PERSONAL DATA PROTECTION POLICY - KUYRAPET

Code: CP-POL-001 | Version: 01 | Issue Date: 01/07/2026 | Classification: Public

I. GENERAL ASPECTS

COMSATEL PERU S.A.C. (hereinafter COMSATEL) values its users and is committed to protecting their privacy. This policy describes the processing of personal data within the framework of the relationship with KuyraPet products or services, including the use of the website https://www.kuyrapet.com.pe/ (hereinafter the website) and its respective applications (hereinafter the applications).

Within the context of Law No. 29733 (hereinafter, the Law) and Supreme Decree No. 016-2024-Jus (hereinafter, the Regulation), regulations that refer to the protection of personal data, the user expresses their free, prior, express, unequivocal, and informed consent, for an indefinite period, and as long as they do not request its cancellation or revoke this authorization, to carry out the processing of the data declared through this channel (hereinafter, the "Personal Data"), which includes the transfer of personal data in accordance with Chapter III of the Regulation. In accordance with Article 5 of the Law's Regulation, said express and unequivocal consent to the terms and conditions, and the processing of personal data provided to COMSATEL, may be given in the following ways:

Verbal: In person or telematically.

Written: By physical or electronic document with handwritten or digital signature.

Digital Channels: Through electronic means by manifesting a "click," "touch," or other similar actions.

Other Means: In accordance with Article 141 of the Civil Code.

II. PROCESSING OF PERSONAL DATA

COMSATEL, domiciled at Diego Gavilán No. 165, Magdalena, is the controller (responsible party) of the personal data collected through KuyraPet products and services, and determines the purposes and legal basis of its processing. The actual processing, hosting, and storage of such personal data are carried out through the KUYRAPET® platform and servers operated by the Manufacturer as a data processor, on behalf of and under the documented instructions of COMSATEL. The database referred to in this policy is registered with the National Authority for Personal Data Protection (ANPDP) under Registration Code: 696-2021-PJ/546-2021-PJ.The Manufacturer processes personal data solely to provide and maintain the service and is bound by the confidentiality and security obligations set out in this policy.

COMSATEL undertakes to limit access to personal data accessed by virtue of the subscription and/or execution of this agreement, to the personnel strictly necessary to fulfill the provision of services under their charge, committing to sign with its employees and third parties used for the fulfillment of its obligations arising from this agreement, a confidentiality agreement that provides, at a minimum, the same confidentiality obligations as those incumbent upon it.

In compliance with Law No. 31814, COMSATEL guarantees that the processing of personal data through Artificial Intelligence systems is carried out under the principles of security, ethics, transparency, responsibility, and human supervision, ensuring that automated decisions have validation and control mechanisms when appropriate.

III. ETHICAL USE OF DIGITAL TECHNOLOGIES AND DATA:

Public entities and private sector organizations promote and ensure the ethical use of digital technologies, the intensive use of data, such as the Internet of Things, artificial intelligence, data science, analytics, and processing of large volumes of data.

IV. PURPOSE OF PROCESSING

Your personal data will be used for the following purposes in both in-person and non-in-person channels: i) Communication: To inform by any means (telephone, email, SMS, WhatsApp, social media, or any mobile application or similar means created or to be created) about facts related to the commercial relationship: pet monitoring services sold, prices, terms, and similar data. ii) Advertising: Sending information about COMSATEL and KuyraPet products, gifts, and promotions, using the means described in subsection i). iii) Marketing: Conducting commercial reports, statistics, surveys, and market studies. iv) Verification: To validate that the information provided is correct and updated. COMSATEL may process my personal data directly or through service providers that will be considered as data processors of my personal data.

V. TRANSFER OF PERSONAL DATA

5.1. Transfer to Third Parties: I acknowledge the possibility that COMSATEL may share, assign, or transfer my personal data to third parties, under the following conditions and purposes:

Data Processors: COMSATEL may share, assign, or transfer data to third parties solely in the categories of data processors detailed in clause IX of this policy (technology, logistics, and payment gateway providers), which act under the strict instruction of COMSATEL and with the confidentiality guarantees required by law.

