Privacy and Personal Data Processing Policy

Last updated: September 2026

1. Data Controller

The owner of the personal data banks and the data controller is FRUX E.I.R.L. (“FRUX”), Peruvian Tax ID (RUC) No. 20616274857, with registered address at Av. Coronel Reynaldo Vivanco 310, Apt. 502, Santiago de Surco, Lima, Peru.

• Email: info@fruxproduce.com
• Phone: (+51) 955 904 637

FRUX is a consultancy specialized in the agro-export sector. It provides technical and commercial advisory, fruit sourcing, market intelligence, and personnel selection and recruitment services. FRUX processes personal data in accordance with Peruvian Law No. 29733, the Personal Data Protection Law, and its Regulations approved by Supreme Decree No. 016-2024-JUS.

2. Scope

This policy applies to:

• Visitors to the website www.fruxproduce.com.
• Prospective clients: companies and professionals interested in our services, or with whom we establish an initial business contact.
• Clients: representatives and staff of companies that contract our services.
• Suppliers: growers, packhouses, exporters, importers, certification bodies, service providers and other industry contacts we work with.
• Candidates: individuals who apply for job openings managed by FRUX or who submit their CV for future opportunities.

3. Personal Data Banks

Personal data is stored in the following data banks owned by FRUX, registered with the National Registry of Personal Data Protection of Peru’s National Authority for Personal Data Protection:

4. Personal Data We Process

4.1 Prospective clients, clients and suppliers

• name, job title, company, country, email address, phone number and professional profiles
• information about the business relationship: inquiries, proposals, contracts, communications and invoicing
• in technical advisory, quality management and fruit sourcing services, contact details of field, quality, certification or commercial staff, and information recorded during visits, assessments or audits (for example, names of responsible persons and process observations)

4.2 Candidates

• Identification and contact details: name, ID document, date of birth, nationality, address, email and phone number.
• Academic and professional background: education, certifications, work experience, languages and skills.
• Job conditions: salary expectations, availability and willingness to relocate.
• Assessments: interview and competency assessment results.
• References and verification: details of the referees you provide, and verification of academic degrees and work experience, in both cases with your authorization.

Sensitive data. FRUX does not request sensitive data, such as health information, racial or ethnic origin, religious beliefs, trade union or political affiliation, or sex life. Nor does it request photographs or marital status, and we ask you not to include them in your CV. If you provide such data voluntarily, it will not be used in any selection decision. Where the law requires processing sensitive data (for example, a pre-employment medical examination required by the employer), your express written consent will be requested in advance.

FRUX conducts its selection processes without discrimination of any kind.

4.3 Website visitors

• browsing data (IP address, browser, pages visited, date and time) collected through cookies (see Section 11)

5. Source of the Data

• directly from you, through forms, email, interviews, meetings or visits
• from the companies you work for, in the course of a service
• from publicly available sources, such as industry directories, trade fairs, public registries and public professional profiles

Where the first contact originates from these sources, we will inform you of this policy and request your consent where applicable.

6. Purposes of Processing

6.1 Necessary purposes

a) Responding to inquiries and requests for information.
b) Preparing proposals and delivering contracted services: technical and commercial advisory, quality management, fruit sourcing, market intelligence and personnel selection.
c) Identifying, assessing and coordinating with suppliers to deliver our services.
d) Candidates: assessing your application, coordinating interviews and assessments, checking references and background, and presenting your profile to the FRUX team and to the client company of the recruitment process.
e) Complying with legal, accounting and tax obligations.

6.2 Additional purposes

These purposes require your prior, express and separate consent:

f) Open application: keeping your CV on file to consider you for future recruitment processes.
g) Sending you commercial information, market reports, newsletters, event invitations, job openings and FRUX news.
h) Producing website usage statistics through analytics cookies.

Declining these additional purposes will not affect our response to your inquiry, the provision of our services, or your participation in the recruitment process you applied for.

7. Recipients and Transfers

FRUX does not sell your personal data. It only shares it in the following cases:

• Technology providers, acting as data processors under confidentiality and security obligations:
  • Google: email, cloud storage and web analytics
  • Microsoft: email, office software and cloud storage
  • Hostinger: website hosting
• Client companies in recruitment processes. Your CV and assessment results are shared with the company offering the position, always with your prior consent for each process.
• Clients of sourcing, quality and advisory services. Only the supplier business contact details strictly necessary for the service are shared.
• Authorities, when required by law or court order.

International transfers. As declared to the National Authority for Personal Data Protection, FRUX carries out international data transfers to the following destinations:

FRUX applies the safeguards required by Peruvian law to these transfers. Candidates will be informed of the client company’s country before their application is submitted.

8. Retention Periods

• Prospective clients: up to 2 years from the last contact.
• Clients and suppliers: for the duration of the relationship and, thereafter, for the periods required by tax, accounting and civil law.
• Candidates, specific process: up to 6 months after the process closes.
• Candidates with open applications: up to 2 years, with the option to renew consent.
• Marketing communications: until you withdraw your consent.

Once these periods expire, data is securely deleted or anonymized.

9. Security and Confidentiality

FRUX applies technical, organizational and legal measures to protect your data, including restricted access, passwords, encrypted cloud storage, HTTPS connections, and confidentiality agreements with staff and providers. Recruitment information is handled with strict confidentiality. Your application will not be disclosed to your current employer.

10. Your Rights

As a data subject, you have the following rights:

• Access: to know what personal data we hold about you.
• Rectification: to correct inaccurate or incomplete data.
• Cancellation: to request deletion of your data.
• Objection: to object to a specific processing activity.
• Portability: to receive your data in a structured format.
• Withdrawal of consent: at any time.

How to exercise your rights:

• by email to info@fruxproduce.com, with the subject line “ARCO Rights”
• in writing at Av. Coronel Reynaldo Vivanco 310, Apt. 502, Santiago de Surco, Lima, Peru
• by phone at (+51) 955 904 637, for guidance on the procedure

Your request must include:

• your full name and an address or email for our reply
• a copy of your ID document (or your representative’s, with proof of representation)
• a clear description of the data concerned and the right you wish to exercise
• any document that helps locate your data

Requests are handled free of charge and within the time limits set by the Regulations.

If you believe your request has not been properly addressed, you may file a complaint with Peru’s National Authority for Personal Data Protection, at the reception desk of the Ministry of Justice and Human Rights (Calle Scipión Llona 350, Miraflores, Lima, Peru) or through its online filing system: https://sgd.minjus.gob.pe/sgd-virtual

11. Cookies

• Technical cookies: necessary for the website to function. They do not require consent.
• Analytics cookies (Google Analytics): only activated if you accept them.

You can manage cookies through the website’s cookie banner or your browser settings.

12. Minors

Our services and recruitment processes are intended for individuals aged 18 and over. We do not knowingly collect data from minors.

13. Changes to This Policy

FRUX may update this policy. The current version will be published on this page with its update date.

14. Governing Language

This policy is published in Spanish and English. In the event of any discrepancy, the Spanish version shall prevail.