Privacy Policy

Last updated: July 9, 2026

This Privacy Policy describes how PROGRESIVO EMPRESA INDIVIDUAL DE RESPONSABILIDAD LIMITADA (“Progresivo Academy”, “we”) collects, uses, stores, and protects your personal data when you use our website, platforms, and services.

The processing of your data is carried out in accordance with Law No. 29733, the Personal Data Protection Law of Peru, its Regulations approved by Supreme Decree No. 016-2024-JUS (in force since March 30, 2025), and the applicable data protection regulations of the Latin American countries where we operate.

By registering, contracting our services, or providing your data through our forms, you declare that you have read and understood this Policy.

1. Data Controller

2. Information We Collect

2.1. Personal identification data

Information that you provide to us directly, such as:

• First and last name
• Email address
• Phone number
• Identity document (when necessary to issue payment receipts or certificates)
• Billing and payment information (processed securely by external providers; we do not store your full card details)

2.2. Usage and browsing data

Information collected automatically:

• IP address and approximate location data
• Browser and device type
• Online identifiers
• Pages visited and browsing time
• Academic progress within our platforms

2.3. Sensitive data

As a general rule, we do not collect sensitive data (racial or ethnic origin, health, biometric data, political or religious convictions, sex life, among others). If any service requires processing such data, we will request your express and written consent, in accordance with the enhanced protection that the law grants to this category of data.

2.4. Cookies and tracking technologies

We use cookies, pixels, and similar technologies to improve the user experience, analyze site performance, and personalize content. You can manage your preferences at any time. For more details, please refer to our Cookie Policy.

3. Legal Bases and Consent

We process your personal data on the basis of:

• Your free, prior, express, and unequivocal consent, granted separately for each purpose.
• The performance of a contractual relationship (provision of the courses and services contracted).
• The fulfillment of legal obligations (tax, accounting, and consumer protection).

Consent for marketing and commercial communications purposes is independent of the consent required to provide you with the service. You may grant or refuse it without this affecting the contracting of the service, and you may revoke it at any time.

4. How We Use Your Information

We use your data for specified, explicit, and lawful purposes:

• To provide, maintain, and improve our courses and services
• To manage your user account and your academic progress
• To process payments and issue payment receipts
• To communicate with you for support, updates, and service notifications
• To comply with legal and regulatory obligations
• With your prior and separate consent: to send you promotions, course news, and commercial communications

We do not use your data for purposes other than those disclosed without first requesting your consent.

5. Data Processors and Third Parties

In order to operate, we share data with providers that act as data processors under contract and following our instructions, for example:

• Payment gateway providers
• Web hosting and cloud infrastructure services
• Email and customer relationship management (CRM) platforms
• Web analytics tools

These third parties only access the data necessary to perform their function and are bound by confidentiality obligations. We do not sell your personal data.

6. Transfer and Cross-Border Flow of Data

Some of our providers are located outside the data subject’s country of residence. As a result, your data may be subject to a cross-border flow (for example, to servers located in the Kingdom of the Netherlands).

In such cases, we guarantee an adequate level of protection, by means of contractual data protection clauses and by verifying that the recipient offers safeguards equivalent to those required by Law No. 29733 and its Regulations. Where required by law, we will request your consent for such transfer.

7. Retention Period

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, and thereafter for the periods required by legal obligations (for example, tax and accounting obligations). Once those periods have elapsed, the data is securely deleted or anonymized.

8. Security Measures

We adopt reasonable technical, organizational, and legal measures to protect your data against unauthorized access, loss, alteration, or improper disclosure (encryption in transit via HTTPS, access controls, backups, among others).

In the event of a security incident affecting your personal data, we will notify the National Authority for Personal Data Protection and, where applicable, the affected data subjects, within the time limits established by the regulations in force.

9. Rights of the Data Subject

As the data subject, you have the right to:

• Access: to know what data of yours we process and for what purpose.
• Rectification: to correct inaccurate or outdated data.
• Cancellation (erasure): to request the deletion of your data where applicable.
• Objection: to object to the processing of your data on legitimate grounds.
• Portability: to receive your data in a structured, commonly used, and machine-readable format, and to request its transmission to another controller where technically feasible.
• Withdrawal of consent: to withdraw the consent granted at any time.

To exercise these rights, write to us at [email protected], stating your request and attaching a copy of your identity document so that we can verify that you are the data subject. We will respond to your request within the legally established time limits.

10. Right to File a Complaint

If you believe that your rights have not been properly addressed, you may file a complaint with the National Authority for Personal Data Protection (ANPD) of the Ministry of Justice and Human Rights of Peru, or with the competent data protection authority in your country of residence.

11. Minors

Our services are intended for persons of legal age. We do not knowingly collect data from minors without the consent of those who hold parental authority or guardianship over them.

If we detect that we have collected data from a minor without such authorization, we will delete it.

12. Personal Data Bank

The data collected is stored in personal data banks owned by PROGRESIVO EMPRESA INDIVIDUAL DE RESPONSABILIDAD LIMITADA. We maintain an internal record of processing activities and adopt the management measures required by Law No. 29733 and its Regulations approved by Supreme Decree No. 016-2024-JUS.

13. Changes to This Policy

We may update this Privacy Policy to reflect legal changes or changes in our services. We will publish the current version on this page, indicating the date of the last update. We recommend that you review it periodically.

14. Contact

For any inquiries regarding this Policy or the processing of your personal data, write to us at:

PROGRESIVO EIRL — RUC 20614181533 — [email protected]