco Internacional del Perú S.A.A. – Interbank (Jr. Carlos Villarán 140, La Victoria, Lima, Perú), Interseguro Compañía de Seguros S.A. (Av. Javier Prado Este 492, oficina 2601, San Isidro, Lima, Perú), Interfondos S.A. SAF (Jr. Carlos Villarán 140, piso 6, La Victoria, Lima, Perú), Inteligo Perú Holdings S.A.C. (Av. Rivera Navarrete 501, piso 17, San Isidro) e Inteligo Bank Ltd. (Seventeen Shop Building, Primer Piso, Collins Avenue & Fourth Terrace, Centreville, PO Box N-3732, Nassau, Las Bahamas).
3 Financiera Oh! S.A. (Av. Aviación 2405, piso 9, San Borja, Lima, Perú)
8. Consequence of providing personal data or refusing to do so
If you choose not to provide us with your mandatory personal data for the necessary purposes, it’s important to consider that we will not be able to provide you with the service or product you wish to hire or have already hired.
However, we want to assure you that you have the option and freedom to give us your consent and authorization to use your personal data for additional commercial purposes, different from the necessary ones.
However, we want to assure you that you have the option and freedom to give us your consent and authorization to use your personal data for additional commercial purposes, different from the necessary ones.
9. Who do we share your personal data with?
9. Who do we share your personal data with?
a) Necessary Recipients
In order to fulfill the necessary purposes and, if applicable, the optional ones described above, Inteligo SAB may process your data directly or through third parties (providers), either at a national or international level. These third parties are committed to providing the service according to our data protection guidelines and the applicable Peruvian regulations.
Some of the necessary recipients with whom we may share your data are:
National Authorities and Credit Information Bureaus
Hosting Providers.
Messenger service providers.
Contact center service providers.
Debt collection service providers.
Consulting service providers.
Advertising providers.
Technology providers.
Document custody service providers.
You can find more details about our necessary recipients in the accompanying Annex II, labeled "List of Providers". If necessary, this list will be promptly updated by Inteligo SAB through this same medium.
Furthermore, we want to reaffirm our commitment not to share your personal data without your authorization, except in the following cases:
Requests for information made by public authorities in the exercise of their functions and within the scope of their competencies.
Requests for information covered by court orders.
Requests for information in accordance with applicable legal provisions (such as credit information bureaus).
b) Optional Recipients
Additionally, if you have given your prior consent, we may transfer your personal data to companies linked to Inteligo SAB mentioned in Annex I, both within and outside of Peruvian territory, in order to carry out activities related to the optional purposes.
c) Transfer abroad
Although our headquarters are located in Peru, we have service providers and linked companies with a presence abroad. In these cases, some activities or processing of personal data may take place outside of Peru. (In the lists described in Annexes I and II, you can find the country of these companies.)
We want to assure you that we have implemented the necessary procedures to ensure that these companies also comply with personal data protection rules and the applicable legislation in the country where the
a) Necessary Recipients
In order to fulfill the necessary purposes and, if applicable, the optional ones described above, Inteligo SAB may process your data directly or through third parties (providers), either at a national or international level. These third parties are committed to providing the service according to our data protection guidelines and the applicable Peruvian regulations.
Some of the necessary recipients with whom we may share your data are:
National Authorities and Credit Information Bureaus
Hosting Providers.
Messenger service providers.
Contact center service providers.
Debt collection service providers.
Consulting service providers.
Advertising providers.
Technology providers.
Document custody service providers.
You can find more details about our necessary recipients in the accompanying Annex II, labeled "List of Providers". If necessary, this list will be promptly updated by Inteligo SAB through this same medium.
Furthermore, we want to reaffirm our commitment not to share your personal data without your authorization, except in the following cases:
Requests for information made by public authorities in the exercise of their functions and within the scope of their competencies.
Requests for information covered by court orders.
Requests for information in accordance with applicable legal provisions (such as credit information bureaus).
b) Optional Recipients
Additionally, if you have given your prior consent, we may transfer your personal data to companies linked to Inteligo SAB mentioned in Annex I, both within and outside of Peruvian territory, in order to carry out activities related to the optional purposes.
c) Transfer abroad
Although our headquarters are located in Peru, we have service providers and linked companies with a presence abroad. In these cases, some activities or processing of personal data may take place outside of Peru. (In the lists described in Annexes I and II, you can find the country of these companies.)
