PERSONAL DATA PRIVACY POLICY

 

The main purpose of this Privacy Policy (hereinafter, the ‘Policy’) is to inform users (hereinafter, the ‘Website Users’) of the website https://www.libredu.com/ (hereinafter, the ‘Website’) about the processing of their personal data (hereinafter, the ‘Personal Data’).

 

Furthermore, the Policy details the processing of Personal Data of students, students' legal representatives, and teachers (hereinafter, the “Platform Users”) on the educational platform (hereinafter, the “Platform”), accessible from the Website via the “Login” button: https://learn.libredu.com/login.

 

The Users of the Website and the Users of the Platform may be collectively referred to as the Users. 

 

The owner of the Website and the Platform is LIBREDU S.A.C. (hereinafter ‘LIBREDU’), with R.U.C. N° 20613000501, domiciled at Cal. German Schereiber No. 276, Urbanización Santa Ana, district of San Isidro, province and department of Lima. The processing of Personal Data complies with all the provisions contained in the Personal Data Protection Law - Law No. 29733, its Regulations and complementary rules (hereinafter ‘the Law’).

 

 

1. ABOUT LIBREDU'S ACTIVITIES

LIBREDU is a Peruvian company dedicated to the development, implementation and maintenance of educational technology solutions.

 

LIBREDU is the owner of the Website, through which Website Users can access information about the Platform, learn about the services and products offered by LIBREDU, subscribe to its newsletter, submit claims and complaints, and consult this Policy. 

 

LIBREDU also holds the rights to use the Platform, a cloud-based educational software (SaaS) that allows educational institutions and publishers (hereinafter, the ‘Clients’) to digitize and distribute educational content, such as books in PDF format and multimedia resources, for the benefit of the Platform's Users. The Platform has been developed by Explico Pte Ltd., a company with registered office at 613B Bedok Reservoir Road, #05-1384, Eunos Grove, Singapore 476213, identified by UEN: 201926646N (hereinafter referred to as ‘EXPLICO’).

 

Users of the Platform may access the Platform from the Website by clicking on the ‘Login’ button. To do so, they must create an account by providing their Personal Data and entering the code assigned by the Clients. Accounts of underage students must be created by their legal representatives, in accordance with the relevant regulations. 

 

2. PURPOSE OF THE PERSONAL DATA REQUESTED

1. NECESSARY PURPOSES

LIBREDU collects and uses Users' Personal Data for the following purposes:

For Users of the Website:

• To deal with and respond to requests, complaints and claims submitted through the Website.
• Contact Users of the Website to provide them with information about the products and services offered by LIBREDU.
• To meet the requirements of competent authorities and comply with current Peruvian regulations.

 

For Platform Users:

• Register and manage the accounts necessary to access the Platform. Student accounts may only be created by their legal representative.
• Provide technical assistance and resolve incidents related to the use of the Platform.
• Deal with requests, complaints and claims.
• Ensure compliance with contractual obligations with Customers.
• To meet the requirements of competent authorities and comply with current Peruvian regulations.

 

The processing of Personal Data of Users is necessary and indispensable to comply with the purposes detailed above, therefore, the refusal to provide such Personal Data could prevent you from enjoying the services provided through the Website and the Platform as appropriate, and the proper use of its functions.

 

2. ADDITIONAL PURPOSES

 

On the other hand, Users' Personal Data may be used for the additional purposes detailed below. 

 

This processing will only be carried out if the Website Users, student representatives and teachers have given their express, free, prior and unequivocal consent to do so, in accordance with the provisions of the Law:

 

• For the promotion of LIBREDU products and services.
• For commercial purposes related to LIBREDU's products and services.

 

It is expressly stated that LIBREDU recognises the right of Users to express their refusal regarding the use and processing of their Personal Data, when they consider that the information provided does not fulfil any of the functions described above, or if the data provided is not necessary for the establishment of a contractual relationship. This is without prejudice to the right of revocation of consent previously granted by the Users, or to exercise their right to oppose the use of their data in terms of the applicable provisions, rights which in any case will be guaranteed by the company at all times.

