POLÍTICA DE
PRIVACIDAD web

DINET S.A. (hereinafter referred to as “DINET”), with Taxpayer Identification Number (RUC) 20427919111, domiciled at Jr. Doménico Morelli 110, Interior 601, 6th Floor, La Rambla Shopping Center, San Borja, makes its Privacy Policy (hereinafter “THE POLICY”) available to visitors of the website https://dinet.com.pe/, i.e., job applicants, suppliers (natural persons), clients (natural persons), and employees (hereinafter, “Web Users”), in accordance with Law No. 29733, the Personal Data Protection Law, its Regulations approved by Supreme Decree No. 016-2024-JUS, and its supplementary and related provisions.

Below are the types of personal data we collect, the purposes for which they are processed, the data processors, the retention period in our personal data banks, the security measures implemented, and the procedures for Web Users to exercise their rights as personal data holders.

1. What personal data do we collect?

Through our website, DINET collects from Web Users their first and last names, National Identity Document number, Foreigner ID number or equivalent, mobile phone number, home address, email address, and username and password for the DINET website. For employees and job applicants, additional sensitive data (related to health) may be collected. This information is stored in our personal data bank called “Web Users” for a maximum period of five (5) years.

2. How do we protect your personal data?

DINET has adopted the necessary technical, legal, and organizational measures established by the applicable Personal Data Protection regulations in the Republic of Peru to ensure the security and proper processing of Web Users' personal data, as well as to prevent improper handling, accidental loss, destruction, or unauthorized access by third parties. DINET informs that the personal data of Web Users will not be sold, transferred, or shared without their authorization, and especially not for purposes other than those described below. However, no system is entirely secure or immune to all forms of attack, so it is not possible to completely prevent the loss, misuse, alteration, unauthorized access, or theft of personal data or confidential information.

3. What are the purposes for using your personal data?

The personal data provided by Web Users through the web platform will be used for the following purposes, as applicable:

If Web Users are clients (natural persons):

  • Provide services and offer products to clients.
  • Maintain efficient and ongoing communication with clients.
  • Process and ship client orders.
  • Fulfill obligations undertaken by DINET with clients upon product purchase.
  • Manage the delivery of placed orders.
  • Maintain a client registry or history.
  • Send information regarding products and/or services offered by DINET, conduct surveys, statistical analysis, and market trend studies.
  • Conduct internal or external audit processes related to DINET’s business operations.
  • Manage goods and services provided by third parties for the proper development of DINET’s commercial activities.
  • Respond to inquiries, requests, complaints, and claims made by clients to regulatory bodies and competent authorities, as required by applicable law.
  • Transfer collected information to various DINET departments and/or its affiliated companies, when necessary to fulfill contractual obligations or support operational needs.
  • Use the different services available on the DINET website.
  • Evaluate, monitor, and address the commercial relationship needs between DINET and its clients.

If Web Users are suppliers (natural persons)

  • Maintain efficient and ongoing communication with suppliers.
  • Transfer collected information to different departments within DINET and/or its affiliates, as necessary to fulfill contractual obligations or for operational purposes.
  • Evaluate, monitor, and address the commercial relationship needs between DINET and its suppliers.

If Web Users are job applicants:

  • Collect and manage applicant information for recruitment and selection purposes.

If Web Users are employees:

  • Create and analyze statistical data, which may be shared with third parties.
  • Evaluate, monitor, and address commercial relationship needs with clients, suppliers, or any interested third party.
  • Monitor employee symptoms and control the spread of COVID-19 within DINET.
  • Transfer this information to public agencies and competent authorities, as required by applicable law.
  • Transfer this information to various DINET departments when necessary to fulfill contractual obligations or operational requirements.
  • Perform any similar activity necessary to develop the contractual employment relationship with DINET.

4. Who can access your personal data?

To fulfill the aforementioned purposes, DINET may transfer and outsource the processing of Web Users’ personal data to third parties located within or outside of the national territory. In such cases, DINET ensures that the processing is limited to the authorized purposes, remains confidential, and follows the applicable security measures established under Peruvian Personal Data Protection regulations.

The third-party recipients or processors who may carry out the processing of personal data are the following:

National data transfers may include the following third parties:

  • Aeropuertos del Perú S.A.
  • Inmobiliaria Koricancha S.A.
  • Talma Servicios Aeroportuarios S.A.
  • Sandoval S.A.C.
  • Ordon S.A.C.
  • Telefónica del Perú S.A.A.