We want to assure you that we have implemented the necessary procedures to ensure that these companies also comply with personal data protection rules and the applicable legislation in the country where the
10. How do we protect your data?
At Inteligo SAB, we constantly strive to offer you the best service, and in order to achieve this, we are committed to continuously implementing new technologies and processes that strengthen the protection of your personal data. In this sense, we have established and strictly follow the following technical, legal, and organizational security measures:
We adopt appropriate security measures to protect your personal information against unauthorized access, alteration, disclosure, loss, or destruction, following the parameters established by applicable data protection regulations.
Our staff who have access to your personal information are subject to the duty of confidentiality and the obligations established by applicable data protection regulations, and any breach may result in disciplinary action, including dismissal and payment of compensation, if applicable, for unauthorized use or disclosure of your personal data.
Likewise, our partners and suppliers who have access to your information are subject to the duty of confidentiality through the signing of confidentiality agreements or clauses, and any breach may lead to automatic termination of the service contract, disqualification, legal action, and assumption of costs and penalties.
We require our suppliers and affiliated companies to have a level of personal data protection that is comparable to that provided by our regulations or international standards in this matter. They are required to adopt technical, organizational, and legal measures to ensure their security and prevent their alteration, loss, processing, or unauthorized access.
We implement adequate measures to ensure the security, permanent confidentiality, integrity, availability, and resilience of processing systems and services.
We provide specific training to our staff on data protection and regularly update their knowledge as part of our mandatory training programs.
We strive to ensure that, when processing your data outside of Peru, the level of protection guaranteed by our regulations is not compromised.
We promptly report any security incidents and take appropriate corrective measures.
Although we cannot guarantee the total invulnerability of the internet, we work to protect your data from unauthorized access by third parties.
We adopt appropriate security measures to protect your personal information against unauthorized access, alteration, disclosure, loss, or destruction, following the parameters established by applicable data protection regulations.
Our staff who have access to your personal information are subject to the duty of confidentiality and the obligations established by applicable data protection regulations, and any breach may result in disciplinary action, including dismissal and payment of compensation, if applicable, for unauthorized use or disclosure of your personal data.
Likewise, our partners and suppliers who have access to your information are subject to the duty of confidentiality through the signing of confidentiality agreements or clauses, and any breach may lead to automatic termination of the service contract, disqualification, legal action, and assumption of costs and penalties.
We require our suppliers and affiliated companies to have a level of personal data protection that is comparable to that provided by our regulations or international standards in this matter. They are required to adopt technical, organizational, and legal measures to ensure their security and prevent their alteration, loss, processing, or unauthorized access.
We implement adequate measures to ensure the security, permanent confidentiality, integrity, availability, and resilience of processing systems and services.
We provide specific training to our staff on data protection and regularly update their knowledge as part of our mandatory training programs.
We strive to ensure that, when processing your data outside of Peru, the level of protection guaranteed by our regulations is not compromised.
We promptly report any security incidents and take appropriate corrective measures.
Although we cannot guarantee the total invulnerability of the internet, we work to protect your data from unauthorized access by third parties.
11. Database (if the content is not a word or phrase, output the original content)
At Inteligo SAB, we want to make sure that you understand how we handle your personal data. Below, we explain in which databases we store your information:
Personal data of clients and potential clients will be kept in the personal data database called "Clients" or "Potential Clients" registered in the National Register of Personal Data Protection with codes 11350 and 82156.
Images recorded through our video surveillance system will be stored in the personal data database called "Video Surveillance" registered in the National Register of Personal Data Protection with code 11353.
Personal data from phone calls will be stored in the personal data database called "Call Audio Data" registered in the National Register of Personal Data Protection with code 11352.
Personal data of clients and potential clients will be kept in the personal data database called "Clients" or "Potential Clients" registered in the National Register of Personal Data Protection with codes 11350 and 82156.
