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Information on how we collect, use and protect your personal data.
[Company Name] (hereinafter, "the Company", "we", or "our"), with registered address at [company address] and contact email [email@example.com], is responsible for the processing of personal data collected through the Platform. This Privacy Policy describes how we collect, use, store, and protect your personal information when you access and use our services.
Summary: We collect your information only with your consent; we only collect the minimum amount of personal information necessary to fulfill the purpose of your interaction with us; we do not sell your information to third parties; and we only use it as described in this Privacy Policy. We recommend that you read the complete document to understand all the details.
By providing us with your personal data, you accept the processing thereof in accordance with this Privacy Policy. We recommend that you carefully read this document before providing any personal information through the Platform.
For the purposes of Ecuadorian legislation: [Company Name], with RUC [company RUC] and registered address at [full address], Ecuador, is responsible for the processing of your personal data in accordance with the Organic Law on Protection of Personal Data (LOPDP), published in Official Gazette Supplement 459 of May 26, 2021. The database called "Users" will be registered with the Superintendent of Personal Data Protection within the period established by law.
Depending on your interaction with the Platform, we may collect the following categories of personal data:
Contact data: name, email address, and telephone number, voluntarily provided when you use the contact form, make an inquiry via WhatsApp, or submit a product review.
Navigation data: IP address (stored in hashed form for anonymization), approximate country of origin (derived from IP), browser type, operating system, and pages visited. This data is collected anonymously through Vercel Analytics and Speed Insights, provided you have given your consent for analytical cookies.
Conversation data: history of messages exchanged through WhatsApp, including the content of text messages, shared images (for automatic product analysis), audio recordings (for automatic transcription), and attachments (for information extraction). The telephone number is stored anonymously using HMAC-SHA256 hash, and conversations are retained for a maximum period of 7 days, unless you request early deletion.
Preference data: language preference (Spanish or English) and visual theme preference (light, dark, or system), stored locally in your browser.
Consent data: record of your consent to cookies, including the categories accepted (necessary, analytical, and/or marketing) and the date and time of consent.
Audit log: when you interact with our services through WhatsApp, we record a history of actions performed, including sending messages, requesting information, and making inquiries. This log includes the date and time of the interaction and its content, stored anonymously and temporarily for service provision and continuous improvement purposes.
We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although the Company does not intentionally request or collect sensitive personal information, you might store this type of information in your WhatsApp messages or in the content you voluntarily share. If you store any sensitive personal information through our services, you consent to the storage of such information in our systems.
We do not collect credit card information or financial data on our servers. Transactions are managed directly through the conversation with the WhatsApp agent, and payments are processed through payment platforms agreed upon between the parties. We do not store card numbers, security codes, or any other sensitive financial information.
We do not knowingly collect information from minors under 18 years of age. If we discover that we have collected personal data from a minor without consent, we will delete such information immediately.
Your personal data will be processed for the following purposes:
Service provision: to process and respond to your inquiries, information requests, product orders, and appointment reservations made through the Platform and WhatsApp, including initial attention through an artificial intelligence agent and referral to human staff when necessary.
Service improvement: to analyze Platform usage, identify browsing trends, evaluate the effectiveness of our content, and improve the user experience. This analysis is performed with anonymized and aggregated data.
Communications: to send confirmations, service-related notifications, and, with your express consent, commercial and informational communications through WhatsApp or email.
Legal compliance: to comply with applicable legal and regulatory obligations, including managing requests to exercise data protection rights.
The processing of your personal data is based on the following legal grounds: (a) the execution of a contract or the application of precontractual measures when you request information or use our services; (b) your express consent for processing data for marketing and analytics purposes, manifested through cookie acceptance and voluntary submission of information through forms; and (c) the Company's legitimate interest in improving its services and ensuring the Platform's security.
