Introduction

At GRUPO PAULINO S.A.C. (hereinafter referred to as “the Company”, including references to “We”, “Our” or “Us”), we deeply value and respect your privacy and recognize the importance of protecting your personal data. In this regard, the Privacy Policy (“the Policy”) is intended to provide you with a clear and transparent description of our practices regarding the collection, use, and disclosure of the personal information we collect.

We want to inform you about how we treat your personal information in the context of our business and shipping activities, as well as about the communications you may receive from us. We encourage you to read this Policy carefully to better understand how we handle your information and what your rights are in relation to it.

By accessing or using our services, you are agreeing to the terms and conditions set forth in this Policy. If you have any concerns or do not agree with any aspect of this Policy , we encourage you to contact us before continuing to use our services.

Key Definitions

This Privacy Policy is based on the definitions established by Peruvian Law No. 29733 – Personal Data Protection Law and its regulations.

Personal data: Information that identifies or makes a natural person identifiable, such as names, surnames, national ID or passport number, address, email, phone number, browsing history, location data, employment, financial or health information, or any other data that may identify an individual directly or indirectly.

Personal data processing: Any technical operation or procedure, whether automated or not, that allows for the collection, registration, storage, conservation, preparation, modification, consultation, use, blocking, deletion, transfer, dissemination, or any other form of handling of personal data.

Data subject: The natural person to whom the personal data being collected, processed, or stored belongs. As a user or customer of GRUPO PAULINO S.A.C., you are the data subject of the personal data you provide to us.

Data controller: A natural person, company, or public or private entity that determines the purpose and means of personal data processing. In this context, {companyName} acts as the Data Controller for the personal data you provide to us.

Data processor: A natural or legal person who processes personal data on behalf of the Data Controller, according to the controller’s instructions and under a formal agreement. All our Data Processors are contractually obligated to ensure the security and confidentiality of your information.

Third party: Any natural or legal person other than the data subject, the data controller, or the data processor. Third parties with whom we share personal data are subject to legal and contractual obligations to protect your data.

Consent: A clear, free, prior, express, unequivocal, and informed expression of will by the data subject authorizing the processing of their personal data in accordance with applicable laws.

Information We Collect

At GRUPO PAULINO S.A.C., we collect various types of personal information from our users/customers in order to provide better service, comply with legal obligations, and offer new features. Below, we outline the types of data we may collect in accordance with current Peruvian regulations:

Personally identifiable information: This includes, but is not limited to, full name, national identity document (DNI) number, address, phone number, email address, date of birth, and any other information that can individually identify you. This data is not collected directly from the website, but only when you make a purchase and enter the required information for your travel ticket issuance.

Payment information: When you make a purchase, your credit or debit card details, along with other financial information required to process the payment, are handled by third-party payment gateways. At {companyName}, we do not store or access your financial information. In Peru, we work with gateways that are authorized and regulated by the SBS (Superintendencia de Banca, Seguros y AFP) and other competent authorities, which comply with strict security and privacy standards. We recommend reviewing the respective provider’s privacy policy before completing your transaction.

Travel-related information: This includes details such as your travel itinerary, seat preferences, and booking history. These data are collected only at the time of purchase and stored as part of our travel management system.

Browsing, usage, and geolocation data: We collect information about how you interact with our website, including your IP address, device type, browser used, pages visited, browsing time, and—if authorized—your geographic location. These data are collected automatically through cookies or similar technologies and are used to provide a more personalized service and improve your online experience. For more information, please see our Cookie Policy.

Communication: We store records of all communications you have with us (email, phone calls, live chat, or other channels). Additionally, upon completing a purchase, we retain your contact information to send you confirmations, updates, or any other notifications related to your trip. Promotional messages may also be sent to you, but only if you have given your express consent, as established by Peru’s Personal Data Protection Law.

How We Use Information

At GRUPO PAULINO S.A.C., we use the personal information we collect from our users for several essential purposes, including:

Providing and improving our services: we use your information to manage and process your transactions, ensure you receive the service you request, and improve the quality of our services. This includes personalizing your experience on our platform, tailoring content and offers to your preferences and needs.

Communication: We use your contact information to communicate with you about your purchase, provide updates on the status of your reservations, and send you important service-related notifications. Also, if you have requested, we use your information to send you promotions, special offers, and newsletters.

Analyzing and improving the user experience: We analyze how you interact with our services to better understand your preferences and needs. This information helps us to optimize our platform, develop new products, and improve our service offerings.

Legal compliance: We may use your information to comply with our legal obligations, resolve disputes, enforce our terms and conditions, and cooperate with law enforcement when necessary.