Images recorded through our video surveillance system will be stored in the personal data database called "Video Surveillance" registered in the National Register of Personal Data Protection with code 11353.
Personal data from phone calls will be stored in the personal data database called "Call Audio Data" registered in the National Register of Personal Data Protection with code 11352.
12. Storage period
a) Personal data registered in the database "Customers" in accordance with Resolution SMV No. 034-2015-SMV-01, Regulation of Intermediaries, will be retained for a period of not less than ten (10) years after termination of the contractual relationship, or while we have your consent for optional treatments.
b) Images captured by the video surveillance system in our offices and stored in the database "Video surveillance" will be retained for a maximum period of sixty (60) days, unless otherwise required by law. For more information on the processing of personal data (images) captured by video surveillance systems, we invite you to review the "Information Sheet on the Processing of Personal Data through Video Surveillance Systems" attached as Annex III.
c) Personal data registered in the database "Data of telephone call recordings" will be stored for five (5) years, in accordance with the Regulation of Intermediaries.
b) Images captured by the video surveillance system in our offices and stored in the database "Video surveillance" will be retained for a maximum period of sixty (60) days, unless otherwise required by law. For more information on the processing of personal data (images) captured by video surveillance systems, we invite you to review the "Information Sheet on the Processing of Personal Data through Video Surveillance Systems" attached as Annex III.
c) Personal data registered in the database "Data of telephone call recordings" will be stored for five (5) years, in accordance with the Regulation of Intermediaries.
13. Exercise of the ARCO rights
You can exercise your rights of access, rectification, cancellation and opposition of your personal data; as well as revoke your consent for optional purposes by submitting your requests at any of the Inteligo SAB offices indicated on our website www.inteligosab.com
Please note that the right of rectification does not apply to images captured through our video surveillance systems. To obtain more information, please refer to the document "Information Sheet on the Processing of Personal Data through Video Surveillance Systems" attached as Annex III.
In order to provide you with appropriate attention in the exercise of your ARCO rights, we have prepared a "Manual for the Attention of ARCO Rights" that details the process step by step. You can consult it in Annex IV attached.
If you believe that you have not been attended to in the exercise of your rights, you may file a complaint with the National Authority for the Protection of Personal Data, by addressing the Reception Desk of the Ministry of Justice and Human Rights: Scipión Llona Street 350, Miraflores, Lima, Peru by filling out the form published at the following link: https://www.minjus.gob.pe/wpcontent/uploads/2018/12/FORMULARIO-DEPROCEDIMIENTO-TRILATERAL-DE-TUTELA.pdf
Please note that the right of rectification does not apply to images captured through our video surveillance systems. To obtain more information, please refer to the document "Information Sheet on the Processing of Personal Data through Video Surveillance Systems" attached as Annex III.
In order to provide you with appropriate attention in the exercise of your ARCO rights, we have prepared a "Manual for the Attention of ARCO Rights" that details the process step by step. You can consult it in Annex IV attached.
If you believe that you have not been attended to in the exercise of your rights, you may file a complaint with the National Authority for the Protection of Personal Data, by addressing the Reception Desk of the Ministry of Justice and Human Rights: Scipión Llona Street 350, Miraflores, Lima, Peru by filling out the form published at the following link: https://www.minjus.gob.pe/wpcontent/uploads/2018/12/FORMULARIO-DEPROCEDIMIENTO-TRILATERAL-DE-TUTELA.pdf
14. Collaborators and Suppliers
At Inteligo SAB we take the treatment of data from our employees and suppliers very seriously, which is why we have implemented strict internal security measures to guarantee the confidentiality, integrity, and availability of such information. In addition, we have duly registered databases in the National Registry of Personal Data Protection (codes 11349 & 11351 ) for each of them.
On the other hand, we want to assure you that all individuals who have access to your personal information, whether internal employees or external suppliers, are subject to strict confidentiality obligations and comply with current data protection regulations. This is supported by our Codes of Ethics, which establish ethical principles and standards of conduct that all our employees and suppliers must follow. These codes seek to guarantee respect for the privacy of all individuals, considering the information accessible through our activities.