In accordance with the Organic Law on Protection of Personal Data (LOPDP) of Ecuador, the processing of your personal data is legitimized under the following grounds established in Article 7 of said law: (i) the data subject's consent (paragraph 1), manifested through cookie acceptance and voluntary submission of information through forms and WhatsApp; and (ii) compliance with legal obligations by the controller (paragraph 8), including managing ARCO rights requests and complying with applicable tax and commercial obligations in Ecuadorian legislation.
For the provision of our services, we may share your personal data with the following third-party service providers, all of whom comply with contractual data security and protection standards:
Vercel Inc. (United States): web hosting and analytics service. Your anonymized navigation data may be processed on servers located in the United States. Vercel complies with the EU-U.S. Data Privacy Framework.
Upstash Inc. (United States): in-memory Redis database service, used to temporarily store conversation sessions and artificial intelligence agent memory. Telephone numbers are stored exclusively in HMAC-SHA256 hash form, without storing plaintext numbers.
OpenAI LLC (United States): artificial intelligence service used to process and respond to user messages, transcribe audios, and analyze images shared through WhatsApp. Messages are sent to OpenAI for processing and are not used to train their models (Zero Data Retention enabled).
YCloud Pte. Ltd. (Singapore): WhatsApp Business API service used for sending and receiving WhatsApp messages. Telephone numbers and messages are processed through their infrastructure for communication delivery.
We do not share your personal data with third parties for direct marketing purposes without your express consent. We may disclose your data when required by law or in response to valid requests from public authorities.
For more information about the data processing by these providers, you can consult their privacy policies: Vercel Privacy Policy, OpenAI Privacy Policy, Upstash Privacy Policy, YCloud Privacy Policy.
International transfers: Your personal data may be transferred and processed in countries other than yours, including the United States and Singapore. For transfers to the United States, our providers (Vercel, OpenAI, Upstash) comply with the EU-U.S. Data Privacy Framework certified by the U.S. Department of Commerce. When data is transferred to countries not subject to an adequacy decision by the European Commission, we implement adequate safeguards, such as Standard Contractual Clauses approved by the European Commission or the UK Government. You may request a copy of such safeguards by contacting us at [email@example.com].
The Platform is not directed to minors under 18 years of age, and we do not intentionally collect personal information from minors. If we become aware that we have collected personal data from a minor under 18 years of age without verifiable parental or guardian consent, we will delete such information from our systems immediately. If you are a parent or guardian and are aware that your child has provided us with personal data, please contact us at [email@example.com] so that we can take the necessary measures.
We do not allow minors under 18 years of age to use our Services. If we discover that a User is under 18 years of age, we will cancel their access and delete their data in accordance with our Data Policy.
In the event of a security breach affecting your personal data, we commit to notify you without undue delay and, in any case, within the maximum period established by applicable legislation (generally 72 hours from becoming aware of the breach). The notification will include: the nature of the personal data breach; the personal data affected; the name and contact details of our contact point for further information; the measures adopted or proposed to remedy the personal data breach; and, where possible, recommendations to mitigate the possible adverse effects.
We maintain records of all personal data breaches, including the facts related to the breach, its effects, and the corrective measures adopted, as required by applicable legislation.
The Company may disclose personally identifiable information or other information we collect about you to law enforcement authorities in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public.
When complying with court orders and similar legal processes, the Company strives to be transparent. Where permitted, we will make reasonable efforts to notify users about any disclosure of their information, unless we are prohibited by law or court order, or in exceptional circumstances.
If you have concerns about how the Company is handling your personal information, please let us know immediately. You can contact us directly at [email@example.com] with the subject "Privacy". We will respond within a maximum of 15 business days.
In case you are not satisfied with our response, you have the right to file a complaint with the Superintendent of Personal Data Protection, the supervisory authority for personal data protection in Ecuador, in accordance with the Organic Law on Protection of Personal Data. You can contact said authority through the official channels provided by the competent body.
We retain your personal data for as long as necessary to fulfill the purposes described in this policy, unless the law requires or permits a longer retention period:
WhatsApp conversation history: 7 days in Redis, with the possibility of early deletion upon user request. The agent's persistent memory (customer preferences, contextual data) is retained for up to 365 days or until the user requests its deletion.
