CPB Policies

Confidentiality Policy

Privacy Policy

The purpose of this Privacy Policy (hereinafter, the “Policy”) is to inform users of the Website (hereinafter, the “Users”) about the use and processing of their Personal Data collected through the Website.

The owner of the Website is Carrera & Cia, Sociedad Civil de Responsabilidad Limitada (“CPB Abogados”), with Tax Identification Number (RUC) 20461677836, with registered address at Ca. Monterrey No. 341, Apt. 601, Santiago de Surco District, Province and Department of Lima, Peru. The processing of Personal Data complies with Law No. 29733 – Personal Data Protection Law (the “Law”) and its Regulations, approved by Supreme Decree No. 016-2024-JUS (the “Regulations”).

Purpose of the Personal Data Requested

Necessary Purposes :

CPB Abogados collects and uses Users' Personal Data for the following purposes:

Allow the User to navigate through the Website.
Respond to any queries the User may have regarding the services provided by CPB Abogados.
Respond to any complaints that the User may submit, in accordance with applicable consumer protection regulations.

Additional Purposes :

Furthermore, Users' Personal Data may be used for the additional purposes detailed below.

This processing will only be carried out if the Website Users have given their express, free, prior and unequivocal consent to do so, in accordance with the provisions of the Law:

Sending commercial advertising, offers and promotions that may be of interest to you.

It is expressly established that CPB Abogados recognizes the right of Users to object to the use and processing of their Personal Data when they consider that the information provided does not fulfill any of the functions described above, or if the data provided is not necessary for the establishment of a contractual relationship. This is without prejudice to the right to revoke consent previously granted by Users, or to exercise their right to object to the use of their data in accordance with applicable provisions, rights that will in all cases be guaranteed by the company at all times.

Obtaining and Processing Personal Data

CPB Abogados may obtain information about Users by any means permitted by law, including, but not limited to, obtaining it in person or through the Website, as appropriate.

Users expressly authorize CPB Abogados and its authorized administrative staff to process the information provided in accordance with current legislation. CPB Abogados undertakes to process and protect such data using digital, technical, and administrative measures, guaranteeing an optimal level of security.

CPB Abogados is responsible for maintaining the confidentiality of the information provided by Users, and undertakes to adopt all necessary control and security measures to prevent alteration, use, unauthorized processing, loss, and/or access by unauthorized third parties.

Users expressly declare that all information made available by CPB Abogados is accurate, true, and provided in good faith, and hereby expressly release CPB Abogados from any liability in relation to the veracity of such information.

None of the data requested and collected by CPB Abogados from Users falls within the definition of "sensitive data" as established by the Personal Data Protection Law.

Mandatory Delivery of Personal Data

In order to fulfill the necessary purposes indicated in this Policy and provide our various services to Users, it is mandatory that you provide the following Personal Data: First and last name, email address, and telephone number.

The processing of the Personal Data of the Users listed above is necessary and indispensable to fulfill the purposes detailed above, respectively, therefore, the refusal to provide them will result in the inability to provide the services and actions described above that the User may request or require.

Any additional Personal Data not mentioned above that may be requested on the Website will be provided at the sole discretion of the User. Therefore, failure to provide such data, or its subsequent deletion or cancellation, will not impede the normal operation of our services.

Automated Decisions and Profiling

CPB Abogados informs Users that no automated decision-making, including profiling, is carried out that may produce legal effects on Users or significantly affect them.

The processing of Personal Data is carried out exclusively with human intervention and for the purposes described in this Privacy Policy, ensuring respect for User rights and transparency in the use of their information.

If CPB Abogados implements automated decision-making or profiling mechanisms in the future, Users will be informed in advance of their existence, the specific purposes of such processing, and the consequences it may entail.

Personal Data Bank

The existence of the personal database in which Users' Personal Data will be stored has been declared to the National Personal Data Protection Authority, under the name "Website Users."

Exercise of rights

As the owner of your Personal Data, the User has the right to access his or her Personal Data held by CPB Abogados, to know the characteristics of its processing, to rectify it if it is inaccurate or incomplete, to request its deletion or cancellation if he or she considers it unnecessary for the purposes previously explained, or to oppose its processing for specific purposes, in accordance with the exercise of the rights of access, rectification, cancellation, opposition, and portability.