Failure to comply with these ethical principles and standards of conduct related to privacy may result in disciplinary actions against employees, which can range from a verbal warning to dismissal, depending on the seriousness of the offense. In addition, in relation to suppliers, failure to comply with security and confidentiality guidelines may result in automatic termination of the service contract, legal actions (damages and compensation), and assumption of costs by the suppliers. In addition to the disciplinary measures detailed above for employees, Inteligo SAB reserves the right to take any legal action that may be necessary, as required.
On the other hand, we want to assure you that all individuals who have access to your personal information, whether internal employees or external suppliers, are subject to strict confidentiality obligations and comply with current data protection regulations. This is supported by our Codes of Ethics, which establish ethical principles and standards of conduct that all our employees and suppliers must follow. These codes seek to guarantee respect for the privacy of all individuals, considering the information accessible through our activities.
Failure to comply with these ethical principles and standards of conduct related to privacy may result in disciplinary actions against employees, which can range from a verbal warning to dismissal, depending on the seriousness of the offense. In addition, in relation to suppliers, failure to comply with security and confidentiality guidelines may result in automatic termination of the service contract, legal actions (damages and compensation), and assumption of costs by the suppliers. In addition to the disciplinary measures detailed above for employees, Inteligo SAB reserves the right to take any legal action that may be necessary, as required.
15. Cookies Policy
Cookies are small text files generated during your internet browsing, used for authentication, security, and customization of the service.
On our channels, it is possible that we use cookies. For more information on the use of cookies on www.inteligosab.com, we invite you to consult our Cookie Policies.
On our channels, it is possible that we use cookies. For more information on the use of cookies on www.inteligosab.com, we invite you to consult our Cookie Policies.
16. Modification of the Privacy Policy
Inteligo SAB reserves the right to modify, update or complete this Privacy Policy at any time and without prior notice. Any changes or modifications to this Privacy Policy will be effective and will have effects on third parties from its publication on this website.
17. Attachments
Annex I: List of Related Companies to which Personal Data can be shared if they have
Annex III: Information Sheet on the processing of personal data through Video Surveillance Systems
1. Identity and address of the owner of the personal data bank or person in charge of processing
The owner of this database in which the personal data provided through the video surveillance system will be stored is Inteligo Sociedad Agente de Bolsa S.A. (hereinafter, “Inteligo SAB”), with address at Av. Rivera Navarrete 501, 21st floor San Isidro, Lima, Peru.
The existence of this personal data bank has been declared to the National Authority for the Protection of Personal Data, through its registration in the National Registry for the Protection of Personal Data with the name “Video Surveillance” and the code: RNPDP-PJP N°11353.
The user is informed that any processing of personal data complies with the provisions of current legislation in Peru on the matter (Law No. 29733 and its Regulations).
2. Purpose
Inteligo SAB will process your data with the purpose of guaranteeing the security of the facilities and the people in them through video surveillance cameras, as well as verifying compliance by its collaborators with their work obligations and duties.
3. Transfers and recipients
Personal data will be transferred nationally to:
The personal data provided will be kept for a maximum period of sixty (60) days.
5. EXERCISE OF THE RIGHTS OF INFORMATION, ACCESS, CANCELLATION AND OPPOSITION OF DATA
As the owner of your personal data, the user has the right to access your data in the possession of Inteligo SAB, know the characteristics of its processing, request that it be deleted or canceled when considering it unnecessary for the purposes previously stated or oppose its processing. be the cáse.
The user may direct their request to exercise their rights to the following address: Rivera Navarrete 501, 21st floor San Isidro, Lima, Peru, or to any of our offices.
In order to exercise the aforementioned rights, the user must submit, at the address previously specified, the respective request in the terms established by the Regulation of Law No. 29733 (including: name of the owner of the personal data and address or other means to receive a response, documents that prove your identity or legal representation, clear and precise description of the data with respect to which you seek to exercise your rights and other elements or documents that facilitate the location of the data).
If the user considers that they have not been assisted in the exercise of their rights, they can file a claim with the National Authority for the Protection of Personal Data, addressing the Parties Table of the Ministry of Justice and Human Rights: Calle Scipión Llona 350, Miraflores, Lima, Peru.