 

 

3. COLLECTION AND PROCESSING OF PERSONAL DATA

 

LIBREDU may obtain information about Users by any means permitted by law, including, but not limited to, obtaining it personally or through the Website and the Platform as appropriate. 

 

Users expressly authorise LIBREDU and its authorised administrative staff to process the information provided in accordance with the provisions of current legislation. The processing of students' Personal Data is expressly authorised by their legal representatives. LIBREDU undertakes to process and protect such data by means of digital, technical and administrative measures, guaranteeing an optimal level of security.

 

LIBREDU is responsible for keeping the information provided by Users with absolute reserve and confidentiality, undertaking to adopt all necessary control and security measures to prevent alteration, use, unauthorised processing, loss and/or access by unauthorised third parties.

 

Users expressly declare that all information made available to LIBREDU is accurate, true and provided in good faith, expressly releasing LIBREDU by this act of any liability in connection with the accuracy of such information.

 

None of the data requested and collected by LIBREDU from Users is considered within the definition of ‘sensitive data’ as established by the Personal Data Protection Act.

 

 

4. PROCESSING OF MINORS' DATA 

 

The data of minors will only be used for the following purposes:

• Registering and administering accounts on the Educational Platform.
• To provide technical assistance and resolve incidents related to the use of the Platform.

 

The Personal Data of minors under 14 years of age will only be processed when the parent, guardian or legal representative has given their express, prior, free and informed consent. 

 

Users over 14 years of age may provide their consent for the processing of their Personal Data, provided that the information provided is clear and understandable for their age. 

 

Limitations on processing: The Personal Data of minors will not be used for advertising or commercial purposes, except with the express consent of the parent or guardian in the case of minors under 14 years of age, or of the user himself/herself if he/she is over 14 years of age.

 

Under no circumstances will the processing of data allow access to age-restricted activities, goods or services.

5. AUTOMATED DECISIONS AND PROFILING

 

LIBREDU informs Users that no automated decisions are made, including profiling, which may produce legal effects on Users or affect them significantly.

 

The processing of Personal Data is carried out exclusively with human intervention and for the purpose of fulfilling the purposes described in this Privacy Policy, guaranteeing respect for the rights of Users and transparency in the use of their information.

 

In the event that in the future LIBREDU implements automated decision-making or profiling mechanisms, Users will be informed in advance of their existence, the specific purposes of such processing and the consequences that it could generate.

 

 

6. PERSONAL DATA BANKS

 

Personal Data collected by LIBREDU through the Website and the Platform shall be diligently stored in the following Personal Data Banks owned by LIBREDU on a case-by-case basis:

 

1. Students
2. Teachers
3. Website Users
4. Enquiries, Complaints and Requests

 

These databases are currently in the process of registration with the National Authority for the Protection of Personal Data, which will be processed in compliance with the provisions of current legislation. 

 

 

7. FOR THE EXERCISE OF THE RIGHTS CONTAINED IN THE PERSONAL DATA PROTECTION LAW

 

As the owner of Personal Data, Users have the right to access their data held by LIBREDU; to know the characteristics of their treatment, rectify or update them if they are inaccurate or incomplete; request their deletion or cancellation when considered unnecessary for the purposes previously stated or to oppose their treatment for specific purposes.

 

LIBREDU acknowledges that Users may at any time revoke the consent expressly granted, as well as limit the use or disclosure of their personal data. Users may exercise directly or through a legal representative, their rights of ACCESS, RECTIFICATION, CANCELLATION, OPPOSITION, REVOCATION OF CONSENT AND / OR PORTABILITY on the use of their Personal Data by addressing their request with the requirements requested in the Personal Data Protection Regulations, and other applicable rules in the following physical address: Cal. German Schereiber Nro. 276, Urbanización Santa Ana, district of San Isidro, province and department of Lima or to the following email: contacto@libredu.com 

 

If the User considers that he/she has not been properly attended to in the exercise of his/her ARCO rights by LIBREDU, he/she may file a complaint with the National Authority for the Protection of Personal Data, by contacting the Mesa de Partes of the Ministry of Justice and Human Rights: Ca. Scipión Llona 350, Miraflores.

