1. INTRODUCTION
Enjoy Travel Now E.I.R.L. is a tourism sector company dedicated to the sale of tourism services nationwide through service intermediation, including: ticket sales, private transfers, lodging and dining services, tour packages, and full-day activities. It is located at Calle Geranios Mza. 10 Interior 7 Residencial La Angostura, Ica. Enjoy Travel Now E.I.R.L. is obliged to comply with current Peruvian legislation regarding the protection of personal data, Law No. 29733 Personal Data Protection and its complementary provisions.
Therefore, Inversiones Enjoy Travel Now E.I.R.L. commits to:
– The collection and use of personal information.
– Ensuring the quality and security of information.
– Respecting individuals’ rights regarding information about themselves.
Enjoy Travel Now E.I.R.L. is committed to protecting, managing, and properly treating the personal data to which it has access in the regular operation of its business. This commitment includes the ongoing review and improvement of the organization’s processes to ensure adequate protection of such personal data and compliance with the guidelines established by Enjoy Travel Now E.I.R.L. for the collection and processing of personal data to ensure respect for the rights of its owners and compliance with the current regulatory framework. The Policy may be supplemented with additional procedures, regulations, and/or guidelines that develop what is established in this document as long as they are aligned with its guiding principles.
2. OBJECTIVE
This document aims to establish principles, uniform practices, and responsibilities related to the processing of personal data in which Enjoy Travel Now E.I.R.L. is involved.
3. SCOPE
This document applies to all processes of Enjoy Travel Now E.I.R.L. that will use customer personal data intended to be contained in Enjoy Travel Now E.I.R.L.’s various databases and their processing.
The Policy shall be fully known and complied with by all Enjoy Travel Now E.I.R.L. employees and suppliers. For the purpose of interpreting this Policy, the definitions contained in the Law shall apply, especially those included below.
4. DEFINITIONS
Personal data: Any information that identifies a natural person or that can identify through reasonably used means. For example, ID number, physical address, full name. Sensitive data: Personal data consisting of biometric data that can identify the owner by themselves; data related to racial and ethnic origin; economic income, political, religious, philosophical, or moral opinions or beliefs; union membership; and health-related information.
Processing of personal data: Any operation or technical procedure, automated or not, that allows the collection, recording, organization, storage, preservation, processing, modification, extraction, consultation, use, blocking, deletion, communication by transfer or dissemination, or any other form of processing that facilitates access, correlation, or interconnection of personal data. In summary, the processing of personal data regulates the ways of using and processing personal data within the organization from its entry to its deletion or retention.
Consent: Prior, free, unequivocal, and express authorization that must be given by the individual to authorize the processing of their personal data.
– Prior: It must be obtained before collection.
– Free: It must not be forced or conditioned.
– Unequivocal and express: There must be no doubt about its manifestation and must be recorded in some tangible medium.
Personal data bank: An organized set of personal data, automated or not, regardless of the medium, whether physical, magnetic, digital, optical, or others, any form or modality of its creation, formation, storage, organization, and access.
Owner of the personal data bank: A natural person, private legal entity, or public entity that determines the purpose and content of the personal data bank, the processing of these, and the security measures.
Processor of the personal data bank: Any natural person, private legal entity, or public entity that alone or acting jointly with another performs the processing of personal data on behalf of the owner of the personal data bank.
Anonymization procedure: Processing of personal data that prevents identification or makes the data subject unidentifiable. The procedure is irreversible. Disassociation procedure: Processing of personal data that prevents identification or makes the data subject unidentifiable. The procedure is reversible.
5. RESPONSIBLE FOR COMPLIANCE
Enjoy Travel Now E.I.R.L. will assign and communicate the corresponding responsibilities to all staff and suppliers for compliance with this Policy.
The department responsible for reviewing this Policy annually and making the necessary adjustments within Enjoy Travel Now E.I.R.L. shall be the General Management. Likewise, said Management shall be responsible for answering any queries related to the application and scope of this Policy.
However, all Enjoy Travel Now E.I.R.L. employees as well as all suppliers and third parties with whom Enjoy Travel Now E.I.R.L. engages in the regular course of its business and who have access to or process personal data are subject to compliance with the Policy. Finally, no Enjoy Travel Now E.I.R.L. employee shall act on behalf of the Company. actions or omissions that constitute a breach of the Law.
6. CONFIDENTIALITY
This Policy is for internal and exclusive use by Enjoy Travel Now E.I.R.L. and, therefore, is confidential. Any use other than that indicated is prohibited and must be expressly authorized in writing by the General Management.
Personal data to which Enjoy Travel Now E.I.R.L. employees and related third parties have access to or participate in their processing may not be treated in any way without the consent of the data subject after the end of their relationship with Enjoy Travel Now E.I.R.L., except as regulated by law.
In the case of employees who, by the nature of their functions, have access to confidential and sensitive personal information, Enjoy Travel Now E.I.R.L. will seek to provide specific training and awareness actions. Individuals involved in the processing of personal data are required to maintain professional secrecy and confidentiality regarding them. This obligation will remain even after their relationship with Enjoy Travel Now E.I.R.L. has ended.
