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Privacy Notice
Privacy and Confidentiality

Privacy Notice

Last updated: May 19, 2026

Contents

Introduction 1. Regulatory Framework 2. Data Processing Controller 3. Data We Collect 4. Purpose of Processing 5. Legal Basis 6. Retention Period 7. Cross-Border Flow 8. Security Measures 9. ARCO Rights 10. Notice Modifications
Privacy Channel

Write to us directly to resolve any concerns about the protection of your information.

info@comafra.net

COMAFRA INTERNATIONAL GROUP (hereinafter, 'the Company', 'we', 'our' or 'COMAFRA INTERNATIONAL GROUP'), with official contact channels through info@comafra.net and phone +1 305 572 8196, recognizes the fundamental importance of privacy, security and protection of personal data of users (hereinafter, 'the User' or 'you') who visit and interact with our institutional website.

This Privacy Notice describes transparently and in detail how we collect, store, process, protect and transfer the personal data you provide. By checking the mandatory acceptance box in our forms and sending us your information, you give your prior, informed, express and unequivocal consent for the processing of your data under the conditions set forth herein.

1

Regulatory Framework and Applicable Jurisdiction

COMAFRA INTERNATIONAL GROUP operates globally with a central administration and technology headquarters regulated under the laws of the United States of America. Consequently, this Notice is governed primarily by the privacy protection legal framework of the State of Florida, USA.

However, due to our physical and operational presence in Latin America, this document adopts and rigorously complies with the data protection principles established in:

  • Peru: Law No. 29733 (Personal Data Protection Law) and its Regulations (Supreme Decree No. 003-2013-JUS).
  • Ecuador: Organic Law on Personal Data Protection (LOPDP).
2

Data Processing Controller

The legal controller of personal data collected through this website is the main corporate entity of COMAFRA INTERNATIONAL GROUP, coordinated operationally across its three main nodes: Miami (USA), Lima (Peru) and Guayaquil (Ecuador).

For any matter related to the management of your data, the exercise of your rights or information security, the User can contact directly through:

Email
info@comafra.net
Global Phone
+1 305 572 8196
3

Personal Data We Collect

COMAFRA INTERNATIONAL GROUP operates a strictly informational and corporate website. We do not request or store sensitive data (such as sexual orientation, religion, health data, political opinions or criminal records), nor do we require the creation of user accounts, logins or credit/debit card data on this portal.

Voluntary Collection

The only personal data we collect is that which the User voluntarily enters in our Contact Form or by writing directly to our institutional emails, which includes:

Full name (First and Last Names)
Email (Personal or Corporate)
Phone (Mobile or Landline, with country code)
Company or organization name
Country or city of residence
Message or inquiry details
4

Purpose of Data Processing

Personal data provided by the User will be processed solely and exclusively for the following legitimate and specific purposes:

4.1 Primary Purposes (Necessary for attention)

  • Query and Request Management: Attend, process and respond to information requests, doubts or quotes about our Premium Consulting, Market Intelligence, Customs Management and Custom Software Development services.
  • Requested Commercial Prospecting: Evaluate the User's business profile to structure personalized commercial proposals for internationalization or demonstrations of our systems (such as the E-commerce Platform or FACTAURUS System).
  • Establishment of Communication Channels: Contact the User via phone, email or instant messaging (if authorized) to follow up on their corporate request.

4.2 Secondary Purposes (Optional)

  • Update Communications: Send informational newsletters, global market analysis, customs regulation alerts or news about our technological tools.
The User may object at any time to the sending of these secondary communications without this affecting the attention of their main inquiry.
5

Legal Basis for Processing

In accordance with current international regulations, COMAFRA INTERNATIONAL GROUP processes your personal data based on the following legal grounds:

  • Consent of the Data Subject: By completing the contact form and clicking the mandatory acceptance box of this Privacy Notice, the User grants unequivocal authorization for us to process their data in order to respond to their message.
  • Pre-contractual Measures: Data processing is necessary for the structuring and sending of a commercial or technical proposal formally requested by the User before signing a definitive service contract.
6

Data Retention Period

Collected personal data will be kept in our databases only for the period reasonably necessary to fulfill the purpose for which they were collected:

  • If the inquiry does not result in a commercial or contractual relationship, data will be securely deleted or anonymized within a maximum of twenty-four (24) months from the last contact.
  • If the User exercises their right to deletion or revocation of consent, data will be immediately deleted from our active systems, unless there is a legal or regulatory international obligation (for example, in tax or customs matters in the USA, Peru or Ecuador) that requires their blocked retention for an additional period.
7

Data Transfer and Cross-Border Flow

As COMAFRA INTERNATIONAL GROUP is a cross-border organization with integrated operations in Miami, Lima and Guayaquil, personal data collected through the web may be subject to Cross-Border Data Flow.

  • Between COMAFRA INTERNATIONAL GROUP Offices: Form data may be shared internally and securely among our consultants in the USA, Peru or Ecuador so that the specialist assigned to your region or service type properly attends your request.
  • Technology Service Providers: COMAFRA INTERNATIONAL GROUP does not sell, rent or commercialize your personal data with third-party companies. However, for web operability, we use cloud storage servers, hosting services and email management tools (CRM or massive cloud infrastructure providers) located primarily in the United States, which operate under strict digital security standards (such as data encryption and confidentiality policies).
8

Information Security Measures

COMAFRA INTERNATIONAL GROUP adopts rigorous technical, organizational, administrative and legal measures to safeguard the confidentiality, integrity and availability of your personal data, preventing their alteration, loss, theft, access or unauthorized processing.

These measures include, among others:

  • Use of secure data transfer protocols (SSL/TLS Encryption) across our entire website.
  • Restricted access to personal data within COMAFRA INTERNATIONAL GROUP, allowing access only to authorized personnel who strictly require the information to respond to the User.
  • Constant monitoring of our servers to prevent cybersecurity incidents or unauthorized access.
9

Exercise of Rights (ARCO Rights)

In accordance with data protection laws of the USA, Peru and Ecuador, the User is the owner of their personal data and has the right to control their use at any time. You may exercise your rights free of charge, traditionally known as ARCO Rights:

Access

Right to know whether COMAFRA INTERNATIONAL GROUP is processing your personal data and to obtain information about the origin, use and destination thereof.

Rectification

Right to request correction or updating of your data if it is inaccurate, incomplete or outdated.

Cancellation / Deletion

Right to request that we definitively delete your personal data from our databases when you revoke your consent.

Objection

Right to refuse the processing of your data for specific purposes (such as advertising or secondary information).

Procedure to exercise your rights

To exercise any of these rights, the User must send a formal written request to info@comafra.net including:

  1. Email subject: "Exercise of Personal Data Rights - [Your Name]".
  2. Clear description of the right you wish to exercise (e.g., I request the deletion of my contact data sent via the form).
  3. Evidence or data that allows verification of your identity as the owner of the email from which the request is sent.

COMAFRA INTERNATIONAL GROUP will respond to your request within the legally established timeframes by the corresponding data protection authorities according to the country of origin of the inquiry.

10

Modifications to the Privacy Notice

COMAFRA INTERNATIONAL GROUP reserves the right to modify or update this Privacy Notice in whole or in part at any time, in order to adapt it to federal legislative changes in the United States or regulatory reforms in Peru and Ecuador, as well as to the Company's own internal practices. Any substantial change will be published and made available through this same web page with the corresponding update date. Continued use of the website and submission of forms after the publication of changes implies acceptance of the new Privacy Notice.