In order to exercise the aforementioned rights, the User may direct their request to exercise ARCO rights to the following address: mkt@cpb-abogados.com.pe.

The request submitted by the User must comply with the specifications established in the Law and the Regulations, including: (i) the User's name, as well as their address or other means to receive a response to their request; (ii) a clear and precise description of the Personal Data for which they seek to exercise their ARCO rights; and (iii) other elements and/or documents that facilitate locating the Personal Data and processing the request.

If the User considers that he or she has not been properly assisted in the exercise of his or her ARCO rights by CPB Abogados, he or she may file a claim with the National Authority for the Protection of Personal Data, by contacting the Reception Desk of the Ministry of Justice and Human Rights: Ca. Scipión Llona No. 350, Miraflores, Lima, Peru.

Transfer of Personal Data

CPB Abogados will not share Users' Personal Data with other third parties, except where legally required.

Cross-border flow

To store Users' Personal Data, CPB Abogados contracts cloud services through Qualis Technology SAC, whose physical servers are located in the United States.

Conservation Period

The Personal Data provided by the User will be processed by CPB Abogados while the inquiries submitted are being addressed. Once the inquiries have been addressed, your information will be deleted from the Website Users' personal database.

However, if the User has given his or her consent for the processing of his or her Personal Data for additional purposes, then CPB Abogados may retain and use the Personal Data required for such purposes for a maximum period of five (5) years or until the User revokes the Consent.

Security Measures

CPB Abogados adopts the necessary technical and organizational measures to guarantee the protection of Users' Personal Data and prevent its alteration, loss, processing, and/or unauthorized access, taking into account the state of the art, the nature of the data stored, and the risks to which they are exposed, all in accordance with the provisions of the Personal Data Protection Regulations.

CPB Abogados employs various security techniques to protect such Personal Data from unauthorized access. Notwithstanding the foregoing, Users acknowledge that existing technical means of providing security are not impregnable and that even when all reasonable security measures are taken, manipulation, destruction, and/or loss of information is still possible. Should these cases arise, CPB Abogados will proceed in accordance with applicable regulations.

Without prejudice to the foregoing, CPB Abogados is not responsible for illegal interceptions or violations of its systems or databases by unauthorized persons, as well as the improper use of information obtained by these means, or any illegitimate interference beyond the control of CPB Abogados and for which it is not responsible.

CPB Abogados is also not liable for any damages or losses that may arise from interference, omissions, interruptions, computer viruses, telephone malfunctions, or disconnections in the operation of this electronic system due to causes beyond the control of CPB Abogados; or for delays or blockages in the use of the computer platform caused by deficiencies or overloads in the internet system or other electronic systems.

Modifications:

CPB Abogados expressly reserves the right to modify, update, or supplement this Policy at any time. Any modification, update, or addition to this Policy will be immediately published on the Website for the User's information.

Please check this Policy regularly for any changes.

Last updated: June 2025

Privacy Policy

Last updated: February 28, 2022

Carrera & Cia Sociedad Civil de Responsabilidad Limitada (“CPB Abogados”), identified with RUC N° 20461677836, with address at Ca. Monterrey N° 341, Apt. 601, district of Santiago de Surco, province and department of Lima – Peru, has a firm commitment to comply with all legal obligations applicable to it and to respect the rights of users (hereinafter, the “Users”) of the website cpb-abogados.com.pe (“Website”).

CPB Abogados understands that Users' personal data must be treated in a manner that guarantees compliance with the legal framework regarding personal data protection and, in addition, takes measures to create an environment of trust and security regarding such processing.

“Personal data” means any information that identifies or allows the identification of Users (hereinafter, “Personal Data”).

Object and scope

The purpose of this Privacy Policy is to inform Users about the use and processing of their Personal Data collected through the Website.

The processing of the Personal Data provided by the User will be carried out by CPB Abogados in strict compliance with the provisions of Law No. 29733 - Personal Data Protection Law (the "Law") and its Regulations, approved by Supreme Decree No. 003-2013-JUS (the "Regulations").

