Privacy Policy

Suri & Huacaya

1. DATA CONTROLLER

Suri & Huacaya, LLC. with registered offices in 222 Broadway 27th Floor, New York, NY, 10038 in its quantity as data controller (“Suri & Huacaya”). The company can be contacted at the following email address, privacy@surihuayaca.com, to inform you about the processing of personal data provided by you (“Data”) with the following modalities. 

2. Ways of Data Processing

Data is processed on paper and in electronic form in line with organizational and security requirements defined by applicable laws. 

3. Purposes of Data Processing

Suri & Huacaya, LLC. processes data (such as, name, surname, address, the details of your purchases, etc.) collected from you online through its websites for the following purposes (i) to manage the sale of our products and provide sale and after-sale services (including, fraud prevention, returns, guarantees, and customer service) and, concerning online activities, to manage the services offered by our websites, including the management of your information requests (“Contractual Purposes”); (ii) to comply with legal and regulatory obligations (“Legal Purposes”); and, with your prior consent, (iii) to send marketing communications through electronic means (including, email, SMS, MMS, mobile, social network, and instant messages) or paper means (including, traditional mail) to promote our trademarks, services, and/or products to conduct market analysis and statistics (“Marketing Purposes”) and (iv) to analyze your habits, interests, and preferences in order to offer services and send marketing communications on this basis (“Profiling Purposes”). 

Moreover, your Data related to spending volume, product category, store of purchasing and date of birth may be processed from May 25th 2018 on the basis of Suri & Huacaya legitimate interest to provide a service in line with your needs, adequately balanced with the necessity of your rights protection (“Marketing Related Legitimate Interest Purposes”). 

4. Legal Basis

Processing of Data for Contractual Purposes is mandatory since it is necessary to register, purchase products and use specific services offered by Suri & Huacaya. Processing of Data for Legal Purposes is mandatory since it is required by the applicable laws. If you do not provide Data, it would not be possible to provide the products or services provided by Suri & Huacaya that you request. Processing of Data for Marketing and Profiling Purposes is not mandatory and subject to your prior consent which, in any case, may be revoked. Processing of Data for Marketing Related Legitimate Interest is functional to the pursuit of a legitimate interest of Suri & Huacaya, properly balanced with your interests and, considering the limitation to this form of processing explained in paragraph 3.

5. Data Retention Period

Your Data is processed for no longer than is necessary to fulfill the above mentioned purposes and, for the Contractual Purposes, Data are retained for the duration of the contract (in case of an account created on the website or in relation to services provided by Suri & Huacaya) and for 10 years after the requested service. For the Legal Purposes, your Data is stored in accordance with the specific limitation periods defined by law. Data for Marketing and Profiling Purposes is stored for a period of 7 years from the last purchase completed, as per the authorization of the Federal Trade Commission (FTC) obtained by Suri & Huacaya, LLC. on February 4, 2019, and/or from the last contact with you (e.g. participation at an event, opening of a newsletter). Even Data processed for Marketing Related Legitimate Interest is retained for a period of 7 years from the last purchase completed, notwithstanding the right to object to the processing at any time. Upon expiry of the above mentioned retention periods, your Data will be automatically deleted or made anonymous in a permanent and non-reversible way. 

6. Data Communication and Transfer Abroad

For the Purposes explained in paragraph 3, Suri & Huacaya may communicate Data, strictly necessary to each purpose of processing, to the following categories of subjects: (i) employees in charge of the processing (such as the personnel of the Customer Relationship Management, IT, Retail offices); (ii) consultants and professional and technical service providers (such as IT service providers, postal offices and couriers, legal consultants, etc.), companies controlled by Suri & Huacaya, Suri & Huacaya companies in joint venture arrangements and Suri & Huacaya franchisees which may also be located in countries outside the USA as indicated on www.surihuacaya.com. Data may be transferred outside the USA. Your Data is not disseminated. 

You have the right to obtain a copy of Data held abroad outside the United States and to receive information on the place where Data is kept, by asking Suri & Huacaya directly through the contact details provided in paragraph 8 of this Privacy Policy. 

7. Data Subject’s Rights

You may always enforce your privacy rights, for example you may access the Data, verify Data content, origin, or accuracy. You may ask that Data be integrated, updated, amended, deleted, blocked for breach of law, or object to the processing of your Data for legitimate purposes. In addition to the rights above, you may ask for a restriction of the processing, for portability of the Data, or bring a claim before the FTC, if the premises subsist. 

8. Changes, Updates, and Contacts

This document will be effective from the date indicated below. Suri & Huacaya may change and/or integrate the Privacy Policy, also as a consequence of further modifications and/or integration of the United States Data Protection Laws and Regulations. Updates and modifications will be notified in advance and you will be able to view the updated Privacy Policy at  www.surihuacaya.com.

If you have doubts, questions, or complaints with regard to the collection and processing of your Data, you may contact us at the following email address: privacy@surihuacaya.com.

Last updated June 10, 2019