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POLICY FOR THE PROCESSING OF PERSONAL DATA

1. WHO ARE WE?

UNIBELL S.A.C. is a Peruvian company identified with RUC N ° 20511451354, dedicated to the manufacture and marketing of articles for personal care and hygiene, holder of recognized brands in the national and international market, which can be reviewed on our institutional website www.lanosterin.com.pe

Our address is located at Jirón General Felipe Varela N ° 352, Breña district. Province and department of Lima.

2. PRIVACY POLICY

Through this document the privacy policy of our society is regulated, which we recommend you review in its entirety.

This policy covers the information collected in person and through our website and social networks.

Unibell cares about the protection and privacy of our users' personal data, for which reason we use all the tools that are within our reach to guarantee confidentiality and the security that all information we collect will be used solely and exclusively for the purposes indicated in this document and in accordance with the current legal framework.

We declare not to carry out acts of transfer of the databases to third parties not linked to our company.

3. APPLICABLE LEGAL FRAMEWORK

a) Political Constitution of Peru.

b) Law No. 29733 - Law on Protection of Personal Data.

c) Supreme Decree No. 003-2013-JUS, Regulation of the Law on Protection of Personal Data.

d) Information Security Directive, approved by Directorial Resolution No. 019-2013-JUS / DGPDP.

e) Directive for the Treatment of personal data through Video Surveillance Systems, approved by Directorial Resolution No. 02-2020-JUS / DGTAIPD.

f) Directives, Directorial Resolutions and other provisions issued by the General Directorate for the Protection of Personal Data of the Ministry of Justice and Human Rights.

4. DEFINITIONS

a) Personal data bank. Organized set of personal data, automated or not, regardless of the support, be it physical, magnetic, digital, optical or others that are created, whatever the form or modality of its creation, training, storage, organization and access.

b) Personal data. All information about a natural person that identifies or makes it identifiable through means that can be reasonably used.

c) Sensitive data. Personal data made up of biometric data that by themselves can identify the owner; data referring to racial and ethnic origin; economic income; political, religious, philosophical or moral opinions or convictions; union membership; and information related to health or sexual life.

d) Cross-border flow of personal data. International transfer of personal data to a recipient located in a country other than the country of origin of the personal data, regardless of the medium in which they are found, the means by which the transfer was made, or the treatment they receive.

e) Sufficient level of protection for personal data. Level of protection that includes at least the consignment and respect for the guiding principles of the Law, as well as technical security and confidentiality measures, appropriate according to the category of data in question.

f) Holder of personal data. Natural person to whom the personal data corresponds.

g) Holder of the personal data bank. UNIBELL.

h) Transfer of personal data. Any transmission, supply or manifestation of personal data, of a national or international nature, to a legal person under private law, a public entity or a natural person other than the owner of personal data.

i) Processing of personal data. Any technical operation or procedure, automated or not, that allows the collection, registration, organization, storage, conservation, elaboration, modification, extraction, consultation, use, blocking, deletion, communication by transfer or by diffusion or any other form of processing that facilitate access, correlation or interconnection of personal data.

j) Clients. Natural or legal person to whom UNIBELL sells goods or provides services by virtue of a pre-existing commercial relationship.

k) Suppliers Natural or legal person that supplies goods and / or services to UNIBELL by virtue of a pre-existing commercial relationship.

l) Worker Natural person who provides or provided personal services to UNIBELL by virtue of an employment contract.

m) Visitor Any natural person who is in the facilities of the UNIBELL offices and who does not have the status of worker.

n) Applicants Natural persons who, due to labor interest, present themselves for personnel selection processes called by UNIBELL, send information in order to be able to advance the respective personnel hiring processes.

o) Owner Natural person whose personal data are subject to Treatment.

p) Responsible for the treatment Who, due to their legal situation, decides on the processing of personal data.

q) UNIBELL Worker User who has access to the databases.