Inteligo SAB will be responsible for the Video Surveillance personal data bank and the personal data contained therein. In order to prevent the loss, misuse, alteration, unauthorized access and theft of personal data or confidential information provided by personal data holders, Inteligo SAB has adopted the legally required levels of security and protection of personal data, and has installed all the means and technical measures at its disposal.
Annex IV: ARCO Rights Care Manual
Legal Basis
Purpose of the Manual
This Manual is intended to inform users and the general public of the procedure that will follow the request made by any natural person who requires to exercise the rights of access, rectification, cancellation or opposition (ARCO), regarding the information of which it is the owner and that is contained in the personal data banks owned by INTELIGO SOCIEDAD AGENTE DE BOLSA S.A. (hereinafter, “Inteligo SAB”).
Legitimacy to exercise ARCO rights
The exercise of rights can be carried out:
1. By the owner of personal data;
2. Through a legal representative accredited as such; or,
3.Through a representative expressly authorized to exercise the right.
If you are the owner of the personal data or its legal representative, you must submit your request in writing, attaching a copy of your identity document (DNI, CE and other). If it is done through a legal representative or attorney-in-fact, the validity of the powers issued by Public Registries of the person exercising the representation must be attached, with an antiquity of no more than 60 days from the date of issuance of the validity of the powers, as well such as the identity document (DNI, CE and other) of the representative. This documentation must be presented at any of the Inteligo SAB offices.
We remind you that, for information security reasons, Inteligo SAB reserves the right to verify the identity of the applicant or legal representative in order to comply with the quality principle.
Reception, correction of the request and request for additional information
The requests will be received by the reception of the offices of Inteligo SAB, leaving proof of their receipt by means of the stamp of a corresponding charge. In the event that the request does not comply with the requirements mentioned above, Inteligo SAB, within a period of 5 business days from the day following receipt of the request, will formulate observations for non-compliance that cannot be resolved ex officio. The person making the request will have a maximum period of 5 business days to correct them. If the indicated period has elapsed without the correction occurring, the application will be considered not submitted.
In the event that the information provided in the request is insufficient or erroneous in such a way that it does not allow attention, Inteligo SAB may require, within 7 business days of receiving the request, additional documentation from the owner of the personal data to respond to it.
Within a period of 10 business days of receiving the request, counted from the day after receipt thereof, the owner of personal data will attach the additional documentation that he or she deems pertinent to support his or her request. Otherwise, said request will be considered not submitted.
Application processing cost
There is no cost to exercise your ARCO rights. The application and processing are free.
Response form
Inteligo SAB will respond in the manner and within the deadlines described in this Manual, which respect the provisions of the Regulations of the Personal Data Protection Law. All requests will be answered, regardless of whether or not personal data of the owner thereof appears in the personal data bank.
Inteligo SAB, in its response, will refer only to those data that have been specifically indicated in your request. Both the request by the owner of the personal data, as well as the response by Inteligo SAB, must be presented in a clear, legible, understandable and easily accessible manner.
Rights to be exercised by the Owner of Personal Data
Requests and response times
Administrative Instance – General Directorate of Personal Data Protection
If the response is totally or partially negative from Inteligo SAB and is not duly justified, the owner of the personal data has the right to appeal to the General Directorate of Personal Data Protection (DGPDP) to file a claim. in the terms established by Law, to exercise your ARCO rights.
To be assisted by the DGPDP and initiate the protection procedure by it, the owner of the personal data must, of necessity, have first appealed to Inteligo SAB and have obtained a totally or partially negative response from them within the established deadlines and indicated in this Manual, since it is an essential requirement that, in order to request protection from the DGPDP, the request has been previously submitted to the owner of the personal data bank.