 

 

8. TRANSFER OF PERSONAL DATA BY LIBREDU

 

LIBREDU may share the Personal Data of Platform Users with publishers to the extent necessary for the provision of the services offered. In particular, publishers who are or become clients of LIBREDU may access the Personal Data of Platform Users through the account provided to them on the Platform, enabling them to: 

 

• View the names of the Platform Users, their registration emails and the educational institution to which they belong.
• Access the codes activated by both students and teachers.

 

The transfer of Personal Data will be carried out in accordance with the applicable personal data protection regulations and with the appropriate security measures to guarantee its confidentiality and integrity.

 

The Platform Users with access to the information can be consulted in the updated list available at the following link: https://www.libredu.com/editoriales-usuarias-de-libredu/   

 

 

9. CROSS-BORDER FLOW

 

Personal Data may be shared with service providers located outside the Peruvian territory, exclusively for the purposes of storage and administration of the Platform, with respect to which Users give their express consent, LIBREDU ensuring due compliance with the security measures necessary for their safekeeping.

1. Cloud storage services:

To store Users' Personal Data, LIBREDU contracts the services of Google LLC, whose servers are located in the United States of America. Google LLC acts as data processor, providing technological infrastructure for the safeguarding of the information.

 

2. Administration and management of the Platform:

Given that the Platform has been developed and is owned by EXPLICO Pte Ltd, domiciled in Singapore, EXPLICO may access the Personal Data of Platform Users solely for the purposes of administration and maintenance of the service, in compliance with LIBREDU's instructions.

 

LIBREDU assures that Personal Data transferred internationally will be treated in accordance with adequate safeguards and security measures will be taken to mitigate any risk, in accordance with applicable law.

 

 

10. RETENTION PERIOD

 

The Personal Data of the Website Users that make up our Personal Data Banks will be stored in our database for a maximum period of five (5) years from its provision by the Website Users, provided that the User does not revoke his/her consent beforehand.

 

On the other hand, the Personal Data of the Users of the Platform that make up our Personal Data Banks will be stored in our database for as long as they are necessary for the fulfilment of the contractual obligations with the Clients, provided that the User does not revoke his/her consent beforehand.

 

Users' Personal Data will be deleted when they are no longer necessary for the purposes associated with their collection.

 

 

11. SECURITY MEASURES

 

LIBREDU adopts the necessary technical and organisational measures to guarantee the protection of Users' Personal Data and to avoid its alteration, loss, processing and/or unauthorised access, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed, all in accordance with the provisions of the Personal Data Protection Regulations.

 

LIBREDU employs various security techniques to protect such Personal Data from unauthorised access. Notwithstanding the foregoing, Users acknowledge that existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. Should such cases arise, LIBREDU shall proceed in accordance with the provisions of the applicable regulations.

 

Notwithstanding the foregoing, LIBREDU shall not be liable for illegal interception or violation of its systems or databases by unauthorised persons, as well as the improper use of information obtained by such means, or any unlawful interference beyond the control of LIBREDU and which is not attributable to LIBREDU. 

 

LIBREDU is also not responsible for possible damages that may arise from interferences, omissions, interruptions, computer viruses, telephone breakdowns or disconnections in the operational functioning of this electronic system, caused by reasons beyond LIBREDU's control; delays or blockages in the use of the computer platform caused by deficiencies or overloads in the internet system or other electronic systems.

 

 

12. MODIFICATIONS TO THE PRIVACY POLICY 

 

LIBREDU expressly reserves the right to modify, update or supplement this Policy at any time. Any modification, update or addition to this Policy will be immediately published on the Website for the User's knowledge.

 

Please check this Policy regularly for changes.

 

Last updated: 5 May 2025