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DORADO LABS S.R.L is a company that respects the Personal Data provided by its current and potential clients, employees, candidates, business partners, suppliers, shareholders, investors and other persons interested in El Dorado’s Services, and for this reason it has implemented this Privacy and Personal Data Processing Policy (hereinafter, the “Policy”), which explains what Personal Data is processed, for what purposes, what the rights of the Data Subject are, and the mechanisms available to exercise them.
The use of the El Dorado Platform, the execution of employment, business partnership or service agreements, and/or the express and unequivocal acceptance of this Policy imply that the Data Subject accepts that their Personal Data will be processed in accordance with the provisions herein.
EL DORADO adopts this Policy in accordance with the general principles of personal data protection and the right to privacy and informational self-determination.
This Policy applies to all Personal Data that EL DORADO, in its capacity as a virtual asset service provider, collects, receives or processes in the course of its corporate purpose and its commercial activities, present or future, regardless of the specific services through which such activities are carried out.
The Policy also covers data of legal entities when it is necessary to process the data of their legal representative, attorney-in-fact or shareholders for purposes of corporate compliance, identity verification (KYC) and the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction (ML/TF/PF).
“Authorization”: the prior, express and informed consent granted by the Data Subject to El Dorado for the Processing of their Personal Data.
“Database”: an organized set of Personal Data that is subject to Processing by El Dorado.
“Non-Public Personal Information (NPI)”: the non-public financial and transactional information of users obtained in connection with the provision of the Visa Prepaid Card service.
“Inquiry”: a request made by the Data Subject to learn what information El Dorado holds about them in its Databases.
“Personal Data”: any information relating to a natural person that identifies them or makes them identifiable.
“Sensitive Data”: data that affects the privacy of the Data Subject or whose misuse may give rise to discrimination, such as racial or ethnic origin, political orientation, religious or philosophical beliefs, trade union membership, health data, data concerning sex life and biometric data.
“Data Processor”: a natural or legal person, public or private, who, alone or jointly with others, carries out the Processing of Personal Data on behalf of and following the instructions of El Dorado, in its capacity as Data Controller.
“Purpose”: the purpose for which El Dorado processes the Data Subject’s Personal Data.
“Platform”: El Dorado’s website and application through which the Services are provided.
“Claim”: a request by the Data Subject to exercise their rights in relation to their Personal Data.
“Data Controller”: a natural or legal person who decides on the Processing of Personal Data, that is, who determines its purpose.
“Services”: the services that El Dorado provides to its users, which can be consulted on its website and application.
“Data Subject”: a natural person whose Personal Data is subject to Processing.
“Processing”: any operation performed on Personal Data, such as collection, storage, use, circulation, transmission, transfer, updating, correction or deletion, whether at the national or international level.
“Transmission”: the delivery of Personal Data to a Data Processor, within or outside Argentina, so that the latter carries out the Processing following the instructions of El Dorado.
“Transfer”: the delivery of Personal Data to another Data Controller, within or outside Argentina, so that the latter processes it autonomously.
The Processing of Personal Data by El Dorado is governed by the principles set forth in Law No. 25,326:
● Lawfulness (sec. 3): El Dorado’s Databases are duly registered and their Processing does not pursue purposes contrary to the law or public morals.
● Data quality (sec. 4): the Personal Data collected is accurate, adequate, relevant and not excessive in relation to the scope and purpose for which it was obtained. In addition:
○ Collection is not carried out by unfair or fraudulent means or in any manner contrary to the law.
○ The data is not used for purposes other than or incompatible with those for which it was obtained.
○ The data is kept accurate and up to date.
○ The data is destroyed when it is no longer necessary or relevant for the purposes for which it was collected, without prejudice to the retention periods required by applicable regulations.
● Consent (sec. 5): the Processing of Personal Data requires the free, express and informed consent of the Data Subject.
● Information (sec. 6): when collecting Personal Data, El Dorado expressly and clearly informs the Data Subject of:
○ the purpose of the Processing and who its recipients may be;
○ the existence of the Database and the identity and address of its Data Controller;
○ whether answers are mandatory or optional, and the consequences of providing the data, refusing to do so or providing inaccurate data;
○ the possibility of exercising the rights of access, rectification and deletion.
● Sensitive data (sec. 7): no person may be compelled to provide Sensitive Data.
● Security (sec. 9): El Dorado adopts the technical and organizational measures necessary to ensure the security and confidentiality of Personal Data, so as to prevent its alteration, loss, consultation or unauthorized processing.