- Intercorp Financial Services Inc. – IFS(Calles 50 Y 74 San Francisco Edificio P.H. 909, Piso 16, Ciudad de Panamá, República de Panamá)
- Banco Internacional del Perú S.A.A. – Interbank(Jr. Carlos Villarán 140, La Victoria, Lima, Perú),
- Interseguro Compañía de Seguros S.A.(Av. Javier Prado Este 492, oficina 2601, San Isidro, Lima, Perú)
- Interfondos S.A. SAF (Jr. Carlos Villarán 140, piso 6, La Victoria, Lima, Perú),
- Inteligo Perú Holdings S.A.C(Av. Rivera Navarrete 501, piso 17, San Isidro)
- Inteligo Bank Ltd. (Seventeen Shop Building, Primer Piso, Collins Avenue &Fourth Terrace, Centreville, PO Box N-3732, Nassau, Las Bahamas)
- Financiera Oh! S.A.(Av. Aviación 2405, piso 9, San Borja, Lima, Perú)
- G4S Perú S.A.C.: Servicios de seguridad. Perú
- Decoclean Express S.A.C.: Servicios de limpieza. Perú
- Corporación MG S.A.C.: Servicios de gestión administrativa, operativa y mantenimiento de bienes y servicios comunes de nuestras oficinas. Perú
- Seguricel S.A.C.: Servicios de de primera respuesta médica. Perú
- GRM Information Management Services S.A.C.: Servicios de de Almacenamiento y Depósito. Perú
- Banco Internacional del Perú S.A.A. – Interbank: Servicios de atención de caja preferencial. Perú
- MDP Consulting S.A.C.: Servicios de outsourcing y desarrollo. Perú
- CAVALI ICLV S.A.: Servicios de liquidación y compensación de valores. Perú
- Carlos Antonio Blas Venegas: Servicio de Atención al cliente. Perú
- Juan Pablo Jarama del Águila: Servicio de Mensajería. Perú
- Juan Carlos Castillo Ortiz: Servicio de Mensajería. Perú
- Microsoft Azure: Servicios de hosting. Estados Unidos de América
- Inteligo Perú Holdings S.A.C., servicios corporativos legales, análisis de data, administración de oficinas, entre otros. Perú
- Botto & Escobar Abogados (DLA Piper), servicios legales. Perú
Annex III: Information Sheet on the processing of personal data through Video Surveillance Systems
1. Identity and address of the owner of the personal data bank or person in charge of processing
The owner of this database in which the personal data provided through the video surveillance system will be stored is Inteligo Sociedad Agente de Bolsa S.A. (hereinafter, “Inteligo SAB”), with address at Av. Rivera Navarrete 501, 21st floor San Isidro, Lima, Peru.
The existence of this personal data bank has been declared to the National Authority for the Protection of Personal Data, through its registration in the National Registry for the Protection of Personal Data with the name “Video Surveillance” and the code: RNPDP-PJP N°11353.
The user is informed that any processing of personal data complies with the provisions of current legislation in Peru on the matter (Law No. 29733 and its Regulations).
2. Purpose
Inteligo SAB will process your data with the purpose of guaranteeing the security of the facilities and the people in them through video surveillance cameras, as well as verifying compliance by its collaborators with their work obligations and duties.
3. Transfers and recipients
Personal data will be transferred nationally to:
- G4S Perú S.A.C.: Servicios de seguridad. RUC: 20422293699
- Inteligo Perú Holdings S.A.C.: Servicios corporativos logísticos para oficinas. RUC: 20603734573
The personal data provided will be kept for a maximum period of sixty (60) days.
5. EXERCISE OF THE RIGHTS OF INFORMATION, ACCESS, CANCELLATION AND OPPOSITION OF DATA
As the owner of your personal data, the user has the right to access your data in the possession of Inteligo SAB, know the characteristics of its processing, request that it be deleted or canceled when considering it unnecessary for the purposes previously stated or oppose its processing. be the cáse.
The user may direct their request to exercise their rights to the following address: Rivera Navarrete 501, 21st floor San Isidro, Lima, Peru, or to any of our offices.
In order to exercise the aforementioned rights, the user must submit, at the address previously specified, the respective request in the terms established by the Regulation of Law No. 29733 (including: name of the owner of the personal data and address or other means to receive a response, documents that prove your identity or legal representation, clear and precise description of the data with respect to which you seek to exercise your rights and other elements or documents that facilitate the location of the data).
If the user considers that they have not been assisted in the exercise of their rights, they can file a claim with the National Authority for the Protection of Personal Data, addressing the Parties Table of the Ministry of Justice and Human Rights: Calle Scipión Llona 350, Miraflores, Lima, Peru.
