Privacy Policy

1. Introduction

Cobrana S.A.C. (hereinafter, “Cobrana”), with Tax ID (RUC) No. 20614567555 and registered address at Avenida Circunvalación del Golf Los Incas 1033, district of Santiago de Surco, Lima, Peru, is a company dedicated to providing technological solutions that facilitate communication, management, reminders and channeling of payments between companies, institutions or organizations that use the platform and their respective clients, end users, affiliates or third parties.

Cobrana is committed to protecting privacy and personal data, in compliance with Law No. 29733 – Personal Data Protection Law, its Regulation (Supreme Decree No. 016-2024-JUS) and other applicable regulations.

This Privacy Policy describes how Cobrana collects, processes, uses, stores and protects the personal data obtained through its website, digital platform and communication channels.

2. Roles in the processing of personal data

Cobrana may act in different roles in the processing of personal data, depending on the origin and purpose of the processing:

a) As data processor

Cobrana acts as data processor when it processes personal data provided by companies, institutions or organizations that use the platform (hereinafter, the “Users”), such as data of clients, end users, students, affiliates, parents, guardians or other third parties (hereinafter, the “Recipients”).

In this case:

• The User acts as the controller of the personal data bank.
• Cobrana processes the data solely following the User’s instructions.
• Cobrana does not determine the purpose or content of the data, limiting itself to processing it for the management of collections, sending reminders, communications and channeling of payments, in accordance with the contracted services.

b) As data controller

Cobrana acts as controller of the personal data bank when it directly collects information from people who visit, communicate with or register on its website or digital platform, for example, through:

• Contact forms
• Commercial inquiries
• Account creation
• Support, complaints or inquiries

Such information forms part of the “Digital Platform Users” Personal Data Bank, owned by Cobrana.

3. Personal data we collect through the website

Cobrana may collect the following personal data voluntarily provided by the users of its digital channels:

a) Data provided directly by the user:

• First and last names
• Email address
• Mobile phone number
• Company or business name

4. Purposes of the processing

Personal data will be processed, as applicable, for the following purposes:

• Manage access to, use of and operation of the Cobrana platform.
• Facilitate communication between Users and their Recipients.
• Send reminders, notices and communications related to payments.
• Authenticate users and ensure the security of the service.
• Provide technical support and handle inquiries or complaints.
• Comply with legal, contractual and regulatory obligations.
• Analyze the use of the service for statistical and continuous-improvement purposes.
• Send commercial information, news or updates about Cobrana’s services, subject to the data subject’s prior consent, where applicable.

5. Legal basis for the processing

The processing of personal data is carried out on the following legal bases:

• Contractual or pre-contractual performance, where the processing is necessary to provide the services.
• Express consent of the data subject, where required by law.
• Compliance with legal or regulatory obligations applicable to Cobrana or the Users.

6. Security and confidentiality

Cobrana implements reasonable technical, organizational and legal measures to protect personal data against unauthorized access, loss, alteration or destruction.

Access to personal data is restricted solely to authorized personnel, subject to confidentiality duties.

In the event of a security breach compromising personal data, Cobrana will promptly notify:

• The data bank controller, when acting as data processor.
• The affected data subjects, where applicable, in accordance with current regulations.

7. Data retention

Personal data will be retained only for the time necessary to fulfill the purposes of the processing and in accordance with applicable regulations.

In particular:

• Data will be retained for the duration of the contractual relationship with the User or until the digital-channel user requests the cessation of processing.
• It may be retained for the time necessary to handle complaints, requests or legal or administrative requirements.
• Once the relationship ends, personal data may be retained for a maximum period of two (2) years, unless a legal obligation requires retention for a longer period.

Indefinite retention of personal data is prohibited, except by express legal mandate.

8. Rights of the data subject (ARCO rights)

Data subjects may exercise the rights of:

• Access
• Rectification
• Cancellation
• Objection
• Withdrawal of consent

To exercise these rights, they must send a request to the email address privacidad@cobrana.pe, attaching a copy of their identity document and a clear description of the request.

Cobrana will handle such requests within the periods established by Law No. 29733.

9. Minors

Cobrana does not process the personal data of minors without the prior and verifiable consent of their parents or legal guardians. If improper processing of such data is detected, it will be deleted immediately.

10. Changes to the Privacy Policy

Cobrana may update this Privacy Policy when necessary. Modifications will be published at www.cobrana.pe, indicating the date of the last update.

When changes are substantial, Users will be notified through the available means.

11. Contact

Cobrana S.A.C.
Address: Avenida Circunvalación del Golf Los Incas 1033, Santiago de Surco, Lima, Peru
Email: privacidad@cobrana.pe
Phone: 980 590 096
Website: www.cobrana.pe