Privacy Policy

The provisions of this Privacy Policy of Grupo Carrillo Royalty S.A.C., with registered address at Av. Rivera Navarrete 395 – Office 303, San Isidro, Peru (hereinafter, “Carrillo Royalty”), are intended to inform you about the processing of personal data collected through the website at https://www.carrilloroyalty.com (hereinafter, the “WEBSITE”), and through any other channel used for the provision or acquisition of Carrillo Royalty products and/or services, as well as the rights you may exercise regarding your information. A “User” is any person who browses the WEBSITE, registers as a client and/or carries out a transaction on the WEBSITE, as well as any person who has provided personal data to Carrillo Royalty in connection with the acquisition of products and services.

At Carrillo Royalty, we care about the protection and privacy of the information you provide to us. Carrillo Royalty guarantees its confidentiality and integrity and employs high information security standards for its access and storage, in accordance with the Personal Data Protection Law – Law No. 29733 and its Regulations approved by Supreme Decree No. 003-2013-JUS (the “personal data protection regulations”).

1. How We Protect Your Information

Carrillo Royalty has implemented, directly and/or through a third party, technical information security measures consistent with standards that guarantee the confidentiality, integrity, and availability of information.

Access and storage are protected by a security architecture that includes preventive and corrective tools designed to protect information against unauthorized access attempts.

All security components are continuously updated to mitigate and correct vulnerabilities that may arise over time. Periodic assessments, monitoring, and ongoing management of the security system are also carried out.

2. Personal Data

Personal data is information relating to a natural person that identifies or makes that person identifiable, such as first name, last name, identity document, address, occupation, nationality, and marital status.

In addition to personal data, there is also sensitive data, which consists of biometric information or information relating to racial or ethnic origin, health, income, political or moral beliefs, among other matters.

3. Consent to the Processing of Personal Data

As the owner of your personal data, you may decide whether to authorize Carrillo Royalty to process it. If you do not give us your authorization, we will not be able to use it for the purposes described in Section 4.

However, you should be aware that Carrillo Royalty is legally authorized to handle information provided by clients by virtue of their contractual relationship with us, including information regarding their personal, financial, and credit status.

Likewise, by virtue of this legal authorization, we may share this information with authorities and entities authorized by law or that request it pursuant to law. This includes regulations related to the prevention of money laundering and terrorist financing, as well as other prudential regulations.

4. Processing of Your Personal Data

With your authorization, except as provided in the second paragraph of the preceding section, Carrillo Royalty, directly or through third parties, may collect, record, organize, store, retain, prepare, modify, block, delete, extract, consult, use, process, or transfer your Personal Data within or outside the national territory, in the forms permitted by law.

This includes the transfer of your Personal Data by Carrillo Royalty to its related companies, affiliates, and/or business partners.

Your Personal Data will be processed for an indefinite period, without prejudice to your right to withdraw your consent at any time.

Please note that our website may suggest links or provide access to other websites that are not part of Carrillo Royalty.

We recommend carefully reviewing the privacy policies of those websites, as they may differ from our Privacy Policy.

5. Purposes of Personal Data Processing

If you authorize the processing of your Personal Data, Carrillo Royalty may use it for the following purposes, among others:

Advertising:

To send and/or offer you, through any written, verbal, digital, or electronic means, commercial offers, advertising, and information about its products and services or those of third-party companies, whether related or unrelated (for example, companies with which we have agreements or joint projects).

Surveys:

To send you invitations and surveys to learn about your experience with the website, its products and services, customer service, and other matters in order to improve the quality of our products.

Assessing Your Creditworthiness and Ability to Pay:

Each document in which you provide your consent will specify the purposes for processing your personal data. This information will be stored in a system that analyzes your credit profile in order to provide you with better offers now or in the future.

6. Use of Cookies

This website uses cookies, which are small files stored on computers that allow us to remember our users’ browsing characteristics or preferences on our website.

This allows us to personalize access to the website during future visits, make browsing more secure, and understand users’ preferences so that we can offer information of interest to them. Users may configure their browser to accept or reject the installation of cookies or to delete them after they finish browsing our website. Carrillo Royalty is not responsible if disabling cookies prevents our website from functioning properly.

7. Rights of the Personal Data Holder

As the holder of your Personal Data, you may exercise your rights of access, cancellation, and objection before Carrillo Royalty.

For this purpose, you must identify yourself using your original identity document. If you act through a representative, the representative must present the power of attorney or other document establishing their authority. In either case, these rights may be exercised by signing the Internal Form that Carrillo Royalty will provide to you free of charge.

Access and Information:

This allows you to learn how your Personal Data is processed, including how it is used, how it is collected, the database in which it is stored, the identity of the owner of that database, and any transfers made, among other information.

Rectification:

This allows you to modify or update your Personal Data when it is inaccurate, incomplete, outdated, or false. To do so, you must specify the data you wish to have corrected or updated and attach supporting documentation.

Cancellation:

This allows you to request the total or partial deletion of your Personal Data from the Carrillo Royalty database. Please note that cancellation cannot be completed while you maintain a contractual relationship with Carrillo Royalty, when your personal data must be retained for the periods established by applicable legal provisions or contractual agreements you have signed, or when it is retained for historical, statistical, or scientific purposes.

Objection:

This allows you to object to the processing of your Personal Data on well-founded and legitimate grounds, provided that the law does not state otherwise.

8. Response Times for Exercising Your Rights

Carrillo Royalty will respond to your request to exercise the rights described above within the following time frames:

  1. Information:

    8 (eight) business days from the day following submission of the request.

  2. Access:

    20 (twenty) business days from the day following submission of the request.

  3. Rectification, cancellation, and objection:

    10 (ten) business days from the day following submission of the request.

9. Ownership of the Personal Data Bank

Carrillo Royalty owns the Personal Data Bank in which your Personal Data is stored, located at Av. Rivera Navarrete 395 – Office 303, San Isidro, Peru.

10. Amendments to the Privacy Policy

Carrillo Royalty reserves the right to amend this Privacy Policy at any time and without prior notice. Any amendment will become effective when it is published on the website.

11. Information About Personal Data Protection

For more information about personal data protection, you may visit the website of the Ministry of Justice’s General Directorate for Personal Data Protection: http://www.minjus.gob.pe/proteccion-de-datos-personales/.