This Personal Data Privacy Policy (the "Privacy Policy") is intended to inform you how Cannabis Libre Club, owned by El Milagro Verde S.A.C. with RUC Nº 20609487080, processes the Personal Data it collects from its Users through questionnaires and written consents or provided via the completion of electronic forms found on the website https://www.cannabislibre.club (hereinafter referred to as the "Website") and Cannabis Libre Club's social media platforms (hereinafter referred to as "Social Media").
For the purposes of this Privacy Policy, any reference to "we" refers to Cannabis Libre Club, and any reference to the "User" refers to all individuals who browse, use, and/or enter into service contracts through the Website and Social Media and/or through the Call Center. At Cannabis Libre Club, we ensure the highest level of security and protection of our Users' Personal Data.
We kindly ask that you read this Privacy Policy before voluntarily providing us with your personal data and, if you agree, to mark the acceptance box expressly and in advance. These data are necessary to fulfill the purposes described in this Privacy Policy, and failure to allow their processing would prevent us from being able to meet these purposes.
1. Regulatory Framework and Guiding Principles
This Privacy Policy is governed by Peruvian legislation, particularly by:
• Law No. 29733 (hereinafter referred to as the "Law")
• Supreme Decree No. 003-2013-JUS, which approves the Regulations of Law No. 29733 (hereinafter referred to as the "Regulation")
• Information Security Directive, approved by Directoral Resolution No. 019-2013-JUS/DGPDP (hereinafter referred to as the "Directive")
• Law No. 29571, Consumer Protection and Defense Code.
2. What information do we collect?
Cannabis Libre Club collects the following information:
- Personal data freely provided by the User at the time of registration, account creation, requesting contact, or entering into a service contract. When the User registers to request a contract through Cannabis Libre Club’s website and social media, or provides their details to be contacted by the Call Center, they must fill out forms that may request their name and/or surname, and/or DNI/CE number, and/or date of birth, and/or gender, and/or mobile phone number, and/or landline number, and/or home address, and/or email address. In some service contracts, personal data related to family life (number and age of children, pregnancy details, among others), health (medical history, medications, etc.), and socio-economic information (income, housing conditions, employment, among others) are requested, which are necessary for the service provision.
- Information collected when the User utilizes Cannabis Libre Club’s website and social media, which includes (i) information about activities conducted by the User while browsing and using the website or social media, such as behavior and usage habits, browsing and purchase history; (ii) the URL from which the User arrives (including external ones); (iii) most visited URLs by the User (including external ones); (iv) IP addresses; (v) browser used by the User; (vi) operational aspects of Cannabis Libre Club’s website and social media, such as navigation analytics and traffic statistics; (vii) Information about the User's phone model and mobile operating system; (viii) information that enables the preparation of a search terms report; (ix) User location, among others (hereinafter referred to as "Usage Information").
- Personal data provided by the User through our Chat, for reporting incidents or issues with purchases through our website and social media. In these cases, the User must provide their name and surname, email address, and phone/mobile number with which they registered or contracted.
- Personal data freely provided by the User when registering a complaint, claim, or general request. When the User registers a complaint, claim, or request on the website or through social media, or in person at our channels or attention campaigns, they must fill out forms where they are requested to provide their name and/or surname, and/or DNI/CE number, and/or date of birth, and/or gender, and/or mobile phone number, and/or landline number, and/or home address, and/or email address.
- Optionally, personal data freely provided by the User when registering or subscribing to participate in a promotion and/or receive a newsletter. When the User registers to participate in a promotion through Cannabis Libre Club’s website or social media, they must fill out forms requesting their name and/or surname, and/or DNI/CE number, and/or date of birth, and/or gender, and/or mobile phone number, and/or landline number, and/or home address, and/or email address; and for those Users subscribing to receive a newsletter, they must complete forms requesting their name and/or surname, and/or DNI/CE number, and/or date of birth, and/or gender, and/or mobile phone number, and/or landline number, and/or home address, and/or email address.
3. What do we use User Information for?
User Information is used for the following purposes:
- Contacting the User for the registration of their purchase.
- Registering the User and providing technical support.
- Verifying and validating the User's identity.
