Privacy Policy

PURPOSE

This Privacy and Personal Data Protection Policy (hereinafter, the “Policy”) is intended to inform, in a clear, transparent, and accessible manner, how personal data accessed in the course of its business and technological activities related to the mining sector is collected, used, stored, retained, shared, and protected.

MS4M S.A.C., identified with Taxpayer Registry No. (RUC) 20570512481, with domicile at Calle Los Halcones 484, district of Surquillo, Lima, Peru, together with its affiliates (hereinafter, “MS4M“, “we”, “our”, or the “Company”), recognizes the importance of the privacy and protection of the personal data of its users, suppliers, employees, contractors, and other persons with whom it maintains commercial or contractual relationships.

MS4M carries out its activities in accordance with the principles and provisions established in the applicable personal data protection regulations, including Law No. 29733 and its Regulations approved by Supreme Decree No. 016-2024-JUS, as well as with internationally recognized principles regarding privacy and information security applicable to business operations and technological services.

SCOPE

This Policy applies to all personal data banks owned or managed by MS4M, as well as to the websites, platforms, technological solutions, applications, services, and digital tools managed by MS4M that expressly refer to this Policy.

We recommend that you carefully review the privacy policies of any third-party website you visit.

1. PURPOSES OF PROCESSING
How long will my personal information be retained?

MS4M collects and processes personal data for the following purposes:

1.1 Necessary Purposes
  • Manage contractual relationships with clients, suppliers, and employees.
  • Provide technological services for the mining sector and ensure the functionality and performance of MS4M products and websites.
  • Manage technical support requests and incidents.
  • Manage user access to platforms and systems.
  • Carry out billing, collection, and tax compliance processes.
  • Manage personnel selection and human resources processes.
  • Manage physical security and video surveillance systems.
  • Comply with legal, regulatory, and contractual obligations.
  • Prevent fraud, security incidents, and unauthorized access.
1.2 Additional Purposes

Subject to applicable regulations and, where appropriate, to the consent of the data subject:

  • Send communications and invitations to corporate events.
  • Conduct satisfaction surveys.
  • Share news, updates, and information related to our services.

The processing of personal data is carried out in accordance with the principles of purpose, proportionality, legality, and transparency.

2. PERSONAL DATA BANKS

Personal data will be stored in data banks owned or managed by MS4M, duly registered or in the process of registration with the competent personal data protection authority, where applicable.

MS4M may process personal data in the following data banks:

  • Users.
  • Applicants.
  • Employees.
  • Suppliers.
  • Video surveillance
  • Images and voice
3. SHARING OF PERSONAL DATA AND INTERNATIONAL TRANSFERS

MS4M does not carry out international transfers of personal data for commercial purposes. However, some of the data we collect and process may be stored on servers located outside the country through cloud services, such as Microsoft Azure, GitHub, and other technology providers.

Likewise, MS4M may share personal data with third parties when necessary to fulfill the purposes described in this Policy.

a) Data Processors and Service Providers
  • Technology infrastructure providers.
  • Cloud storage providers.
  • Technical support and maintenance providers.
  • Cybersecurity service providers.
  • Enterprise and collaboration platform providers.
  • Hosting and software development providers.
b) Authorized Third Parties
  • Administrative, judicial, or regulatory authorities.
  • Affiliated companies or technology partners.
  • External auditors or advisors.

Any transfer, communication, or access to personal data is carried out under appropriate contractual, organizational, and security measures, and solely for the purposes for which the data was collected.

4. DATA RETENTION

MS4M will retain information, including personal data, only for as long as necessary to fulfill legitimate business purposes, legal obligations, contractual requirements, or other legitimate reasons. Once such purposes have been fulfilled, personal data will be securely deleted, anonymized, or blocked.

We may retain personal information as long as any of the following circumstances applies:

  • A current contractual or commercial relationship exists.
  • The information is necessary to provide services or technical support.
  • It is necessary to comply with legal, tax, accounting, regulatory, or audit obligations.
  • The information is necessary for the exercise or defense of rights in administrative, arbitration, or judicial proceedings.
5. SECURITY MEASURES

MS4M implements reasonable technical, organizational, and legal measures to protect personal data against unauthorized access, alteration, disclosure, loss, destruction, or misuse.

These measures may include:

  • Access controls and authentication mechanisms.
  • Encryption of sensitive information.
  • Cybersecurity monitoring and controls.
  • Information backup and recovery procedures.
  • Confidentiality obligations and contractual safeguards.
  • Internal privacy and information security training programs.

When we share information with third parties, we adopt reasonable measures to contractually require such third parties to protect and process personal data responsibly.

Nevertheless, no website, computer system, or electronic transmission can guarantee absolute security. Therefore, although we make reasonable efforts to protect the information, MS4M cannot guarantee 100% security.

6. COOKIES AND SIMILAR TECHNOLOGIES

The websites of MS4M use only essential cookies necessary for the correct functioning and security of the website.

MS4M does not use cookies for behavioral advertising, invasive profiling, or unauthorized tracking mechanisms.

7. RIGHTS OF DATA SUBJECTS

Subject to applicable regulations, data subjects may exercise the following rights:

  • Right of Access: Obtain confirmation of the processing of their personal data and access it.
  • Right of Rectification: Request the correction or updating of inaccurate, incomplete, or outdated data.
  • Right to Object: Object to the processing of their personal data in certain circumstances provided by law.
  • Right to Cancellation or Erasure: Request the deletion of their personal data where legally applicable.
  • Right to Data Portability: Request and receive the personal data provided to an organization in a structured, commonly used, and machine-readable format, where applicable under current regulations.

To exercise these rights, the data subject may submit a request through:

Email: privacy@ms4m.com
 Subject: “REQUEST TO EXERCISE PERSONAL DATA RIGHTS – [RIGHT REQUESTED]”

The request must include:

  • Full name of the data subject.
  • Identity document or equivalent means to verify identity.
  • A clear description of the request.
  • Supporting documentation, where applicable.

MS4M may adopt reasonable measures to verify the identity of the requester before granting access to personal data or attending to any request.

8. CONTACT INFORMATION

For any inquiries related to this Privacy Policy or the processing of personal data, you may contact:

MS4M S.A.C.
 Calle Los Halcones 484, Surquillo, Lima, Peru
 Email: privacy@ms4m.com

MS4M will review and address the requests received in accordance with the applicable personal data protection regulations and the corresponding privacy standards.

Personal Data Officer: Juan Antonio Ñahue Gaona- jnahue2505@gmail.com.

MS4M S.A.C. is a socially responsible Peruvian company that provides high-quality integrated technological solutions for mining operations. With a presence in both national and international markets, we are committed to establishing, implementing, and continuously improving our Integrated Management System for Quality and Information Security.

In line with our vision to be a global benchmark in mining operational technology solutions, we commit to:

  1. Providing high-quality technological solutions for the mining industry, ensuring that our processes are carried out under strict quality and information security conditions. We promote a culture of prevention and fulfillment of the needs and expectations of our clients and stakeholders (both internal and external), as well as compliance with all requirements applicable to the Integrated Management System.
  2. Preserving the confidentiality, integrity, and availability of information against deliberate or accidental internal and external threats. We ensure response capabilities in emergency situations and the restoration of critical services in the shortest possible time.
  3. Providing the necessary resources to ensure the fulfillment of objectives and the implementation of control measures to prevent risks from materializing while fostering a culture of continuous improvement in the effectiveness of the Integrated Management System.
  4. Complying with current contractual, regulatory, and legal requirements applicable to the Integrated Management System.

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