1. Data controller
NOVALY S.A.C., with RUC (Taxpayer ID) No. 20610879048 and registered address at Jr. Tumán Collasuyo 275, Urb. Centro Comercial Monterrico, Santiago de Surco, Lima, Peru, is the controller of the personal data collected through its website and its own commercial channels.
For questions or requests about your personal data, you may write to info@novaly.com.pe.
This policy is interpreted in accordance with Ley N.º 29733, Ley de Protección de Datos Personales (Peruvian Personal Data Protection Law), and its regulations in force.
2. Scope
This policy covers inquiries about our services, conversations with Novi on the website and WhatsApp, and the scheduling of meetings with our team.
It does not govern the data that Novaly processes on behalf of its clients through other solutions or projects. In those cases, the processing is subject to the instructions of the responsible organization and to the corresponding agreements.
3. Data we process
Depending on your interaction with us, we may process:
- Name and email address.
- Company or organization.
- Telephone number, including the one used to communicate with us via WhatsApp.
- Availability and the information needed to schedule meetings.
- Messages, dates and history of conversations with Novi and our team.
- Information about business or technology needs that you share voluntarily.
The data is added to our records of contacts and business opportunities.
We request only the information necessary for each step. If you do not provide the data that is essential to answer a request or book a meeting, we may not be able to complete it.
Please avoid sharing passwords, banking information, sensitive data or confidential information about third parties that is not necessary for your inquiry.
4. Main purposes
We use the data to:
- Answer inquiries and explain our services.
- Understand the need you have communicated and guide the commercial follow-up.
- Schedule meetings and manage related communications.
- Prepare proposals and carry out the pre-contractual steps requested.
- Follow up on the inquiry or business opportunity.
- Keep the history necessary to ensure continuity of service.
- Handle requests regarding personal data and comply with legal obligations.
- Protect our channels and manage security incidents.
Follow-up will be related to your request. You may ask us to stop contacting you by writing to info@novaly.com.pe.
We will not use your data for promotional campaigns other than this service without your consent or another applicable legal basis.
5. Use of Novi and improvement of the assistant
Novi is an artificial intelligence assistant that answers questions about Novaly and makes it easier to schedule meetings.
Conversations are stored in our management system and may be accessed by authorized personnel to handle requests and continue the commercial process.
Additionally, we may ask for your authorization to review identifiable conversations in order to evaluate responses, adjust Novi's instructions and detect information that needs to be updated.
You may refuse or withdraw this additional authorization without losing the ability to receive service or schedule a meeting.
To add questions and answers to the reference information used by the assistant, we will remove any personal data and confidential information that is not necessary. We will not incorporate identifiable conversations into answers intended for other users.
This improvement is limited to Novi on Novaly's own channels. It does not involve using your conversations to develop solutions for third parties.
6. Consent and other legal bases
When processing requires consent, we will request it in advance through an affirmative action, after providing you with the corresponding information.
We may also process the data strictly necessary for the pre-contractual steps you request, to perform a contractual relationship or to comply with legal obligations, within the exceptions provided for by the regulations.
Merely accessing the website, reading this policy or sending a message does not constitute a general authorization for any use of your data.
7. Service providers and recipients
To operate our channels, we use the following service providers:
| Provider | Function |
|---|---|
| Elastika Cloud | Hosting and storage of the Novi platform and its history. |
| OpenAI | Processing of messages to generate Novi's responses. |
| Meta / WhatsApp | Operation of communications via WhatsApp. |
| Calendly | Availability lookup and meeting scheduling. |
Each provider receives the information necessary for its function. Its involvement depends on the channel and on the step being carried out.
Certain providers also process information under their own responsibility for purposes such as security, abuse prevention and administration of their services, in accordance with their applicable terms.
You can consult their official documents:
- OpenAI: https://openai.com/policies/data-processing-addendum/
- WhatsApp: https://www.whatsapp.com/legal/
- Calendly: https://calendly.com/legal/privacy-notice
- Elastika Cloud: https://elastika.cloud/
We do not sell your personal data. We may disclose it to authorities when there is a legal obligation or a valid request.
8. Hosting and international processing
The main hosting of the Novi platform and its history takes place on Elastika Cloud infrastructure located in Peru.
The use of OpenAI, Meta / WhatsApp and Calendly involves or may involve processing outside Peru, including in the United States, depending on the entities, infrastructure and sub-processors involved.
Main hosting in Peru does not mean that all information is processed exclusively in the country.
For international processing under our responsibility, we will apply the requirements of Peruvian regulations and the corresponding contractual safeguards. When your consent is required, we will request it and inform you about such processing.
You may request additional information about recipients and international processing at info@novaly.com.pe.
9. Retention
The data and histories of prospects who do not contract our services will be kept for 12 months from the last interaction.
An automated interaction that receives no response will not, by itself, restart that period.
Once the period has ended, we will delete or anonymize the data. If there is a legal obligation, a complaint or a dispute that justifies keeping certain information, we will limit its use to that purpose and to the time necessary.
If you contract our services, the data necessary for the contractual relationship will be kept in accordance with the service and the applicable legal obligations.
Backups are subject to rotation and deletion procedures. Information pending removal from a backup will not be used for ordinary commercial activities; if a backup is restored, the corresponding deletions will be applied again.
Information that has been effectively anonymized may be kept for analysis and service improvement.
10. Security and confidentiality
We apply technical and organizational measures proportionate to the processing to protect data against unauthorized access, loss, alteration and disclosure.
Access is limited to the staff and providers who need it for their functions. Incidents will be managed and reported in accordance with the applicable legal obligations.
11. Your rights
You may exercise your rights of information, access, rectification, cancellation and objection, and withdraw your consent where applicable.
Write to info@novaly.com.pe stating:
- Your name.
- The request you wish to make.
- The email address or number you used to contact us, when it helps to locate the information.
We will request only the additional data necessary to verify your identity. We will not require unnecessary documents to process your request.
We will respond within the legal time limits. If we cannot grant what was requested, we will explain the reason and the available avenues to challenge the decision.
Withdrawal does not affect processing validly carried out beforehand. Deletion may be limited by legal obligations, in which case the requester will be informed.
If you believe your rights have been infringed, you may contact the Autoridad Nacional de Protección de Datos Personales del Ministerio de Justicia y Derechos Humanos (National Personal Data Protection Authority of the Ministry of Justice and Human Rights): https://www.gob.pe/anpd.
13. Updates
We will publish any update together with its effective date.
Changes will not retroactively authorize new purposes. When additional consent is required, we will request it before the processing begins.
See also: Terms of Use