Privacy policy

Objective

The personal data privacy policy (hereinafter “privacy policy”) aims to inform you about how LUCIDA—with its registered address at Calle Monte Rosa 255, 4.° piso, Santiago de Surco, Lima, Peru—processes your personal data. This data is collected through various means such as our website, electronic forms, applications, questionnaires, written or verbal consents, phone calls, video calls, and any other communication medium that refers to this privacy policy.

The term “user” refers to any individual who requests, shows interest in LUCIDA’s services, or has had contact with LUCIDA or its business partners.

At LUCIDA, we ensure the security and protection of our users’ personal data. Please read this privacy policy before providing us with your personal data. You can choose to accept or decline the processing of your personal data. However, if you choose to decline, we will not be able to fulfil the purposes described in section 6. Similarly, the data requested in our forms and questionnaires is essential to address your requests and deliver our services, provided you have been informed of this.

Scope and retention period

This privacy policy applies to personal data banks under LUCIDA’s ownership and the processing of all personal and sensitive data provided by users. This data will not be retained longer than necessary and will be deleted upon the data owner's request, in compliance with the law and applicable regulations.

Regulatory framework and guiding principles

This policy is grounded in the Peruvian legislation, specifically:

Law No. 29733, the Personal Data Protection Law (hereinafter “law”).
Supreme Decree No. 003-2013-JUS, which approves the Regulation of Law No. 29733 (hereinafter “regulation”).
The Information Security Directive, approved by Directorial Resolution No. 019-2013-JUS/DGPDP (hereinafter “directive”).
Law No. 29571, the Consumer Protection and Defence Code.

LUCIDA created its privacy policy in alignment with the guiding principles set out in the aforementioned law and the regulation. Consequently:

In line with the principle of legality, LUCIDA refrains from collecting our users’ personal data through fraudulent, unfair, or illicit means.

Consistent with the principle of consent, the processing of our users’ personal data will be contingent upon their explicit authorisation.
Our users’ personal data is amassed for a specific and lawful intent. It will not be utilised for objectives other than those explicitly defined at the point of collection, barring instances of historical, statistical, or scientific endeavours when a dissociation or anonymisation procedure is employed.
All processing of personal data will be pertinent, relevant, and not excessive in relation to the purpose for which they were amassed.
The personal data under processing will be precise, truthful, and updated to the greatest extent feasible concerning the purpose for which they were amassed. They will be preserved in a manner that ensures its security and solely for the duration necessary to meet the processing's objective.
LUCIDA, along with any processing supervisors, if applicable, implement the required technical, organisational, and legal measures to ensure the security and confidentiality of personal data. LUCIDA maintains suitable security measures consistent with the nature of the processing and the category of personal data in question.
LUCIDA ensures an adequate level of protection for personal data in cross-border flows, providing, at the very least, a safeguard comparable to that outlined by the law and regulation.

Definition of personal data

The law and regulation define personal data as any numerical, alphabetical, graphical, photographic, acoustic information, personal habits, or any other type of information concerning natural persons that either identifies them or makes them identifiable through means that can be reasonably used.

LUCIDA’s data banks

A personal data bank refers to an organised collection of personal data, whether automated or not, irrespective of the medium—be it physical, magnetic, digital, optical, or any other. This applies regardless of the standard or method of its creation, formation, storage, organisation, and access.

In strict adherence to the law and its associated regulations, LUCIDA’s data banks, which contain users’ personal data, are registered with the National Personal Data Protection Registry. Your personal data will be incorporated into a data bank named “Usuarios” owned by LUCIDA. By accepting this privacy policy, the user explicitly consents to the inclusion of their personal data in the “Usuarios” data bank under LUCIDA’s ownership.

Use of user information

We utilise the users’ personal data for the following purposes:

Managing the contractual relationship with LUCIDA: This includes processing and attending to reservation requests, admissions, and registrations; addressing subscription requests to services or activities offered by LUCIDA or its associates; recommending the appropriate treatment or work plan, if applicable; monitoring treatments or work plans both in person and remotely; offering teleconsultation and teleorientation services; executing administrative tasks related to the services provided to the user; supporting the user; validating the accuracy of the information they provide; creating anonymised or dissociated statistical reports; reminding users of upcoming appointments or other related matters; and addressing any questions or concerns the user might have. All these are carried out in alignment with the prevailing legal framework.

Addressing queries, complaints, and suggestions: This may involve sending estimates, contracts, or payment receipts upon the user's request, or facilitating contact between the user and a sales executive.

User registration management: We manage user registrations on our web platforms and applications for various activities they might request, such as booking appointments or receiving reports.