Inteligo SAB will be responsible for the Video Surveillance personal data bank and the personal data contained therein. In order to prevent the loss, misuse, alteration, unauthorized access and theft of personal data or confidential information provided by personal data holders, Inteligo SAB has adopted the legally required levels of security and protection of personal data, and has installed all the means and technical measures at its disposal.
Annex IV: ARCO Rights Care Manual
Legal Basis
- Personal Data Protection Law – Law No. 29733
- Regulations of the Personal Data Protection Law – Supreme Decree No. 003-2013-JUS (Chapter I of Title IV of the Regulations, articles 47 to 59
Purpose of the Manual
This Manual is intended to inform users and the general public of the procedure that will follow the request made by any natural person who requires to exercise the rights of access, rectification, cancellation or opposition (ARCO), regarding the information of which it is the owner and that is contained in the personal data banks owned by INTELIGO SOCIEDAD AGENTE DE BOLSA S.A. (hereinafter, “Inteligo SAB”).
Legitimacy to exercise ARCO rights
The exercise of rights can be carried out:
1. By the owner of personal data;
2. Through a legal representative accredited as such; or,
3.Through a representative expressly authorized to exercise the right.
If you are the owner of the personal data or its legal representative, you must submit your request in writing, attaching a copy of your identity document (DNI, CE and other). If it is done through a legal representative or attorney-in-fact, the validity of the powers issued by Public Registries of the person exercising the representation must be attached, with an antiquity of no more than 60 days from the date of issuance of the validity of the powers, as well such as the identity document (DNI, CE and other) of the representative. This documentation must be presented at any of the Inteligo SAB offices.
We remind you that, for information security reasons, Inteligo SAB reserves the right to verify the identity of the applicant or legal representative in order to comply with the quality principle.
Reception, correction of the request and request for additional information
The requests will be received by the reception of the offices of Inteligo SAB, leaving proof of their receipt by means of the stamp of a corresponding charge. In the event that the request does not comply with the requirements mentioned above, Inteligo SAB, within a period of 5 business days from the day following receipt of the request, will formulate observations for non-compliance that cannot be resolved ex officio. The person making the request will have a maximum period of 5 business days to correct them. If the indicated period has elapsed without the correction occurring, the application will be considered not submitted.
In the event that the information provided in the request is insufficient or erroneous in such a way that it does not allow attention, Inteligo SAB may require, within 7 business days of receiving the request, additional documentation from the owner of the personal data to respond to it.
Within a period of 10 business days of receiving the request, counted from the day after receipt thereof, the owner of personal data will attach the additional documentation that he or she deems pertinent to support his or her request. Otherwise, said request will be considered not submitted.
Application processing cost
There is no cost to exercise your ARCO rights. The application and processing are free.
Response form
Inteligo SAB will respond in the manner and within the deadlines described in this Manual, which respect the provisions of the Regulations of the Personal Data Protection Law. All requests will be answered, regardless of whether or not personal data of the owner thereof appears in the personal data bank.
Inteligo SAB, in its response, will refer only to those data that have been specifically indicated in your request. Both the request by the owner of the personal data, as well as the response by Inteligo SAB, must be presented in a clear, legible, understandable and easily accessible manner.
Rights to be exercised by the Owner of Personal Data
- Right of Access: The owner of personal data has the right to obtain the information about himself that is subject to processing in the personal data bank of Inteligo SAB, the way in which it was collected, the reasons that motivated its collection and at whose request the collection was carried out, as well as the transfers made or planned to be made. This right, as understood, must be exercised if the owner does not know how his or her data is located in Inteligo SAB's personal data bank without his or her consent. If the person has given their consent, it is presumed that they have accepted and know the reasons why their data is in the Inteligo SAB personal data bank.
- Right to Rectification: It is the right of the owner of personal data to modify data that turns out to be inaccurate, erroneous or false. The rectification request must indicate which personal data it refers to, as well as the correction that must be made to them, accompanying the documentation that supports the origin of the requested rectification. You may also request, via rectification, the updating and/or incorporation of new data to the personal data bank of Inteligo SAB, accompanying the documentation that supports the origin and well-founded interest for the same.