Who is responsible for the processing of users' personal data?

The party responsible for processing Users' Personal Data is Carrera & Cia Sociedad Civil de Responsabilidad Limitada, identified with RUC No. 20461677836, with registered address at Ca. Monterrey No. 341, Apt. 601, district of Santiago de Surco, province and department of Lima - Peru.

The existence of the personal database in which Users' Personal Data will be stored has been declared to the National Personal Data Protection Authority, under the name "Website Users."

The personal data bank is currently undergoing registration with the National Registry for the Protection of Personal Data.

What personal data of users is collected through the website?

In order to use the services offered through the Website, Users must provide CPB Abogados with the following information:

First and last names
Email address
Phone number
Cookies, as detailed in the corresponding cookies section

This Personal Data will be freely provided by Users when using the Website. CPB Abogados will not collect or use Users' Personal Data other than that which the User has authorized. Under no circumstances will CPB Abogados collect Users' Personal Data without their consent and/or authorization, except in cases expressly permitted by law and regulations. In any case, Users will be duly informed about the processing of their Personal Data, in accordance with applicable requirements.

Users declare that the Personal Data they provide through the Website is true and accurate, and assume responsibility for any false information they may have provided.

For what purpose will users' personal data be processed?

The Personal Data provided by Users will be processed for the purposes detailed below:

Allow the User to navigate through the Website.
Respond to any queries the User may have regarding the services provided by CPB Abogados.
Respond to any complaints that the User may submit, in accordance with applicable consumer protection regulations.
The User's Personal Data is necessary and essential to fulfill the detailed purposes, so failure to provide such Personal Data will prevent the User from enjoying the services offered through the Website.
Furthermore, Users' Personal Data may also be used for additional purposes, such as sending commercial advertising, offers, and promotions that may be of interest to them. This processing will only be carried out if the User has given their express consent, in accordance with the provisions of the Law and the Regulations.
The User will be entitled to revoke, at any time, the consent given for the processing of their Personal Data for additional purposes.
The User's Personal Data will not be used for purposes other than those mentioned above.

With whom will users' personal data be shared?

To store Users' Personal Data, CPB Abogados contracts cloud services through Qualis Technology SAC, whose physical servers are located in the United States.

CPB Abogados will not share Users' Personal Data with other third parties, except where legally required.

What is the retention period for users' personal data?

However, if the User has given their consent for the processing of their Personal Data for additional purposes, CPB Abogados may retain and use the Personal Data required for such purposes until the User revokes their consent.

Regarding the use of cookies on the Website, the retention period for these cookies will be detailed in the corresponding section.

Finally, if the User has filed a complaint in the Virtual Complaints Book of CPB Abogados, the Personal Data contained in the complaint form will be stored for a period of three (3) years, so that CPB Abogados can comply with its obligations under the regulations on consumer protection.

Exercise of user rights of access, rectification, cancellation and opposition

In order to exercise the aforementioned rights, the User may direct their request to exercise ARCO rights to the following address: mkt@cpb-abogados.com.pe.

Security measures to protect users' personal data

CPB Abogados will be responsible for the personal data banks of Website Users and Complaints Book, as well as the Personal Data of Users contained therein.

In order to prevent the loss, misuse, alteration, unauthorized access, and/or theft of the Personal Data provided by the User, CPB Abogados has adopted the levels of security and protection of personal data required by law and regulations, through the implementation of all technical means and measures at its disposal.

In this regard, CPB Abogados guarantees Users the confidentiality of the Personal Data provided, in accordance with applicable regulations regarding personal data protection.

Anti-corruption and anti-ML/FT commitment

CPB Abogados maintains its unwavering commitment to integrity, legality, and transparency in all our actions. As a law firm, we recognize our responsibility to prevent corruption, money laundering, and the financing of terrorism and other crimes. We have adopted a strict compliance policy that guides our professional and corporate conduct. This policy reflects not only compliance with current regulations but also our ethical conviction to act with integrity, promoting a culture of zero tolerance for any illicit practices.