Security: The information we collect is also used to protect the security of our services, detect and prevent fraud, abuse, and other activities that may compromise the integrity of our systems or the safety of our users.

Data marketing (sale of personal data): At GRUPO PAULINO S.A.C., we do not sell our users' personal data to third parties. This includes any transfer of personal data that would be considered a “sale” under the California Consumer Privacy Act (CCPA). Under this law, consumers have the right to opt out of the sale of their personal data. If at any time GRUPO PAULINO S.A.C. decides to change its policy and offer third parties access to our users' personal data in a manner that would be considered a sale, we will notify users in advance and provide them with the option to opt-out of such transactions, in compliance with the CCPA.

Notices and Communications

Notifications related to your purchase

At GRUPO PAULINO S.A.C., we use your contact information to send you essential notifications related to purchases and services you have requested. These notifications include:

• Booking confirmations: we send you confirmations of your purchase, including details of your travel itinerary and any other aspects relevant to your booking.

• Itinerary updates: If there are changes to your itinerary, such as schedule or route changes, we will notify you immediately so that you are informed and can plan accordingly.

• Reminders and alerts: We will send you reminders about your upcoming trip, as well as any important alerts that may affect your transportation experience.

Promotional communications

In addition to operational notifications, if you have given your consent, we may send you promotional communications, including:

• Special offers and discounts: Occasionally, we will inform you of exclusive promotions, travel discounts, or new routes available.

• Newsletters: You may also receive newsletters with news, updates on our services, and relevant content that we think may be of interest to you.

At any time, you can request to stop receiving these promotional communications by using the unsubscribe button included in each message we send you. This process is simple and ensures that you will not receive future promotions if you wish to do so.

SMS Notifications

By making a purchase on our website, you agree to receive essential notifications related to your transaction through various channels, including text messages (SMS). These notifications are intended to keep you informed about the status of your purchase and travel, and include booking confirmations, ticket updates, reminders of upcoming travel, and any other important information related to your transaction.

Importantly, we use SMS messaging to provide you with direct and timely communication, ensuring that you receive all the information you need for your travel experience, from purchase confirmation to reminders close to your travel date.

If at any time you wish to stop receiving SMS notifications, you can easily deactivate this service by contacting our customer service team or by adjusting your notification preferences in your account on our website. Our goal is to give you full control over the communications you receive, while respecting your preferences at all times.

International Data Transfers

At GRUPO PAULINO S.A.C., your personal data may be stored and processed on servers located outside Peruvian territory, including but not limited to the United States. These transfers are made in order to provide our services in a secure, efficient, and continuous manner.

In accordance with Law No. 29733, any international transfer of personal data requires the data subject’s prior, express, and informed consent, except in cases expressly exempted by law. {companyName} ensures that such transfers are carried out in compliance with the principles of purpose, proportionality, security, and quality as required by Peruvian regulations.

By using our services and accepting this Privacy Policy, you give your consent for your personal data to be transferred internationally and processed in jurisdictions with adequate levels of data protection, or under the appropriate contractual safeguards.

If you would like more information about these transfers or wish to revoke your consent at any time, you may contact us through the channels provided in our Privacy Policy.

Data Security

At GRUPO PAULINO S.A.C., the security of your personal information is a priority. We use secure Oracle servers and adopt up-to-date technologies and best practices to protect your data against unauthorized access, misuse, disclosure, alteration or destruction.

• Protection during payment: Transaction fraud protection is handled by third-party payment gateways, such as Authorize.net, which employ advanced security measures to ensure that your transactions are secure.

• Technologies and Best Practices: We implement measures such as Secure Socket Layer (SSL) encryption to protect data during transmission. In addition, we follow appropriate security standards and apply best practices in the management of our systems and servers, minimizing risks and ensuring the integrity of your information.

• Audits and Compliance: At GRUPO PAULINO S.A.C., we seek to comply with applicable data protection regulations in the United States and Mexico, adopting best practices in the management of personal information. While we do not conduct internal audits unless required by law, we implement appropriate security and control measures to ensure compliance with applicable legal obligations regarding the processing of personal data.

At GRUPO PAULINO S.A.C., we seek to comply with applicable data protection regulations in the United States and Mexico by adopting best practices in the management of personal information. We implement appropriate security and control measures to ensure compliance with our legal obligations regarding the processing of personal data.

While we make every effort to protect your data, it is important to keep in mind that no system can guarantee absolute security. However, we are committed to using the most effective methods available to us to safeguard your information.