International data transfers may include the following third parties:

  • GoDaddy (United States of America)
  • Prodigibid S.A. de C.V. (Mexico)
  • Computrabajo Perú S.A.C (Peru, Mexico, Colombia, Brazil, Chile, Argentina, Spain)
  • Telefónica del Perú / Microsoft Azure (Peru and United States)
  • HubSpot, Inc. (United States)
  • KPMG (Argentina)

DINET’s website is hosted on a server located at 14455 N. Hayden Rd., Suite 219, Scottsdale, Arizona 85260, USA.

This information will be updated in THE POLICY as necessary so that it is available to users whenever they wish to verify the list of third parties.

5. How can you exercise your rights regarding your personal data?

As data holders, Web Users have the right to access their personal data held by DINET; to know the characteristics of their processing; to rectify them if they are inaccurate or incomplete; to request their deletion or cancellation if considered unnecessary for the stated purposes; or to object to their processing for specific uses.

Web Users may revoke their express consent at any time and may also limit the use or disclosure of their personal data.

DINET thus acknowledges and guarantees the right to information and the rights of access, rectification, cancellation, and opposition (commonly known as “ARCO” rights), as well as the rights to information and data portability (collectively, the "Personal Data Protection Rights"). Requests to exercise these rights must be sent to the following email:misdatospersonales@dinet.com.pein accordance with the requirements outlined in Article 64 of the Regulations.

Each request must contain at least the following:

1. Full name of the data holder. 2. Type and number of identity document. 3. If submitted by a legal representative, the same data for the representative and a copy of the document proving legal representation. 4. A clear and specific description of the personal data involved and the right being exercised. 5. Supporting documents or those that help locate the personal data. 6. Email address or physical address to which DINET should send its responses. 7. Date and signature.

The request must indicate whether responses should be sent to the provided email or physical address.

The data holder must present a copy of their national identity document or equivalent. If the request is submitted by a legal representative, they must also attach a copy of their identity document and the document proving their representation.

6. What are the response times for personal data protection rights requests?

The response period for requests regarding the right to information is eight (8) business days, and for requests concerning the rights of rectification, cancellation, and objection, the response period is ten (10) business days. Requests related to the rights of access and data portability have a response period of twenty (20) business days. These deadlines may be extended only once and for an equal period, provided that the circumstances justify it. DINET is obligated to communicate such an extension decision, including justification, to the email address provided by the personal data owner. Said extension and its justification must be communicated to the data subject or their legal representative within the period intended to be extended.

The cancellation of personal data will not proceed when such data must be retained by DINET due to historical, statistical, or scientific reasons, in accordance with applicable regulations, due to contractual relationships with the data owner that justify its processing, or by order of the competent authority.

If the right to information, data portability, and/or the ARCO rights are not addressed within the established timeframe or are denied, you may file a complaint before the National Authority for the Protection of Personal Data of the Republic of Peru, by going to the service desk of the Ministry of Justice and Human Rights located at Calle Scipión Llona No. 350, Miraflores, Lima, or, if applicable, before the competent Judicial Authority for purposes related to a habeas data action.

The terms and conditions governing DINET’s website and all relationships that may arise from it are protected under Peruvian law. Any dispute that may arise from accessing or using this website shall be submitted to the competent Peruvian administrative authorities, as applicable, and to the jurisdiction of the judges and courts of the Judicial District of Lima – Cercado (Republic of Peru).

7. Who is the Personal Data Officer?

DINET, in order to ensure compliance with Article 37 of the Regulation of the Personal Data Protection Law, has implemented the role of Personal Data Officer. This designated person is responsible for verifying, advising, and implementing compliance with the legal framework for personal data protection at DINET.

DINET makes available to the personal data holders the contact information of the Personal Data Officer, in case they need to make any communication regarding personal data protection:

  • Name: Heidi Tucto
  • Email: heidi.tucto@dinet.com.pe
  • 8. Can this Privacy Policy be modified or updated?

    As part of the continuous improvement of our processes, DINET may modify and/or update this Privacy Policy to adapt to future regulatory changes, implement best practices, improve service quality, or communicate new options related to this document. Any change to this Privacy Policy will become effective once the updated or modified version is posted on this website. Use of this website following these changes constitutes acceptance of the updated or modified Privacy Policy. Please review these terms regularly to be aware of any changes and how they may affect you.

    Any inquiries related to THE POLICY may be directed to the email address:misdatospersonales@dinet.com.pe.