1. OBJECTIVE

The objective of this policy is to establish the general guidelines to prevent, detect, and punish any potential act of corruption, whether public or private, money laundering, terrorism, tax and customs offenses, parallel accounting, and crimes against the cultural and paleontological heritage of Peru, as well as any other offenses incorporated by Law 30424 and its amendments – Law on Administrative Responsibility of Legal Entities.

2. RANGE

This policy applies to all current or potential employees, suppliers, clients, and members of CPB ABOGADOS' senior management, and, where applicable, to any third party contractually or commercially related or linked to the Company.

CPB ABOGADOS informs its clients, suppliers, and other stakeholders about its Anti-Corruption Policy, with the goal of ensuring that they adhere to the principles and guidelines established therein. All clients are expected to maintain a firm commitment to integrity, ethics, and the prevention of any form of corruption within their relationships with our firm.

POLICY STATEMENT

CPB ABOGADOS does not tolerate acts of corruption, money laundering, terrorist financing, or any other acts that may involve the commission of criminal offenses in its activities and relationships.
There are no valid justifications or reasons that allow us to accept conduct in which employees (regardless of their position or length of service), suppliers, current or potential clients, or members of senior management commit, participate in, contribute to, and/or have knowledge of, and fail to report and/or denounce, acts or conduct that constitute corruption, money laundering, and terrorist financing.
CPB ABOGADOS, within the framework of its commercial, contractual, and professional relationships, establishes that both the firm and its collaborators, clients, strategic partners, suppliers, and other interested parties declare and commit to the following:
- Regulatory Compliance: In the execution of legal services, procedures, or related actions, they undertake not to infringe or violate any laws, regulations, or rules in force in Peru, including—but not limited to—anti-corruption regulations, provisions on the prevention of money laundering and terrorist financing, as well as applicable international treaties.

- Lawful Origin of Funds and Prevention of Money Laundering/TF: They declare that the resources comprising their assets, as well as those used to contract and perform legal services, do not come from illicit activities such as money laundering, terrorist financing, drug trafficking, illegal fundraising, or other criminal conduct.

- Due Diligence and Prevention: They are obligated to implement reasonable and effective measures to ensure that their partners, directors, clients, suppliers, collaborators, and other related parties are not linked to illicit activities, especially those related to money laundering or terrorist financing. This includes verifying the legitimate origin of the funds and assets involved in their operations, as well as notifying the other party of any changes in this situation.

GUIDELINES

In order to fulfill the objective of this policy, CPB ABOGADOS:

It prohibits its Senior Management, collaborators in general, as well as third parties acting on its behalf or for its benefit, from carrying out any potential act of corruption, public or private, money laundering, terrorism, tax crimes, customs crimes, parallel accounting, crimes against the cultural and paleontological heritage of Peru, as well as any other that is incorporated within the scope of Law 30424 and its amendments - Law of Administrative Responsibility of the Legal Entity.

It urges its employees and third parties acting on its behalf or for its benefit to always act ethically and in compliance with applicable laws, as reflected in the clauses for the prevention of money laundering and terrorist financing incorporated into commercial and/or employment contracts.

CPB Abogados conducts due diligence actions regarding its employees and business partners in existing or planned operations or activities.

It has appointed a Compliance Officer with the authority and independence to perform his or her duties, who has sufficient resources at his or her disposal to implement and maintain the AML/TF Prevention System at CPB Abogados.

It encourages reporting in good faith or based on a reasonable belief of possible acts of public or private corruption, money laundering, terrorism, tax offenses, customs offenses, parallel accounting, crimes against Peru's cultural and paleontological heritage, as well as any other offenses included within the scope of Law 30424 and its amendments - Law on Administrative Responsibility of Legal Entities, or suspicion that one may be occurring, as well as raising concerns. These communications may be directed to the Whistleblower Channel.

It guarantees that individuals who file reports through the Reporting Channel or refuse to participate in what they consider a potential act of public or private corruption, money laundering, terrorism, tax crimes, customs crimes, parallel accounting, and crimes against Peru's cultural and paleontological heritage, as well as any other crimes included within the scope of Law 30424 and its amendments – Law on Administrative Responsibility of Legal Entities, will not suffer any harm or retaliation for doing so. It also guarantees the confidentiality and confidentiality of the identity and information provided.