● Confidentiality (sec. 10): every person involved in the Processing of Personal Data is bound by professional secrecy with respect to such data, even after their relationship with El Dorado has ended.
In addition, the processing of Non-Public Personal Information (NPI) associated with the Visa Prepaid Card service will also be carried out in compliance with the applicable regulations of the United States.
The Data Controller of the Personal Data covered by this Policy is EL DORADO LABS S.R.L, a company incorporated under the laws of the Argentine Republic, identified with CUIT 30-71856888-5, and domiciled at Humboldt 1967, Buenos Aires, Argentina.
EL DORADO LABS S.R.L may transmit and/or transfer Personal Data, nationally and internationally, to the Data Processors and Data Controllers with which it interacts for the development of its activities, for which it will adopt the relevant legal and contractual mechanisms to ensure the principles set forth in this Policy, as detailed in Section 9.
El Dorado collects Personal Data from Data Subjects, among others, in the following cases:
In general, El Dorado may collect from all Data Subjects, among others: first and last names or company name, depending on whether the Data Subject is a natural or legal person; country and city of residence or domicile; telephone number; email address; and the type and number of the identity document or of the company’s incorporation record; as well as any other data necessary to fulfill the purposes described in this Policy.
In addition to the general data indicated in section 6.2, the following may be collected from Platform clients and users: commercial and transactional profile information; data of the account(s) or wallet(s) used to operate on the Platform; P2P transaction history; browsing history on the Platform; history of customer service cases; information contained in national and international restrictive lists; age; the type and number of the identity document, together with a legible and valid image thereof; the client’s biometric liveness verification; and information about their economic activity and the source of their funds. When the client is a legal entity, the following may also be collected: company name, address, email address, company registration number and tax identification number; description of its economic activity and, where applicable, the type of license, registration or authorization number and the issuing authority; name, address and email address of its Compliance Officer; identification of its ultimate beneficial owners and shareholders and whether any of them is a politically exposed person or subject to international sanctions; information about its geographic scope, its clients and its program for the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction (ML/TF/PF); and supporting documentation such as recent financial statements, certificate of incorporation, bylaws or articles of association, shareholder register, register of directors or officers, and proof of address, as well as any other information required to fulfill the Processing purposes set forth in Section 7 of this Policy and to properly provide El Dorado’s Services.
In addition to the general data indicated in section 6.2, the documents customarily required for these relationships may be collected from El Dorado’s candidates, employees, shareholders and investors, among others: résumé or curriculum vitae; personal and professional references; proof of studies and certifications; DNI or passport; proof of address; and, where applicable, shareholder or equity interest certificate and documentation on the source of the funds contributed or invested.
In addition to the general data indicated in section 6.2, the documents customarily required to formalize this type of business relationship may be collected from El Dorado’s partners and suppliers, among others: articles of association or bylaws, duly registered with the Inspección General de Justicia (IGJ) or the relevant Public Registry depending on the jurisdiction; proof of registration with the Agencia de Recaudación y Control Aduanero (ARCA), with its Clave Única de Identificación Tributaria (CUIT), or the equivalent tax identification document; commercial references; DNI or passport of the legal representative or attorney-in-fact; the power of attorney or document evidencing such representation; and any other documentation necessary for the performance of the relevant agreement or business relationship.
Given the nature of the Service, El Dorado may process certain Sensitive Data, such as the image of the Data Subject’s identity document and their photograph obtained through biometric liveness verification carried out as part of the identity verification (KYC) process, as well as any other Sensitive Data necessary to fulfill the purposes described in this Policy and to properly provide the Services.
El Dorado will only collect and process Sensitive Data in the permitted cases and will always inform the Data Subject that they are not obliged to provide it or to authorize its Processing. If the Data Subject does not grant such authorization, El Dorado will not be able to continue with the identity validation process and, consequently, will not be able to provide the Services.
By participating in videoconferences, events, activities, experiences, activations, campaigns, contests, promotional or marketing activities, events sponsored or supported by El Dorado, as well as in any other activity organized, produced, sponsored or disseminated by El Dorado, the Data Subject authorizes El Dorado, free of charge and on a non-exclusive basis, to capture, record, reproduce, use, edit, adapt, communicate, publish and disseminate their name, image, voice and/or participation, as applicable, in photographs, videos, recordings, broadcasts, interviews, testimonials and other audiovisual or graphic content generated in connection with such activities.