- Collecting information on activities conducted by the User while browsing the platform and making purchases, to offer personalized content based on their interests and needs. For example, the User will be able to view their contract history.
- Using Personal Data to provide home delivery services.
- Transferring User Information to companies providing cloud-based infrastructure services, which are used to host, store, and process User Information. It should be noted that such processing is necessary for the execution of Cannabis Libre Club's contractual relationship with the User and is therefore essential for providing the Cannabis Libre Club service.
- Addressing User complaints, claims, or requests and providing the necessary support.
- If the User consents to the processing of their personal data for additional purposes, market studies may be conducted, purchase histories may be recorded and analyzed, purchase profiles may be created, advertising campaigns may be conducted, and commercial prospecting, including sending (via physical, electronic, or telephone means) advertising, gifts, offers, and/or promotions (personalized or general) of products and/or services, may be performed. Likewise, for the execution of the promotion in which the User participates, if applicable, Personal Data may be communicated to the promotion organizers and/or companies responsible for delivering prizes, as indicated in the Terms and Conditions of each promotion. It should be noted that this processing is essential for the purposes described in this section.
- Statistical analysis for developing business strategies, in an anonymized or dissociated manner.
The User expressly states that they have been duly informed of all the aforementioned purposes. Furthermore, by accepting this Privacy Policy, the User authorizes and consents, in advance, freely, explicitly, unequivocally, and free of charge, to the processing of their Personal Data and the inclusion of their information in the Databases mentioned in this document, owned by El Milagro Verde S.A.C. If the User does not consent to the additional processing of their personal data described in a separate document, this will not affect the provision of the contracted service. Moreover, the User acknowledges and accepts that any processing of User Information necessary for executing the contractual relationship between the User and Cannabis Libre Club does not require their consent and only needs to be informed to the User.
4. Nature of the Information
The information provided by the User in the forms on Cannabis Libre Club's Website or Social Media is necessary to fulfill the purposes described above. Therefore, if the User does not allow its processing, they will not be able to access the services described in this document.
5. Transfer of Personal Data
The personal data provided by the User is shared with:
El Milagro Verde S.A.C., for those Users who choose the "home delivery" option for their products, as this company is responsible for executing the commercial transaction according to the Terms and Conditions published on the website. The User can review El Milagro Verde S.A.C.’s privacy policy at the following link: https://www.cannabislibre.club/en/content/8-privacy-policy
6. Database Ownership by El Milagro Verde S.A.C.
The User's personal data will be stored in the databases owned by El Milagro Verde S.A.C., as follows:
- The personal data entered for purchase registration and all that derives from it will be stored in the database named "Delivery".
- The personal data entered in the Complaints Book or through the ARCO request will be stored in the database named "Claims Attention".
The User gives their express consent for the inclusion of their Personal Data in the El Milagro Verde S.A.C. Database corresponding to their condition.
7. On the Accuracy of Personal Data
The User declares that the Personal Data provided is true, complete, and accurate. Each User is responsible for the truthfulness, accuracy, validity, and authenticity of the Personal Data provided and commits to keeping it properly updated. Notwithstanding the above, the User authorizes El Milagro Verde S.A.C. to verify the accuracy of the Personal Data provided through information obtained from publicly accessible sources or entities specialized in providing such information. El Milagro Verde S.A.C. is not responsible for the accuracy of information that is not self-produced, nor does it assume any responsibility for any damages that may arise from the use of such information.
8. How Do We Safeguard User Information?
El Milagro Verde S.A.C. adopts the necessary security measures to ensure the protection of the User’s information to prevent its alteration, loss, unauthorized processing, and/or access, considering the state of the technology, the nature of the data stored, and the risks to which they are exposed. In this regard, El Milagro Verde S.A.C. will use industry standards to protect the confidentiality of the User's information and declares the use of various security measures to prevent unauthorized access. However, El Milagro Verde S.A.C. is not responsible for illegal interceptions or breaches of its systems or databases by unauthorized persons, nor for the improper use of information obtained through such means, or any unlawful intrusion beyond the control and due diligence of El Milagro Verde S.A.C. and which is not attributable to it. El Milagro Verde S.A.C. is also not responsible for potential damages arising from interference, omissions, interruptions, computer viruses, telephone failures, or disconnections in the electronic system's operation caused by factors beyond El Milagro Verde S.A.C.’s control and which could not be avoided with due diligence; or for delays or blockages in the use of the IT platform caused by deficiencies or overloads in the Data Processing Center, the Internet system, or other electronic systems.
