Data controller

The institutional data controller for personal data treatment in Alerta is Saphi X Thryv S.A.C., RUC 20612289787, domiciled in Lima, Peru.## Categories of data collected

Alerta collects only the data strictly necessary to operate the system. Collection is organized in five categories.

Verified identity. Full name, date of birth, type and number of identity document, image of the document during verification. These data are requested only from Vigías, Expertos, Aliados and institutional representatives of corporate partners and government agencies.

Contact data. Email address, telephone number when the person voluntarily provides it, institutional physical address when applicable to the role.

Territorial data. Preferred territorial zone of operation for Vigías. Approximate location of each documented observation. Location is captured at the block or intersection level rather than the specific address, in accordance with the How to observe guide.

Activity records. Documented observations, validations issued, redemptions performed, transfers processed, state change events of the entity within the system.

Technical usage data. IP address, browser and operating system during access, session records. These data are retained for ninety days for operational security and technical diagnostic purposes.

Categories of data Alerta does not collect

Alerta explicitly forgoes the collection of the following categories of data, in compliance with the founding principle of Article I:

• Screen dwell time, scroll patterns, interaction sequences that measure attentional engagement.
• Extended demographic data (ethnic origin, sexual orientation, political affiliation, religious beliefs, health condition) beyond what is strictly necessary for identity verification.
• Real-time geolocation data outside the moment of documentation of an observation.
• Biometric data (fingerprint, facial recognition outside initial verification, voice).
• Device advertising identifiers or third-party commercial trackers.

Purposes of treatment

The data collected is treated exclusively for the following purposes:

• Operating the Alerta civic system in accordance with its Constitution.
• Verifying the identity of participating entities and protecting their safety in accordance with Article V.
• Processing the emission, redemption and traceability of seeds in accordance with Article VIII and the Treasury annex.
• Calculating and maintaining the accumulated trust score in accordance with the Trust Score.
• Complying with applicable legal obligations and, where appropriate, responding to requirements of competent authority in accordance with the procedure described below.
• Communicating to the data subject institutional matters that affect their participation.

No personal data is treated for advertising purposes, commercial transfer to third parties or profile elaboration that affects automated decisions. The operation of Saphi Intelligence on personal data is subject to the limits of Article X and to the Agent catalog.

Retention

Retention periods are governed by the following rules:

• Identity document image. Retained during active participation plus twelve additional months. After that period, it is irreversibly deleted.
• Basic identity data (name, document number, contact). Retained during active participation plus thirty-six additional months for legal obligation compliance and audit.
• Published observations. Remain accessible in perpetuity in accordance with Article VI, in anonymity modalities compatible with the requests of the data subject.
• Aggregated activity records. Remain accessible in perpetuity in anonymized form for institutional transparency purposes.
• Technical usage data. Retained for ninety days.

Transfer to third parties

Alerta does not transfer personal data to third parties for commercial, advertising or profiling purposes. The only situations in which information is transferred are the following:

• Technical processors. Infrastructure providers (data storage, email delivery, payment processing) acting under contract as treatment processors. The updated list of processors is published as an annex to this policy.
• Requirement of competent authority. When a Peruvian judicial authority issues a formal requirement consistent with Law 29733 and applicable international treaties. In these cases, Alerta notifies the data subject when notification is not legally prohibited.
• Article V protocol. In situations of risk to the physical safety of a Vigía, Alerta may share strictly necessary information with legal counsel and, when the data subject consents, with protection authorities.

Rights of the data subject

In accordance with Law 29733 and the present policy, the data subject has the following rights:

• Right of access. Request a copy of the personal data Alerta retains about the data subject.
• Right of rectification. Request correction of inaccurate or outdated data.
• Right of cancellation. Request deletion of personal data when no longer necessary for the purposes of treatment.
• Right of opposition. Oppose treatment for substantiated reasons relating to the particular situation of the data subject.
• Right of portability. Receive personal data in structured and commonly used format.
• Right not to be subject to individualized automated decisions. Consistent with Article X of the Constitution, no decision affecting the institutional position of the data subject is taken in a purely algorithmic manner.

Request procedure

Alerta responds within no more than twenty business days from receipt of the request.

If the data subject considers that the response does not adequately address the request, they may turn to the National Authority for Personal Data Protection of the Ministry of Justice and Human Rights of Peru.

Identity protected under Article V

The identity, location and physical safety of Vigías constitute information protected with absolute character in accordance with Article V of the Constitution. This protection operates in stricter terms than the minimum legal obligations: it includes active response protocols in cases of exposure, legal assistance and, when necessary, personal accompaniment.

The Article V protection takes precedence over any operational optimization. No data linked to the identity of a Vigía is published, transferred or treated without explicit verification of compliance with the safety protocol.

Data of minors

Alerta does not incorporate persons under eighteen years of age as entities of the system. The identity verification described in Vigía onboarding excludes minors. Observations that document situations involving minors receive special treatment in accordance with the civic safety protocol, with mandatory blurring of identity and expert validation of editorial pertinence.

Modifications of the policy

Modifications to this policy are announced two weeks in advance in the RSS feed, in accordance with the transparency calendar described in Treasury. Substantive modifications require tricameral agreement in accordance with Article IV.

Effective date

This policy enters into effect with the publication of version 0.2 of the constitutional document. Its last update corresponds to May 2026.