Commercial or Marketing Purposes: Likewise, said transfer may occur for the purpose of carrying out commercial or marketing activities, under the guarantee that COMSATEL will ensure that the data is not misused. This transfer usually occurs for purely commercial reasons with individuals and companies third to COMSATEL and its line of business, such as sales representatives, insurance companies, financial entities, vehicle marketers, which are listed at the end of this document.

No transfers to other categories of third parties will be made without the prior, express, and informed consent of the data subject. The transfer should not cause any harm to the data subject.

5.2. Right to Object: The user retains their right, with or without cause, to object to their data being disclosed to any third party, whether or not related to COMSATEL (including cases not provided for in clause IX), and must formally communicate this via email to: servicio@comsatel.com.pe.

5.3. Security in Transfer: COMSATEL adopts and shall adopt the necessary legal, technical, and organizational security measures to guarantee the security of Personal Data and prevent its alteration, loss, theft, unauthorized processing, or access, considering the state of technology, the nature of the personal data subject to commissioned processing, and the risks to which they are exposed, whether arising from human action or the physical or natural environment. For this purpose, COMSATEL expressly declares that it has implemented the security controls required by the Personal Data Protection Law and its Regulation.

5.4. Different Use: If personal data is used differently from what is indicated, COMSATEL will communicate this in advance via the email address servicio@comsatel.com.pe, so that the data subject may express their opposition to such processing if they do not agree.

5.5. COMSATEL will process the personal data that I provide to it or to which it may have access physically, orally, or electronically, through publicly accessible sources or from third parties and/or database consultation entities domiciled in Peru or abroad, whether natural or legal persons, private or public.

5.6. The refusal to provide my personal data, as well as the revocation of the consent granted for the use of my personal data, makes it impossible for COMSATEL to include them in its database that sends instant and updated information. Furthermore, upon requesting revocation, COMSATEL will remove me from its subscriber list, and I will therefore be unable to receive information or communications about different products, satisfaction surveys, service improvements, or events organized by COMSATEL or any of its departments.

5.7. You may exercise your rights of Information, Access, Rectification, Cancellation, Revocation, Opposition, etc. (ARCO rights) regarding the use of your personal data, in accordance with the Personal Data Protection Law, Law No. 29733, and its Regulation, Supreme Decree No. 016-2024-JUS. In this regard, you have the right, among others, to access your personal information, to request the rectification of inaccurate data, and to revoke your consent for its processing; likewise, you may request the deletion of your data or object to its processing, even when it is no longer necessary for the purposes that motivated its collection.

The exercise of these rights is free of charge. To do so, you can send an email to servicio@comsatel.com.pe or submit a written request to COMSATEL at the following physical address: Calle Diego Gavilán No. 165 – Magdalena del Mar – Lima – Perú, attaching a copy of your identity document (DNI/CE/Passport) that proves your ownership over the personal data for which you will exercise your right. The request will be addressed in accordance with the deadlines established in the personal data protection regulations.

5.8. We may collect your location information through GPS coordinates (e.g., latitude/longitude) available through your mobile device via our applications, if you have them installed. We may also collect information about your location using other technologies and sensors that may provide us with such information. Likewise, in the case of services that include mobile video systems, images, recordings, and events associated with the vehicle's operation may be captured through video technologies (such as DMS, ADAS, or others applicable according to the contracted service).

COMSATEL may use technological platforms, cloud infrastructure, and third-party services for the provision of certain functionalities associated with video, monitoring, telemetry, and information storage, ensuring that said providers implement adequate technical, organizational, and security measures for the protection of personal data, in accordance with current regulations and international information security standards, such as ISO/IEC 27001 certifications or applicable equivalents.

5.9. The use of the information is strictly limited to the functionalities inherent to the applications and the generation of information for the user, or in accordance with the authorization granted by the user. The information is used to:

i) track your location and movements;

ii) monitor aggregated metrics for the user to analyze;

iii) generate alerts and security events; and

iv) diagnose and resolve issues associated with the service.