Such authorization covers the use of this content in advertising pieces, communication and marketing campaigns, social media, websites, digital platforms, audiovisual material, printed material, commercial communications, presentations, events, brand activations, promotional activities, contests, institutional publications and other media or communication channels, current or future, for informational, institutional, promotional, advertising or commercial purposes related to El Dorado, its products, services, activities, initiatives or brand.
In principle, the Data Subject’s participation and the authorization to use their name, image, voice and/or participation will not give rise to any right to remuneration, royalty, compensation or consideration in their favor. However, the parties may agree in good faith, before or after a given activity, on specific consideration or economic terms when, due to the characteristics, scope, duration, nature or purpose of the participation or of the use of the content, they deem it appropriate. Any agreed consideration must be set forth in the terms defined by the parties for the relevant activity.
The Data Subject understands and accepts that the content may be used individually or together with other content, and may be edited, cut, adapted or incorporated into different pieces or formats, provided that its use does not unlawfully affect their honor, good name or dignity.
For the provision and administration of the Visa Prepaid Card service, and in compliance with the applicable regulations of the United States, El Dorado may collect, use and process users’ Non-Public Personal Information (NPI).
NPI includes, without limitation, financial and transactional information related to the use of the aforementioned product. The Non-Public Personal Information collected in connection with the Visa Prepaid Card will be used exclusively for everyday business purposes, including, among others:
For these purposes, the Company shares NPI with Bridge Ventures LLC and Lead Bank (as the issuing bank of the Visa Prepaid Card), solely for the business purposes described above.
Users have the right to opt out of sharing their Non-Public Personal Information (NPI) with non-affiliated third parties for marketing or non-essential purposes.
Non-Public Personal Information and any other personal data collected specifically for the Visa Prepaid Card will not be sold, rented or shared with third parties for their own marketing purposes, without prejudice to disclosures permitted or required by applicable law or necessary for the provision of the service.
All collection, use and disclosure of NPI will be carried out in accordance with applicable law, the agreements with the issuing bank and the principles of confidentiality, security and data minimization.
El Dorado will process Personal Data to: fulfill its corporate purpose and provide its services; keep and manage the information of the employment, civil or commercial relationship with Data Subjects; comply with legal, accounting, commercial and regulatory obligations; monitor and preserve the security of El Dorado’s people, assets and information; host Personal Data on its servers or on those of its Data Processors; disclose information when necessary to comply with legal proceedings, prevent fraud or protect the security of El Dorado or third parties; prevent and detect the commission of crimes, for which it may consult national and international databases and restrictive lists; comply with regulations on the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction (ML/TF/PF); maintain direct communication with Data Subjects for contractual and informational purposes; carry out statistical, commercial, financial and administrative analyses; and respond to Inquiries, requests and Claims.
For Platform clients and users, El Dorado will also process Personal Data to:
● Properly provide, manage, administer, operate, maintain and improve the Services offered by El Dorado, as well as the products, functionalities and solutions available through the Platform.
● Verify, validate, update and maintain the identification, contact, profile and other information provided by the Data Subject, and manage the registration, onboarding, authentication, access and data update processes.
● Consult, verify and validate the Data Subject’s information in public and private sources, databases, credit bureaus, and public and restrictive lists, whether national or international, and determine or update their risk profile in accordance with El Dorado’s ML/TF/PF prevention policies and procedures and other applicable legal or regulatory obligations.
● Carry out due diligence, know-your-customer (KYC), risk management, fraud prevention and detection processes, and the detection of unusual transactions, illicit activities, identity theft and other conduct that may affect the security, integrity or proper provision of the Services.
● Comply with the legal, regulatory, contractual and supervisory obligations applicable to El Dorado, and respond to requirements, requests, orders or actions from administrative, judicial, regulatory, tax, police or any other competent authorities.
● Manage, process, administer, monitor and follow up on the transactions, requests, orders, movements, products and services used by the Data Subject through the Platform.
● Provide customer service, manage requests, Inquiries, complaints, Claims, petitions, suggestions and other communications from the Data Subject, and monitor and evaluate the quality of the service and the Services.
● Implement and maintain security, authentication, identity verification, access control and unauthorized access prevention measures, and protect the accounts, funds, assets, information, technological infrastructure and other resources associated with the Services.
● Detect, prevent, investigate, manage and mitigate risks related to fraud, money laundering, terrorist financing, the financing of the proliferation of weapons of mass destruction, cybercrime, identity theft, abuse of the Services, illicit activities or any other irregular conduct or conduct contrary to the Platform’s terms of use.