5. PURPOSE OF THE PROCESSING OF PERSONAL DATA

a) Purpose of the Treatment of Personal Data of Clients. UNIBELL may carry out the Treatment of personal information about its Clients for the purposes of its corporate purpose. For this reason, the contracts that are celebrated with Clients will be governed by the provisions of this Policy, or will include a clause that regulates the Treatment of the information accessed by virtue of it. In the same way, UNIBELL may carry out the treatment of the personal information of its potential, current or future Clients and of those Clients with whom its commercial relationship has ended, in order to send them commercial information that in its opinion may be of your interest; as well as, among others, inviting them to events that it organizes; send newsletters, reports or publications and, in general, use the data for the development of the activities included in the corporate purpose of UNIBELL. Likewise, UNIBELL, on the occasion of events, trainings or other activities carried out by it, may record and take audios, videos or photos of Clients of their development. These audios, videos or photos may be used by UNIBELL in newsletters, publications, and in general in any activity carried out by UNIBELL.

b) Purpose of the Processing of Personal Data of Workers. UNIBELL will carry out the Treatment of personal information of its workers and their family nucleus in order to comply with the obligations that emanate from the respective labor relations. Such obligations include, among others, payroll payments, granting of benefits, performance evaluations, improvement of training programs, among others. On the other hand, UNIBELL, on the occasion of the events, trainings or other activities carried out by them, may record and take audios, videos or photos of the employees of their development. These audios, videos or photos may be used by UNIBELL in newsletters, publications, and in general in any UNIBELL activity, even once the worker ceases her employment relationship with UNIBELL. Likewise, UNIBELL will have a file in which the personal data of all Employees who have terminated their employment relationship with UNIBELL will be stored for up to 5 years. The purpose of this file is: (i) Serve as a basis for the issuance of labor certificates or any other document related to the employment relationship in accordance with current labor regulations, at the request of the Former Employee or her successors in title; (ii) Serve as a basis for the granting of employment references to potential employers of the Former Employee, when the latter authorizes it at the time of her separation from any of UNIBELL; and / or iii) the information stored in this file may be studied, analyzed and used by UNIBELL in order to consider the Former Employee in the personnel hiring processes carried out by UNIBELL.

c) Purpose of the Processing of Personal Data of Applicants UNIBELL may collect personal information from applicants who present themselves for selection processes in order to advance the respective personnel hiring processes. Additionally, UNIBELL may store the information of those who present themselves for these processes for 30 days and use it in personnel selection processes in the future. For the foregoing, it is understood that whoever submits their resume for consideration by any of UNIBELL, by any means, understands and authorizes the Treatment that UNIBELL may do of their personal data. On the other hand, UNIBELL, on the occasion of the events, trainings or other activities carried out by it, may record and take audios, videos or photos of the applicants during their development. These audios, videos or photos may be used by UNIBELL in newsletters, publications, and in general in any UNIBELL activity, even once the employee retires from working with UNIBELL, that is, once the person is considered a former employee.

d) Purpose of the Treatment of Personal Data of Suppliers UNIBELL will carry out the Treatment of personal information of its Suppliers in order to comply with the obligations acquired by virtue of the respective relationship. In relation to Suppliers, such obligations include, among others, evaluating their performance; establish, manage or terminate business relationships or verify references; provide the business metrics, and the others that are established in the agreements or contracts that are signed with the respective Provider. The treatment of the data collected by virtue of the provisions of this section will be carried out and will be in force as long as the purpose for which the respective data was collected is maintained.

e) Complaints Book UNIBELL will carry out the Treatment of personal information of the Holders in order to attend any claim that they may present through this means, in accordance with the legislation on consumer rights, and will remain in force during the period indicated by the regulations of the matter.

f) Purpose of the Processing of Personal Video Surveillance Data UNIBELL will carry out the Treatment of personal information of the Holders in order to safeguard the security inside and outside their offices. In outdoor areas, video surveillance will be carried out within reasonable areas and without violating the right to privacy of neighbors UNIBELL may record and take audios, videos or photos of the Holders who have entered their offices through the closed security circuit and other means that have been implemented for safety purposes, as well as verifying compliance by workers with their obligations and work duties. These data may be obtained during entry, stay and exit from various environments of the UNIBELL offices. The Treatment of the data that is collected by virtue of the provisions of this section will be carried out and will be in force for a period of 7 days or, in exceptional cases, while the purpose for which the respective data was collected is maintained or the defined retention times for video surveillance tapes in UNIBELL's internal policies or by legal mandate.

g) Visitors UNIBELL will carry out the Treatment of personal information of the Holders in order to safeguard the security within their offices, with the sole purpose of knowing the identity of third parties who enter the UNIBELL facilities. This information will be valid for a period of 30 days.

h) Users Since the users are Unibell workers, their data will be treated according to the workers' data treatment policies.