Any matter not specifically addressed in this document is governed in accordance with the Data Protection regulations established by Law No. 29733 and its Regulation, Supreme Decree No. 016-2024-JUS.

VI. CONSEQUENCES OF REFUSAL OR REVOCATION

Refusal to provide data or revocation of consent makes it impossible for COMSATEL to include them in the updated information database. If revocation is requested, the user will be removed from the subscriber list and will stop receiving information about KuyraPet products, surveys, and events.

VII. ARCO RIGHTS

You may exercise your rights of Access, Rectification, Cancellation, and Opposition (ARCO rights) free of charge:

Electronically: By writing to servicio@comsatel.com.pe.

Physically: By sending a written request to Calle Diego Gavilán No. 165, Magdalena del Mar, Lima, attaching a copy of your identity document (DNI/CE/Passport).

VIII. SENSITIVE DATA AND LOCATION

8.1. Sensitive Data: For the use of sensitive data (biometric, health, etc.), COMSATEL will require express written consent.

8.2. Location Information (GPS): We collect GPS coordinates and sensor data through the applications to:

i) Track the pet's location and movements.

ii) Monitor aggregated metrics for owner analysis.

iii) Diagnose and resolve service issues. This information is stored securely and used exclusively for the application's functionalities, without being shared with third parties for commercial use unrelated to the service.

IX. MODIFICATIONS AND CONTACT

COMSATEL reserves the right to modify this policy to adapt it to regulatory changes or service improvements. Changes will be published on the website, and continued use of the services after publication will imply acceptance of the new policy. For inquiries, contact servicio@comsatel.com.pe.

X. RECIPIENTS AND DATA PROCESSORS

In accordance with Section IV of this policy, the user authorizes the transfer and/or access to their personal data to the following categories of third-party companies that act as data processors under the strict instruction of COMSATEL:

a) Technology and Platform Service Providers: The Manufacturer provides cloud infrastructure, hosting, data storage, Customer Relationship Management (CRM) systems, internal management platforms or similar, mobile application support, and software licenses, which act as data processors to guarantee the correct execution, technical maintenance, security, administrative management, and support of the KuyraPet applications. These services are executed in virtual environments protected by strict confidentiality contracts and technical security measures aligned with the requirements of D.S. No. 016-2024-JUS, guaranteeing that the information is used solely and exclusively to ensure the stability, updating, attention, and technical support of the platform. Accordingly, these providers are expressly prohibited from using any personal data for their own, commercial purposes, or for purposes other than the strict purposes and instructions dictated by COMSATEL.

b)  International Transfer of Personal Data: Personal data collected through the KuyraPet service may be transferred to, stored in, and processed in jurisdictions outside the Republic of Peru, including by the Manufacturer that operates the KuyraPet platform and servers. Any such international transfer is carried out under appropriate safeguards, in particular a data processing agreement between COMSATEL and the Manufacturer incorporating the confidentiality, security, and use-limitation obligations required by Law No. 29733 and its Regulation, so that the personal data receives a level of protection equivalent to that established under Peruvian law.

c) Payment Gateway and Financial Service Providers: Certified companies that process payment transactions for subscriptions. COMSATEL does not store or directly manage credit or debit card data; such data is captured and processed directly by these providers in their own secure environments, complying with respective international security standards and current regulations.

All the mentioned companies act solely on behalf and by order of COMSATEL, complying with the technical and organizational guarantees required by Law No. 29733 - Personal Data Protection Law and its Regulation approved by Supreme Decree No. 016-2024-JUS. The contracts signed with said processors include confidentiality clauses and a prohibition on using the data for purposes other than those agreed upon. COMSATEL guarantees strict compliance with current regulations by all its suppliers, which are backed by international standards.

For more information about the processing of your personal data or to exercise your rights of access, rectification, cancellation, or opposition (ARCO rights), the CLIENT may contact our Customer Service area through the email address servicio@comsatel.com.pe or through our telephone exchange (01) 513-5111 option 4-4. Your request will be internally forwarded to the responsible area for attention within the deadlines established by law.