● Carry out statistical, financial, transactional, operational and behavioral analyses, as well as segmentation, profiling, analytical models, market studies, usage trends and behavioral patterns, in order to understand, evaluate and improve the user experience and the operation of the Services.
● Develop, evaluate, test, implement and improve new products, services, functionalities, tools, technologies and solutions offered by El Dorado or related to the Platform.
● Carry out commercial prospecting, client segmentation, analysis of preferences and interests, commercial profiling and evaluation of business opportunities, in accordance with applicable regulations.
● Send communications related to the provision, operation, security, maintenance, updating or modification of the Services, including operational, technical, security, legal and administrative notices.
● Send, where appropriate and in accordance with applicable regulations, commercial, advertising or promotional communications about products, services, benefits, news, events, campaigns, contests, promotions, activities and opportunities offered by El Dorado or by third parties with which El Dorado has business relationships.
● Design, organize, manage and execute marketing campaigns, promotions, contests, events, activations, loyalty programs, benefits, incentives and other commercial activities aimed at clients and users.
● Evaluate eligibility, participation and fulfillment of conditions to access products, services, promotions, benefits, campaigns, programs, functionalities or other initiatives offered by El Dorado.
● Conduct surveys, satisfaction studies, market research, feedback activities and user experience analyses in order to understand the needs, preferences and perception of clients and users regarding El Dorado and its Services.
● Generate statistical, aggregated, anonymized or dissociated information for purposes of analysis, management, research, product development, decision-making, strategic planning and measurement of the performance of the Services, provided that such information does not directly identify the Data Subject when the purpose so requires.
● Manage the contractual, commercial and legal relationships with the Data Subject, including the management of collections, payments, invoicing, claims, disputes and other actions arising from the relationship with El Dorado.
● Manage, document and keep the records, supporting documents, evidence and traceability of the activities, transactions and communications carried out through the Platform, when necessary for the proper provision of the Services, compliance with legal obligations or the protection of El Dorado’s rights and interests.
● Carry out audit, internal control, quality review, risk management, compliance, investigation and improvement processes for El Dorado’s processes and Services.
● Share or allow access to Personal Data with suppliers, contractors, strategic partners, related entities, Data Processors and third parties that provide services to El Dorado, when such access or Processing is necessary to fulfill the purposes set forth in this Policy and in accordance with applicable regulations.
● Carry out any other activities that are necessary, related or complementary to the proper provision of the Services, the development of the relationship with the Data Subject, the protection of El Dorado’s rights and interests and compliance with applicable legal, regulatory and contractual obligations.
Evaluate and carry out the recruitment process, based on the résumé, references and proof of studies provided by the candidate; verify the identity and contact details of candidates, employees, shareholders and investors based on their DNI or passport and proof of address; evidence the status of shareholder or investor, based on the shareholder or equity interest certificate, and facilitate the exercise of their corporate rights; and verify the source of the funds contributed or invested, in accordance with the ML/TF/PF prevention policies applicable to El Dorado.
Formalize the business relationship with partners and suppliers, verifying their legal existence based on their articles of association or certificate of incorporation and their Registro Único de Contribuyente (RUC) number (or the equivalent tax identification number); evaluate their commercial suitability based on the commercial references provided; verify the identity and powers of the legal representative or attorney-in-fact based on their DNI and the corresponding power of attorney; and manage the performance of the agreement, including the payment of any amounts, commissions or withholdings and the issuance of invoices and other contractual or commercial records.
To fulfill the purposes described in this Policy, El Dorado may engage Data Processors, i.e., third parties that carry out the Processing of Personal Data on behalf of El Dorado and exclusively in accordance with its instructions. This may include, where necessary given the nature and purpose of the contracted service, the Processing of Sensitive Data, including data of a biometric nature, collected in connection with know your customer or know your counterparty processes. The actions of a Data Processor do not relieve El Dorado of its responsibility as Data Controller vis-à-vis the Data Subject.
Likewise, and depending on the type of relationship a Data Processor has with El Dorado, and where deemed appropriate given the nature of such relationship, the Data Processor may contract directly with Data Subjects to offer its own services. In such case, the Data Processor will act as Data Controller with respect to the Personal Data it processes under that direct relationship, which will be governed by its own terms and conditions and its own privacy policy, for which El Dorado will not be responsible.