9. Disclosure
El Milagro Verde S.A.C. is committed to not disclosing or sharing the User’s Personal Data without their proper consent, except in the following cases:
- Requests for information from public authorities in the exercise of their functions and within their competencies.
- Requests for information pursuant to court orders.
- Requests for information in accordance with legal provisions.
10. Cookies
The Cannabis Libre Club Website uses cookies. A “Cookie” is a small text file that a website stores on the User’s browser. Cookies facilitate the use and navigation of a website and are essential for the proper functioning of the Internet, providing numerous advantages in the delivery of interactive services. Through cookies, websites and mobile applications can use information from your visit to perform evaluations and statistical calculations on anonymous data, as well as ensure service continuity or make improvements. Additionally, the information obtained through cookies is also used to analyze the User’s browsing habits and searches to improve commercial and promotional initiatives, displaying advertisements that may be of interest to the User and personalizing content. Cookies can be deleted from the hard drive if the User so wishes. Most browsers automatically accept cookies, but they allow the User to change their browser settings to reject the installation of cookies without affecting their access and navigation. In the event that links or hyperlinks on the Cannabis Libre Club Website and Social Networks redirect the User to other Internet locations owned by third parties that use cookies, El Milagro Verde S.A.C. is not responsible for the use of cookies by those third parties.
11. Scope and Retention Period
The personal data of Users will be retained for as long as necessary to fulfill the purposes of processing and/or until the User revokes their consent, after which it will be deleted in compliance with applicable laws and regulations.
12. Rights of Access, Rectification, Cancellation, and Opposition
ThThe data subject may exercise their rights of access, rectification, cancellation, or opposition by submitting a request through the link https://www.cannabislibre.club/en/content/12-arco-rights-request-form, via email at hola@cannabislibre.club, or through WhatsApp at +51 904077678.
If you believe that your rights have not been adequately addressed, you may file a complaint with the National Authority for the Protection of Personal Data. To do so, you must submit your claim at the Ministry of Justice and Human Rights, located at Calle Scipion Llona 350, Miraflores, Lima, Peru, attaching Form N.º 011, which must be downloaded and completed beforehand. The form is available at the following link: https://www.gob.pe/institucion/minjus/informes-publicaciones/1496089-formulario-n-011-procedimiento-trilateral-de-tutela-por-denegatoria-del-ejercicio-de-los-derechos-de-acceso-rectificacion-cancelacion-y-oposicion-como-titular-de-datos-personales
13. Age of Consent
By providing their personal data to El Milagro Verde S.A.C., the User declares they are at least eighteen years of age or the legal guardian of a minor, thereby giving valid consent according to the law. El Milagro Verde S.A.C. will not voluntarily process the personal data of minors unless it has received proper consent in accordance with applicable regulations. If it is discovered that the personal data collected belongs to a minor without the authorization of their legal guardian, appropriate measures will be taken to delete such data.
14. Transfer of Contractual Position
The User expressly authorizes the transfer of this Policy and their information to any party that (i) becomes bound by this Policy; and/or (ii) becomes the new manager of the database containing the User’s Information. Once the transfer has occurred, El Milagro Verde S.A.C. will not be held liable for any event that takes place from the date of the transfer onwards. The new data controller will assume all responsibilities established in this Policy regarding the processing, safeguarding, and retention of the previously detailed information.
15. Modifications to the Privacy Policy
El Milagro Verde S.A.C. expressly reserves the right to modify, update, or supplement this Privacy Policy at any time. Any modification, update, or extension to this Privacy Policy will be immediately published on the Cannabis Libre Club website and social media platforms, ensuring that the User is aware of what information we collect and under what circumstances, and consent will be requested upon re-accessing these services.
Last updated: October 17, 2024.