7. PRINCIPLES
All Enjoy Travel Now E.I.R.L. employees must permanently comply with the principles established in the Law as detailed below:
a. Legality. The processing of personal data carried out by Enjoy Travel Now E.I.R.L.. will be in accordance with the provisions of the Law. The collection of personal data by fraudulent, unfair, or illegal means is prohibited.
b. Consent. Enjoy Travel Now E.I.R.L. may not process personal data that does not have the prior, express, unequivocal, and free consent of its owner as necessary, except for the exceptions provided by law.
c. Purpose. Enjoy Travel Now E.I.R.L. will collect personal data clearly indicating the purpose for which it collects such data, which must be determined, explicit, and lawful. The personal data subject to processing may not be used for different or incompatible purposes with those that motivated their obtaining, except with the consent of their owner. In this sense, Enjoy Travel Now E.I.R.L. will comply with implementing measures that guarantee: • The collection, storage, and preservation of personal data comply with the principles of proportionality and purpose. • The adequate safeguarding of personal data, complying with appropriate technical and legal security measures. It should be noted that Enjoy Travel Now E.I.R.L. may not disclose personal data unless ordered by a motivated order of the judge or with the authorization of its owner, with the guarantees provided by law. Likewise, Enjoy Travel Now E.I.R.L. may not refuse to provide information containing personal data to a public entity as long as such requirement is made for the strict fulfillment of the competencies of such entities assigned by current legislation.
d. Proportionality. All processing of personal data carried out by Enjoy Travel Now E.I.R.L. must be adequate, relevant, and not excessive for the purpose for which they were collected.
e. Quality. The personal data to be processed by Enjoy Travel Now E.I.R.L. must be truthful, accurate, and, as far as possible, updated, necessary, relevant, and appropriate with respect to the purpose for which they were collected. They must be preserved in such a way as to guarantee their security and only for the time necessary to fulfill the purpose of the processing, respecting the legal deadlines for the retention of applicable documents and information.
f. Security. Enjoy Travel Now E.I.R.L.. and third parties to whom the processing of personal data is entrusted must adopt the necessary and appropriate technical, organizational, and legal measures to guarantee the security of personal data against different risks, such as accidental loss or destruction by disaster, unauthorized access, covert use, or infection by malware or computer viruses. These measures will be established, communicated, and updated by Enjoy Travel Now E.I.R.L. as necessary.
g. Adequate level of protection. In the event that Enjoy Travel Now E.I.R.L. carries out international transfers of personal data, it must guarantee a sufficient level of protection for the personal data to be processed or, at least, comparable to that provided by law.
h. Rights of personal data subjects. Enjoy Travel Now E.I.R.L. will have a simple and free procedure for addressing the rights of personal data subjects provided for by law: (i) information, (ii) access, (iii) update, (iv) inclusion, (v) rectification, (vi) deletion, (vii) prevent supply, (viii) opposition, and (ix) objective treatment.
Therefore, Enjoy Travel Now E.I.R.L.: • Will take the necessary measures to inform the personal data subject about the rights conferred by law. • Will adopt measures that allow the personal data subject to keep them updated. • Will comply with timely and legally binding deadlines for requests and inquiries related to the aforementioned rights of personal data subjects; The following guidelines will apply in the processes of addressing the rights of personal data subjects: • The deletion or rectification of personal data shall not proceed when it affects Enjoy Travel Now E.I.R.L., its shareholders, employees, or directors’ legitimate rights or interests, or those of third parties, or when there is a legal obligation to retain the personal data. Enjoy Travel Now E.I.R.L. may reject certain requests when the disclosure of personal data may compromise or hinder ongoing judicial or administrative actions.
8. TRANSFER OF PERSONAL DATA
Personal data processed by Enjoy Travel Now E.I.R.L. may only be transferred to third parties for the fulfillment of purposes related to the legitimate interest of the transferor and the transferee and with the prior, express, free, unequivocal, and informed consent of the data subject. Such consent shall not be required in cases permitted by law.
9. COLLECTION OF SENSITIVE DATA
Enjoy Travel Now E.I.R.L. will only collect personal data and/or sensitive data when strictly necessary and in respect of the principles of purpose and proportionality. When the collection and processing of such data result from compliance with a legal obligation, Enjoy Travel Now E.I.R.L. will inform the data subject of such situation prior to their collection.
10. DISCLOSURE OF PERSONAL DATA
Enjoy Travel Now E.I.R.L. will not disclose personal data to third parties except when: a) It is necessary for the purpose for which the personal data was collected; such as in the provision of services through third parties and suppliers. b) The data subject is informed before the disclosure or at the time of the collection of personal data. c) The data subject gives their prior and express consent. d) Consent is not required by law. e) Personal data is required by public entities within the scope of their legal competences and attributions. f) Personal data is necessary to satisfy legitimate requirements of a company interested in acquiring any of Enjoy Travel Now E.I.R.L.’s operations, subject to the consent of its owner; or, g) Access to personal data is by auditors and lawyers and other professionals obligated to maintain professional secrecy.
11. ELIMINATION OF PERSONAL DATA
Once the processing of personal data has ended and the purpose has been fulfilled, and provided that there is no legal mandate or reason justifying the retention of personal data, Enjoy Travel Now E.I.R.L. will proceed to delete them from its records. Alternatively, Enjoy Travel Now E.I.R.L. may apply dissociation processes, or equivalent processes when for commercial, statistical, or market analysis reasons, it justifies the convenience of retaining such data. Enjoy Travel Now E.I.R.L. will define the necessary procedures for the deletion of personal data in a timely manner.
12. PENALTY REGIME
It will be considered a serious offense and subject to sanctions for any employee who commits any violation of the provisions established in this Policy. Enjoy Travel Now E.I.R.L. will take disciplinary measures it deems pertinent in cases of non-compliance with the obligations stipulated herein by employees.
13. DISSEMINATION AND COMPLIANCE WITH THE POLICY
Enjoy Travel Now E.I.R.L. will endeavor to: i) ensure compliance with the provisions of this Policy; ii) make each employee aware of, observe, and respect this Policy; iii) publish this Policy in easily accessible places; and iv) subscribe to confidentiality obligations with employees, users, contractors, and third parties accessing the personal data included in databases.