- Derecho de Cancelación: El titular de los datos personales podrá solicitar la supresión o cancelación de sus datos personales del banco de datos personales de Inteligo SAB cuando éstos hayan dejado de ser necesarios o pertinentes para la finalidad para la cual hayan sido recopilados, cuando hubiere vencido el plazo establecido para su tratamiento, cuando ha revocado su consentimiento y en los demás casos en los que no estén siendo tratados conforme a Ley, al Reglamento y a las finalidades para las cuales prestó consentimiento.Right of Cancellation: The owner of the personal data may request the deletion or cancellation of his or her personal data from the Inteligo SAB personal data bank when they are no longer necessary or relevant for the purpose for which they were collected, when it has expired. the period established for their treatment, when they have revoked their consent and in other cases in which they are not being treated in accordance with the Law, the Regulations and the purposes for which they gave consent.
- Right to Object: The owner of the personal data has the right not to have the processing of his or her personal data carried out or to cease it, when he or she has not given his or her consent for its collection because it was taken from a source of access to the public.Even if they have given their consent, the owner of personal data has the right to oppose the processing of their data, if they prove the existence of well-founded and legitimate reasons related to a specific personal situation that justify the exercise of this right. If the opposition is justified, Inteligo SAB will proceed to cease the processing that gave rise to the opposition.
- Right to Information: The owner of the personal data has the right to obtain the information that is subject to processing about himself. The owner of personal data has the right to be informed in a detailed, simple, express, unequivocal manner and prior to its collection, about the purpose for which his or her personal data will be processed, who the recipients are or may be, the existence of the data bank in which they will be stored, as well as the identity and address of the owner and, if applicable, of the person(s) in charge of processing your personal data, the mandatory or optional nature of your responses to the proposed questionnaire, especially with regard to sensitive data, the transfer of personal data, the consequences of providing your personal data and your refusal to do so, the length of time for which your personal data is kept, and the possibility of exercising the rights that the law grants you and the means provided for this.
- Revocation: To revoke the authorization to the optional processing of personal data that you had provided at some point.
Requests and response times
- Access Request: The maximum period for the response by Inteligo SAB to the exercise of the right of access will be 20 business days counted from the day following the presentation of the request by the owner of personal data. If the request is approved, Inteligo SAB will proceed to issue the requested information to the applicant.
- Request for Rectification, Cancellation or Opposition In the cáse of the exercise of these rights, the maximum response period from Inteligo SAB will be 10 business days counted from the day following the presentation of the corresponding request.The deadlines for responding to these requests may be extended only once and for an equal period, at most, as long as the circumstances justify it. This justification for the extension of the period must be communicated to the owner of the personal data within the period intended to be extended.The total or partial negative response by Inteligo SAB to the request for any right of the owner of personal data must be duly justified.
- Request for Information: The maximum period for the response by Inteligo SAB to the exercise of the right to information will be 8 business days counted from the day following the presentation of the request by the owner of personal data.If the request is approved, Inteligo SAB will proceed to issue the requested information to the applicant.
- Revocation request:The maximum period for Inteligo SAB to respond to the revocation request is 5 business days from the day following receipt of the request.
- Extension of Deadlines The corresponding deadlines for the response or attention to ARCO rights may be extended only once, and for an equal period, at most, as long as the circumstances justify it.The justification for the extension of the period must be communicated to the owner of the personal data within the period that is intended to be extended.
Administrative Instance – General Directorate of Personal Data Protection
If the response is totally or partially negative from Inteligo SAB and is not duly justified, the owner of the personal data has the right to appeal to the General Directorate of Personal Data Protection (DGPDP) to file a claim. in the terms established by Law, to exercise your ARCO rights.
To be assisted by the DGPDP and initiate the protection procedure by it, the owner of the personal data must, of necessity, have first appealed to Inteligo SAB and have obtained a totally or partially negative response from them within the established deadlines and indicated in this Manual, since it is an essential requirement that, in order to request protection from the DGPDP, the request has been previously submitted to the owner of the personal data bank.
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