El Dorado contractually requires all its Data Processors to: (i) process Personal Data exclusively for the authorized purposes and following El Dorado’s instructions; (ii) implement technical, human and administrative security measures equivalent to those required of El Dorado; (iii) keep Personal Data confidential, even after the contractual relationship has ended; (iv) not subcontract the Processing without El Dorado’s prior authorization; (v) delete or return Personal Data upon termination of the contractual relationship, unless there is a legal obligation to retain it; and (vi) cooperate with El Dorado to timely respond to Data Subjects’ Inquiries and Claims.
By accepting this Policy, the Data Subject authorizes El Dorado to transmit their Personal Data, within or outside Argentina, to the corresponding Data Processors under the terms described in Section 8.2, so that they may provide El Dorado with the operational, technological, compliance or administrative support necessary for the provision of the Services.
El Dorado may transfer Personal Data to third-party Data Controllers, within or outside Argentina, when the Data Subject so authorizes, when permitted by law or when there is an administrative or judicial order requiring it. Personal Data may be transferred, among other cases, for: (i) the proper provision of El Dorado’s Services; (ii) compliance with requirements from governmental, judicial or regulatory authorities, including competent authorities in digital asset matters; and (iii) the provision of services by technology or infrastructure providers located outside Argentina.
If El Dorado transmits Personal Data to a Data Processor, the latter will process it in accordance with this Policy. If it transfers Personal Data to another Data Controller, such Personal Data will be processed in accordance with that new Data Controller’s data protection policy, of which El Dorado will endeavor to inform the Data Subject.
International transfers of Personal Data will be carried out in accordance with section 12 of Law No. 25,326 and the supplementary regulations of the Agencia de Acceso a la Información Pública (Argentine Agency for Access to Public Information). To this end, El Dorado will adopt the necessary measures for the receiving third party to be aware of and undertake to observe the principles of this Policy, ensuring that the information received is used solely for the purposes authorized by the Data Subject and related to the provision of the Services.
By accepting this Policy, the Data Subject expressly consents to the international transfers described in Section 9.2 and in section 6.8.
El Dorado requires the free, prior, express and informed consent of the Data Subject for the Processing of their Personal Data, except where not required by law.
Authorization may be obtained through electronic documents, data messages, forms on the Platform or any other mechanism that allows the Data Subject’s consent to be unequivocally verified.
When El Dorado substantially modifies the purposes of the Processing, it will publish the changes on the Platform and request a new authorization from the Data Subject when necessary. If the Data Subject does not agree with the new purposes, they may revoke their authorization and request the deletion of their Personal Data, provided there is no legal or contractual duty preventing such deletion.
The Data Subject has the following rights:
● Access: to know whether El Dorado processes their Personal Data and, if so, to access it.
● Rectification: to request the correction or updating of their Personal Data when it is inaccurate, incomplete or outdated.
● Deletion: to request the deletion or removal of their Personal Data from El Dorado’s Databases when the Processing does not respect the applicable principles, rights and guarantees.
● Objection: to object, on legitimate grounds relating to their particular situation, to the Processing of their Personal Data for specific purposes.
● Portability: to request and obtain from El Dorado a copy of their Personal Data in a generic and commonly used format.
● To request proof of the authorization granted for the Processing of their Personal Data.
● To be informed, upon request, of the use that has been made of their Personal Data.
● To refrain from answering questions about Sensitive Data, without being obliged to authorize such Processing.
● To submit Inquiries and Claims to El Dorado in accordance with the procedure described in Section 12 and, once that procedure has been exhausted, to file complaints before the competent authority.
A request for deletion of information and the revocation of authorization will not proceed when the Data Subject has a legal or contractual duty to remain in El Dorado’s Database.
The Data Subject has the right to exercise the right of access to their data free of charge at intervals of no less than six (6) months, unless a legitimate interest is evidenced in accordance with section 14, subsection 3 of Law No. 25,326. The AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA (Argentine Agency for Access to Public Information), in its capacity as Supervisory Authority of Law No. 25,326, has the power to handle the complaints and claims filed by those whose rights are affected by non-compliance with the regulations in force on personal data protection.
A Data Subject who wishes to exercise their rights must send an email to support.admin@eldorado.io, addressed to EL DORADO LABS S.R.L, specifying: (i) the name and identification of the Data Subject or of the legitimate representative; (ii) a precise and complete description of the facts giving rise to the Inquiry or Claim; (iii) the request; (iv) the email address to which the response should be sent; and (v) the relevant documents and other evidence.