Preference cookie: 1 year from your last update.
Phone cookie: 15 minutes, used solely to facilitate sending messages without having to re-enter the number.
Analytical navigation data: according to Vercel Analytics retention policy, with aggregated data retained indefinitely and detailed data for a limited period.
Once the retention periods have elapsed, your data will be securely deleted or anonymized.
In accordance with applicable data protection legislation, you have the following rights: (a) right of access: to obtain confirmation as to whether we are processing your personal data and to access it; (b) right of rectification: to request correction of inaccurate or incomplete data; (c) right to erasure ("right to be forgotten"): to request deletion of your personal data when they are no longer necessary for the purposes for which they were collected; (d) right to restriction of processing: to request restriction of the processing of your data; (e) right to data portability: to receive your data in a structured, commonly used, and machine-readable format; (f) right to object: to object to the processing of your data for direct marketing purposes; and (g) right to withdraw consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
To exercise any of these rights, you can contact us at [email@example.com] or through the contact form available on the Platform. We will respond to your request within the maximum legal period. You also have the right to file a complaint with the competent data protection supervisory authority.
In accordance with Articles 13 to 19 of the Organic Law on Protection of Personal Data (LOPDP) of Ecuador, you have the following rights: access (Art. 13), rectification (Art. 14), erasure or cancellation (Art. 16), objection (Art. 16), portability (Art. 17), suspension of processing (Art. 18), and the right not to be subject to automated individual decisions (Art. 19). To exercise any of these rights, you can contact us at [email@example.com] with the subject "Exercise of LOPDP Rights". We will respond to your request within a maximum period of 15 business days, as established in the LOPDP. If you are not satisfied with our response, you have the right to file a complaint with the Superintendent of Personal Data Protection.
We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing your personal data. These measures include: encryption of communications via HTTPS/TLS protocol; encryption at rest of sensitive data; anonymization of telephone numbers via HMAC-SHA256; access control based on the principle of least privilege; and security incident response protocols.
However, no data transmission over the Internet or electronic storage system can be guaranteed as completely secure. Therefore, we cannot guarantee the absolute security of your data.
We reserve the right to update this Privacy Policy at any time. We will notify you of any material changes by posting the new policy on the Platform and, where possible, by email notification to the registered address. We recommend that you periodically review this page to stay informed about how we protect your information. Continued use of the Platform after any modification constitutes acceptance of the updated policy.
We use cookies and similar technologies to ensure the proper functioning of the Platform, improve your experience, and, with your consent, analyze traffic and personalize content. Cookies are small text files stored in your browser when you visit a website.
Do Not Track: "Do Not Track" is a privacy preference you can set in your browser if you do not want online services to collect and share certain types of information about your online activity over time. We do not track your browsing activity on other online services over time, and we do not allow third-party services to track your activity on our site beyond our basic analytical cookies. Because we do not share this type of data with third-party services or allow third-party data collection on our Platform, and we do not track our users on third-party websites, we do not need to respond differently to an individual browser's "Do Not Track" setting. If you want to enable your browser's privacy and "Do Not Track" settings, the website Do Not Track has specific instructions for each browser.
Necessary cookies: these are essential for the Platform to function and cannot be disabled. They include session cookies to maintain your language preference, cookie consent cookies to remember your choice about cookies, and necessary technical cookies for the proper display of the site. These cookies do not require your express consent.
Analytical cookies: these allow us to count visits and traffic sources so that we can measure and improve the Platform's performance. These cookies collect aggregated and anonymous information. We use Vercel Analytics and Speed Insights for this purpose. These cookies are only activated if you give your consent.
Marketing cookies: these are used to track visitors across websites and display relevant and engaging ads for the user. We currently do not use third-party marketing cookies on our Platform, but this category is available in case they are implemented in the future.
You can manage your cookie preferences at any time through the cookie settings panel available on the Platform. You can also configure your browser to block or delete cookies, although this may affect the Platform's functionality.