User satisfaction assessment: We aim to gauge the user's satisfaction with the services they've availed. This involves sending out satisfaction surveys and emails about our website or applications, but only if the user has explicitly given their consent for such communications.

Academic use of image and voice: With the user's explicit consent, we may record and use their image and voice strictly for academic purposes when applicable.

Sending information: To send information related to the benefits the user receives as part of the contracted services. Also, to send information about the services offered by LUCIDA, informational material, educational content, and relevant offers, provided the user has explicitly given their consent for this activity.

Service feedback: To identify, through surveys and other tools, indicators related to the services contracted by the user and to send relevant educational information about them.

Data transfer to authorities: To transfer personal data to public authorities when required and in accordance with current legislation.

Anonymised information: LUCIDA may process anonymised information for scientific research purposes. This information, according to the law, is not classified as personal data as it neither identifies nor makes the user identifiable.

Identity verification: Users are informed that, for accreditation purposes and to prevent impersonation by third parties, their image may be processed to validate their identity conclusively.

Data validation: The data provided by the user will be validated and updated by LUCIDA with any other data from legally constituted public access sources, in accordance with the Law and additional current regulations on the matter. This data will be incorporated into LUCIDA's databases.

Data storage with Google Inc.: LUCIDA contracts the services of Google Inc., whose servers are located in the United States of America, for the storage of personal data in the cloud.

By accepting this privacy policy, the user confirms they are informed of the above purposes and gives their explicit, prior, free, clear, unequivocal, and voluntary consent for the processing of their personal data and for the inclusion of their information in LUCIDA’s data bank. Similarly, the user declares that the personal data they have provided through the forms available on any of LUCIDA’s web pages or applications, or through any other oral or written means, including forms, phone calls, or video calls, are true, accurate, complete, and up-to-date.

It's important to note that by clicking on links on our website or applications, users may be redirected to other sites outside our website. LUCIDA is not responsible for the privacy practices of other websites or applications, so we recommend that users read their respective privacy policies.

User information safeguard

LUCIDA implements the necessary security measures to ensure the protection of user information to prevent its alteration, loss, processing, or unauthorised access, taking into consideration the nature of the information and the risks to which they are exposed. To protect the user’s personal data, we strictly comply with the law and regulations.

Disclosure

LUCIDA commits not to disclose or share the user’s personal data without their proper consent, except in the following cases:

Information requests from public authorities in the exercise of their functions and within their competencies.
Information requests by court orders.
Information requests under legal provisions.

LUCIDA’s website may use cookies, small text files that websites store on your computer, smartphone, tablet, or any other internet access device. Cookies help recognise users’ devices when they revisit the website, making it easier to use and remembering their preferences and browsing settings (e.g., language, country, etc.). Cookies can’t harm your device and help improve the services we offer, allowing us to collect statistical information that helps us understand how users use our website and therefore improve its structure and content. Some cookies are strictly necessary for the website to function correctly, and others serve to improve performance and user experience on LUCIDA’s websites.

The cookies we use at LUCIDA exclusively use anonymised information; that is, information that neither identifies nor makes users of our platforms or websites identifiable, so they are not considered personal data under the provisions contained in the law and other regulations on the matter. If there are links or hyperlinks on the website that redirect to other websites owned by third parties, LUCIDA is not responsible for the use of cookies by them.

Exercise of rights

Users can exercise their rights of access, rectification, opposition, cancellation, and other rights enshrined in the law and its regulations by sending a request to contact@thinklucida.com. Notwithstanding the above, LUCIDA may retain certain user information requesting deregistration to serve as evidence in the event of a claim against LUCIDA for liabilities arising from the service provided or the processing of such information. The duration of such retention may not exceed the legal statute of limitations for such liabilities.

Users can, at any time, limit the use or transfer of their data by informing via an email to contact@thinklucida.com. However, this may prevent LUCIDA from providing certain services to that user. If they believe their rights have not been addressed, users can file a complaint with the National Personal Data Protection Authority.

Age of consent

The law indicates that users must be at least fourteen years old to provide their consent for personal data management. To provide personal data and give consent for personal data management to LUCIDA validly, the user declares they are at least fourteen years old or are the guardian of a minor. LUCIDA will not process personal data related to minors unless they have the proper consent in accordance with the applicable standard. If it is discovered that personal data of minors has been collected without the proper consent of the legal guardian, appropriate measures will be taken to delete them.

Modifications to LUCIDA’s privacy policy

LUCIDA reserves the right to modify, update, or complete this privacy policy at any time. Any modification, update, or expansion made to the privacy policy will be immediately published on the website, so the user will be aware of what information we collect and how and under what circumstances we use and process their information.

Last revised: October 2023

Privacy policy

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