When the Data Subject wishes to access the information held in the Database, El Dorado will respond to the request within a maximum term of ten (10) calendar days from its receipt, in accordance with section 14 of Law No. 25,326.
When the Data Subject considers that their Personal Data should be rectified, updated, deleted or subject to objection, or when they notice an alleged breach of this Policy, they may file a Claim with El Dorado. If the Claim is incomplete, El Dorado may request the Data Subject to complete it.
El Dorado will address the Claim within a maximum term of five (5) business days from its receipt, in accordance with section 16 of Law No. 25,326.
The removal or deletion of Personal Data will not proceed when there is a legal or contractual duty to remain in El Dorado’s Database.
Any incident related to information security breaches will be reported internally to El Dorado’s Compliance Officer or Data Protection Officer, who will coordinate with the Technology area the adoption of the relevant corrective measures and, where applicable, will inform the competent authorities and the affected Data Subjects.
● Guarantee at all times the full and effective exercise of the Data Subjects’ rights.
● Request and keep a copy of the authorization granted by the Data Subject.
● Duly inform the Data Subject of the purpose of the collection and the rights to which they are entitled.
● Keep the information under security conditions that prevent its alteration, loss, consultation, use or unauthorized access.
● Ensure that the information is truthful, complete, accurate, up to date, verifiable and understandable.
● Update and rectify the information when appropriate, and timely communicate any changes to its Data Processors.
● Provide Data Processors only with Personal Data whose Processing has been previously authorized.
● Require Data Processors to respect the security and privacy conditions of the Data Subject’s information.
● Timely process the Inquiries and Claims submitted by Data Subjects.
● Appoint a Personal Data Protection Officer.
● Register its Databases with the competent authority, when such registration is required under applicable regulations.
● Guarantee to the Data Subject, at all times, the full and effective exercise of their rights.
● Process Personal Data only for the purposes and instructions authorized by El Dorado.
● Keep the information under the security conditions necessary to prevent its alteration, loss, consultation, use or unauthorized or fraudulent access.
● Timely carry out the updating, rectification or deletion of Personal Data as instructed by El Dorado.
● Keep the information processed confidential, even after the contractual relationship with El Dorado has ended.
● Inform El Dorado of any breaches of security codes or risks in the management of the Data Subjects’ information.
● Cooperate with El Dorado in responding to Data Subjects’ Inquiries and Claims within the terms indicated by El Dorado.
El Dorado will process the Data Subject’s Personal Data from the time the Data Subject grants their authorization until the purpose for which it was collected has been fulfilled, or until El Dorado is dissolved and liquidated, whichever occurs first. However, once the purpose has been fulfilled, El Dorado may retain the information for the period necessary to comply with legal, contractual, accounting, tax or reporting obligations before authorities, including those related to the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction (ML/TF/PF).
In any case, the Data Subject may revoke their authorization at any time through the institutional channels indicated in Section 12, subject to verification of their identity.
El Dorado implements reasonable human, administrative and technical protection measures, proportionate to the risk, aimed at ensuring the confidentiality, integrity and availability of Personal Data and preventing its alteration, loss, consultation, use or unauthorized or fraudulent access. These measures include, among others: an access management system with role-based differentiated privileges; encryption of sensitive information both in transit and at rest; the definition of internal responsibilities for the safekeeping and protection of Personal Data; and mechanisms for security incident management.
By accepting this Policy, the Data Subject expressly accepts these protection measures and declares that they consider them appropriate and sufficient for the protection of their Personal Data.
A cookie is a file that is downloaded onto the Data Subject’s device when accessing the Platform. Cookies allow, among other things, the storage and retrieval of information about the user’s browsing habits. El Dorado uses its own and third-party cookies in order to personalize the browsing experience, remember preferences, generate metrics and analytics, and track consumption habits within the Platform.
The Data Subject may reject the use of cookies through their browser settings.
El Dorado has appointed Catalina Ortega Osorio as Personal Data Protection Officer, who may be contacted at catalina@eldorado.io . Any questions, Inquiries or Claims related to this Policy may be addressed to her or to the institutional email support.admin@eldorado.io.
Any modification, update or adjustment to this Policy will be timely notified to the User through the application, also referred to as the Platform.
The User accepts and acknowledges that it is their responsibility to periodically review the application in order to become aware of such changes. Continued use of the Platform, or express acceptance within it, will be deemed full and binding acceptance of the new conditions of the Policy.
Last updated: September 29, 2026
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