Privacy Policy

The data controller in respect of the processing described herein is Expedite Business Solutions S.A.S., a company organised under the laws of Ecuador, with registered offices at [ADDRESS TO BE CONFIRMED] and tax identification number [RUC TO BE CONFIRMED]. Data-protection enquiries, requests and complaints may be addressed to our data-protection contact at [DPO NAME / EMAIL TO BE CONFIRMED]. Upon entry into force of the competent Ecuadorian data-protection authority, we will additionally provide the registration and notification details required by the LOPDP.

We collect and process the following categories of personal data: (i) identification and contact data — name, electronic mail address, telephone number and, where required for payout or tax purposes, official identity-document number; (ii) account data — credentials, role preferences (Buyer and/or Professional), profile information and professional descriptions supplied by you; (iii) marketplace content — Problems you publish, Solutions, offers and counteroffers you submit, messages exchanged between Buyers and Professionals, and ratings; (iv) transactional and financial data — purchases of Manolitos, Manolito balances and ledger entries, agreed prices, completed Transactions, commission calculations, pending and available earnings, and payout bank details furnished by Professionals; and (v) technical data — IP address, device identifiers, browser and operating-system characteristics, log files and usage data, collected through cookies and similar technologies as further described in our Cookie Policy.

We do not knowingly collect personal data from persons under eighteen (18) years of age, and the Platform is not directed at minors. Should we become aware that such data have been collected, we will delete it promptly.

Personal data are processed for the following purposes and on the following legal bases, using the categories recognised by the LOPDP: (i) performance of the contract — creating and administering your account, enabling the publication and purchase of Solutions, calculating commissions, maintaining Manolito and wallet balances, and effecting weekly payouts; (ii) compliance with legal obligations — accounting, tax, anti-money-laundering and consumer-protection duties imposed by Ecuadorian law; (iii) legitimate interests — securing the Platform, preventing and detecting fraud and abuse, troubleshooting, and improving service quality, subject in each case to a balancing test against your rights; and (iv) consent — optional marketing communications and non-essential cookies, which you may withdraw at any time without affecting the lawfulness of prior processing.

Sensitive data, special categories of data, and data concerning criminal offences, if ever processed, will be handled only in accordance with the heightened requirements of the LOPDP.

Within the marketplace, certain data are necessarily visible to counterparties: Buyers and Professionals can see each other’s public profile information, marketplace content and transaction records pertaining to their mutual Transactions. Purchased Solution content is disclosed only to the relevant Buyer.

In addition, we may disclose personal data to: (i) service providers acting as data processors under written instructions — including cloud-hosting and database providers and authentication providers, and any customer-support tooling documented before use; (ii) professional advisers bound by confidentiality — auditors, lawyers and accountants; and (iii) competent authorities, where disclosure is required by Ecuadorian law, regulation, court order or lawful governmental request. We do not sell personal data, and we do not disclose it for third parties’ independent marketing purposes.

Some of our processors host or support the Platform outside Ecuador. Where personal data are transferred to jurisdictions that do not ensure an adequate level of protection, we rely on appropriate safeguards, such as contractual clauses consistent with the standards contemplated by the LOPDP and its regulations, and we limit transfers to what is strictly necessary. The list of recipient jurisdictions and safeguards shall be finalised with counsel before production release.

Personal data are retained only for as long as necessary for the purposes described above: for the duration of the contractual relationship; thereafter, for the limitation periods applicable to contractual, consumer, tax and accounting claims under Ecuadorian law [PERIODS TO BE CONFIRMED BY COUNSEL]; and, for ledger, Transaction and payout records, for the minimum archival periods mandated by applicable commercial and tax legislation. When retention ceases to be justified, data are deleted or irreversibly anonymised.

We implement technical and organisational measures appropriate to the risk, including transport-layer encryption, hashed credentials, role-based access controls, server-side authorisation checks, audit logging of financial ledger entries, and vendor security assessments. No method of transmission or storage is entirely secure; accordingly, while we strive to protect your data, we cannot guarantee absolute security and will discharge our obligations, including breach-notification duties, in accordance with the LOPDP.

Subject to the exceptions established by the LOPDP, you may exercise the rights of access, rectification, erasure (“right to be forgotten”), objection, restriction of processing, data portability, and the right not to be subject to solely automated decisions producing legal effects. Requests may be submitted to [PRIVACY EMAIL TO BE CONFIRMED], together with proof of identity; we will respond within the statutory period [THIRTY (30) DAYS, TO BE CONFIRMED], free of charge save for manifestly unfounded or excessive requests.

You may also withdraw consent at any time and lodge a complaint with the competent Ecuadorian data-protection authority once it is operational, or with any other competent body. Unspent Manolito balances and pending legal or tax obligations may temporarily preclude complete erasure, as permitted by law.

The Platform is intended exclusively for adults. We do not knowingly solicit or process personal data of persons under eighteen (18) years of age. If you believe that a minor has provided us with personal data, please contact us so that we may investigate and delete such data.

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated through the Platform or by electronic mail, and the revised version will display an updated “Last updated” date.

This Privacy Policy is governed by the laws of the Republic of Ecuador, including the Constitution of the Republic, the LOPDP, its implementing regulations, and sectoral e-commerce and consumer-protection rules. It must be read together with our Terms and Conditions and Cookie Policy.

The contact, retention and cross-border transfer placeholders in this Policy must be completed by the Company following Ecuadorian legal review before public launch.