6. PROCEDURE FOR THE EXERCISE OF THE HOLDER'S RIGHTS (ARCO RIGHTS)

The owners have the rights of information, access, rectification, cancellation, opposition and objective treatment of personal data, which can only be exercised by the owner of personal data, without prejudice to the rules that regulate representation.

Due to the right to information, the owner of personal data has the right to be informed in a detailed, simple, express, unequivocal way and prior to its collection, about the purpose for which their personal data will be processed; who are or may be its recipients, the existence of the data bank in which they will be stored, as well as the identity and address of its owner and, if applicable, of the person or persons in charge of processing your personal data; the mandatory or optional nature of your responses to the questionnaire that is proposed, especially regarding sensitive data; the transfer of personal data; the consequences of providing your personal data and your refusal to do so; the time during which your personal data is kept; and the possibility of exercising the rights granted by law and the means provided for it.

Due to the right of access, the owner of personal data has the right to obtain the information about herself that is subject to treatment in data banks of public or private administration, the way in which her data was collected, the reasons that motivated its collection. and at the request of whom the collection was made, as well as the transfers made or planned to be made of them.

For the right to update, inclusion, rectification and deletion, the owner of personal data has the right to update, inclusion, rectification and deletion of their personal data subject to treatment, when they are partially or totally inaccurate, incomplete, when warned omission, error or falsehood, when they are no longer necessary or pertinent to the purpose for which they have been collected or when the term established for their treatment has expired.

Due to the right to prevent the supply, the owner of personal data has the right to prevent them from being supplied, especially when this affects their fundamental rights. The right to prevent the supply does not apply to the relationship between the owner of the personal data bank and the person in charge of processing personal data for the purposes of processing these ”.

Due to the right of opposition, provided that, by law, the opposite is not provided and when they have not given consent, the owner of personal data may oppose their treatment when there are well-founded and legitimate reasons related to a specific personal situation. In case of justified opposition, the owner or the person in charge of processing personal data, as appropriate, must proceed to its deletion, in accordance with the law ”.

To exercise your ARCO rights, you must send a request to UNIBELL, to our aforementioned address or to the email This email address is being protected from spambots. You need JavaScript enabled to view it., which will contain:

a) Names and surnames of the holder of the right and accreditation of the same with their respective identity document, and where appropriate, their legal representative.

b) Specific request that gives rise to the request.

c) Address, or address that may be electronic, for the purposes of the corresponding notifications.

d) Date and signature of the applicant.

e) Documents that support the request, if applicable.

We will respond to your request within a maximum period of 15 business days, unless we require more information to adequately attend to your request.

7. CONFIDENTIALITY OF INFORMATION

We are committed to maintaining confidentiality regarding personal data and your background.

8. INFORMATION SECURITY

For the purposes of processing personal data, we declare that we have reasonable policies that involve technical, organizational and legal measures that guarantee its security and prevent its alteration, loss, treatment or unauthorized access.

9. DATA PROCESSING OF MINORS

UNIBELL only collects and uses the personal data of minors with the prior consent of the holders of parental authority, guardians or legal representatives. If a minor enters their personal data through our website, the existence of the authorization of the holders of parental authority, guardians or legal representatives will be presumed, who will be held responsible for all acts carried out by minors at their discretion. position.

10. INTERNATIONAL TRANSFER OF PERSONAL DATA

We undertake the commitment not to carry out cross-border flows of personal data to countries that do not have adequate levels of protection in accordance with current legislation.

11. USE OF COOKIES

Our website uses cookies, which are small files that are stored on computers and that allow us to remember browsing characteristics or preferences that you have on our website. Thanks to this we can personalize the income to the web in future visits, make browsing more secure and know your preferences to offer you information of interest. You can configure your browser to accept or reject the installation of cookies or delete them once you have finished browsing our website. UNIBELL is not responsible for the fact that the deactivation of cookies may prevent the proper functioning of our website.

12. CHANGES TO OUR POLICY

We reserve the right to modify this data treatment policy, without prior notice and without the need to communicate the changes, assuming our commitment to publish it on our website and social networks.