5. CONSEQUENCES OF NON-COMPLIANCE

Failure to comply with this Policy will result in liability for any direct or indirect damages caused to CPB Abogados by its actions. In the case of its collaborators, CPB Abogados will act in accordance with its internal regulations, compliance policies, and the legal framework in force in Peru, assessing the appropriate disciplinary or contractual measures, civil, administrative, or criminal actions.

In the event that the breach relates to clients or suppliers, CPB ABOGADOS reserves the right to unilaterally terminate the contractual or commercial relationship, without incurring any liability for the firm.

Likewise, CPB ABOGADOS will have the right to demand compensation for any costs, damages, and losses that this situation may cause, including—but not limited to—legal, administrative, reputational, operational, and any other expenses arising from the early termination of the relationship.

Declaration on the prevention of money laundering and terrorist financing

THE PARTIES declare, in a sworn statement, that the resources comprising their assets, as well as the resources they will allocate to the development of legal services, do not come from money laundering, terrorist financing, drug trafficking, illegal fundraising, or, in general, any illicit activity.

The Parties undertake to carry out all activities aimed at ensuring that all their partners and the resources they have contributed, their directors and the decisions they make, their clients and the origin of the funds they use, their suppliers and the origin of the goods or services provided, their employees and their conduct, etc., are not related to or originate, as the case may be, from illegal activities, particularly money laundering or terrorist financing.

In any case, if during the term of the legal service provided, THE CLIENT, any of its directors or partners were to become involved in an investigation of any kind (criminal, administrative, etc.) related to illegal activities, money laundering or terrorist financing, or were included in control lists such as those of the UN, OFAC, etc., CPB ABOGADOS has the right to unilaterally terminate the service provided.

Whistleblower Channel Protocol

Object

The purpose of this Protocol is to establish an external communication channel for receiving complaints related to regulatory non-compliance and/or unethical practices related to money laundering, terrorist financing, and bribery in its various forms.

Carrera & Cia Sociedad Civil de Responsabilidad Limitada (hereinafter, “CPB Abogados”) has established a zero-tolerance policy toward any form of corruption, prohibiting any conduct that could be construed as bribery in the private or public sector, money laundering, or terrorist financing.

This Protocol is established to publicize the aforementioned reporting channel and ensure that, if a complaint is filed, it will be handled professionally and confidentially, with appropriate measures adopted to protect the interests of CPB Abogados and the complainant.

Scope

Interested parties or individuals associated with CPB Abogados, as well as clients, suppliers, and third parties, may submit complaints through the Complaints Channel.

CPB Abogados undertakes to analyze all complaints received objectively and confidentially. It will also guarantee the confidentiality of the identity of the person filing the complaint and the person(s) being reported, informing only those strictly necessary to the process.

Communication and reception

Anyone who becomes aware of an irregularity may report it via the following email address: canaldedenuncias@cpb-abogados.com.pe, to the Prevention Officer and/or certain individuals authorized by CPB Abogados.

Minimum requirements for the complaint

For a complaint to be admitted for processing and therefore investigated, it must, to the extent possible, meet the following minimum requirements:

Description of the event and/or suspicious behavior;
Possible people involved;
Dates and/or dates of the event and/or conduct;
Means in which the possible illicit conduct has been carried out;
If applicable, potential economic impact; and
Providing evidence.

Admission to process

If, after obtaining all the relevant information about the incident and/or conduct provided by the complainant, it is considered that there are reasonable indications of the existence of an action or omission contrary to the regulations, the investigation procedure will be initiated.

If the information received is insufficient or there is no clear evidence of an action or omission contrary to regulations, the complaint will be dismissed, the case will be closed, and the complainant will be notified of the reasons for the dismissal.

Whistleblower protection

CPB Abogados will ensure, to the extent possible, that no retaliation occurs against the person or persons who file complaints in good faith.

Likewise, CPB Abogados guarantees that the investigation processes will be subject to the utmost confidentiality, in order to protect the identity of the complainant, if known, as well as the identity of the accused and the facts, informing only those strictly necessary to the process.

CPB Abogados reserves the right to make any modifications to this Protocol it deems appropriate or adapt them to current regulations at any time.