Credit Card and Bank charge information

At GRUPO PAULINO S.A.C., protecting your financial information is very important. When you make a purchase through our platform, your credit or debit card details and other financial data are processed exclusively by secure payment gateways, such as Authorize.net.

These gateways handle the validation and authorization of transactions, ensuring that your information is protected by advanced encryption technologies and security protocols.

User Rights

At GRUPO PAULINO S.A.C., we respect and protect the rights of our users regarding their personal data, in accordance with Law No. 29733 - Personal Data Protection Law of Peru. Below are the main rights you can exercise:

Right of access: You have the right to know what personal data we process about you, how we obtained it, for what purpose, and whether it has been shared with third parties. You may request a copy of your data at any time.

Right of rectification: If the personal data we have about you is inaccurate, incomplete, or outdated, you may request its correction or update.

Right of cancellation: You have the right to request the deletion of your personal data when you consider that it is not being processed in accordance with current regulations, or when the data is no longer necessary for the purpose for which it was collected. This right is subject to legal exceptions.

Right of opposition: You may object to the processing of your personal data for legitimate and justified reasons, provided there is no legal obligation preventing the exercise of this right or that the processing is necessary for the execution of a current contractual relationship.

Procedure to exercise rights: You can exercise any of these rights by submitting a request through the contact channels detailed in this policy. The request must include your full name, identity document number, a description of the right you wish to exercise, and any supporting documentation.

At GRUPO PAULINO S.A.C., we commit to responding to your request within the timeframes established by current regulations and to provide you with all the necessary information regarding the status and outcome of your request.

Cookies Similar Technologies

At GRUPO PAULINO S.A.C., we use cookies and similar technologies to enhance your user experience, personalize content and analyze the use of our services. Cookies are small data files that are stored on your device when you visit our website. These technologies allow us to remember your preferences, keep you logged in, and provide you with a more seamless and personalized experience.

Types of cookies we use

Essential Cookies: These cookies are necessary for our website to function properly. Without them, we would not be able to provide services such as account management or payment processing.

Performance cookies: We use these cookies to collect information about how users interact with our website, allowing us to improve its performance and provide you with a better experience.

Functionality cookies: These cookies allow us to remember your choices (such as your user name, language or the region you are in) and provide enhanced and more personalized features.

Advertising cookies: We use these cookies to make advertising more relevant to you. They can also limit the number of times you see an advertisement and help us measure the effectiveness of our advertising campaigns.

Similar technologies: In addition to cookies, we use similar technologies such as pixels, web beacons and local storage to collect information and improve your experience on our platform and service.

Cookie control and management

You have control over the use of cookies on our website. Through our consent banner, you can decide whether you want to Allow all cookies, enable only strictly necessary cookies, or manage your privacy preferences by selecting which types of cookies you want to allow.

While you can set your browser to accept or reject cookies generally, we caution you that disabling certain cookies may affect the functionality of some features of the site.

For more information on how we use cookies and how you can manage them, we invite you to consult our Cookie Policy, where you will find additional details on the use of these technologies.

Changes to this Privacy Policy

At GRUPO PAULINO S.A.C., we reserve the right to update or modify this Privacy Policy at any time. Changes will reflect our current practices, new services or legal requirements that may arise. Whenever we make an update, we will notify our users through a prominent notice on our website or by other means of communication, such as e-mails if necessary. The date of the update will be indicated at the top of this page.

We recommend that you review this Privacy Policy periodically to be aware of any changes. Your continued use of our services following the implementation of changes will constitute your acceptance of the changes.

We recommend that you review this Privacy Policy periodically to be aware of any changes. The date of the last update will always be indicated at the top of this page. Your continued use of our services after the implementation of the changes will constitute your acceptance of the changes.

Contact Information

If you have questions, concerns or comments about this Privacy Policy or how we handle your personal data, please feel free to contact us.

You may contact us by the following means:

Email: grupopaulinosac@gmail.com

Telephone: 940 521 555

We are committed to responding to your inquiries in a timely and effective manner.

Specific Provisions for Peru

At GRUPO PAULINO S.A.C., we comply with Peruvian regulations on personal data protection. Below are specific provisions applicable in Peru:

We comply with the provisions of Law No. 29733 - Personal Data Protection Law and its regulations, which ensure that your personal data is processed properly, securely, and in accordance with the principles of legality, consent, purpose, proportionality, quality, security, and availability of recourse.

As the data subject, you have the right to exercise the rights of access, rectification, cancellation, and opposition (ARCO rights), as well as to revoke your consent for the processing of your data at any time, in accordance with the law.

If you wish to exercise any of these rights or have questions regarding the processing of your personal data, you can contact us through the communication channels provided in this policy or on our official website.