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PRIVACY POLICY AND PROCESSING OF PERSONAL DATA
EL DORADO
In this privacy and personal data processing policy, "we", "us", "El Dorado" or "Company" refers to El Dorado SV SA de CV or its affiliates, subsidiaries or related companies (as specified in the table in Annex A hereto) and "our" shall be interpreted accordingly.
EL DORADO is a company that respects the Personal data provided by its current and potential clients, employees, candidates, business partners, suppliers, shareholders, investors, and potential parties interested in El Dorado's services, and for this reason, it has implemented this Privacy and Personal Data Processing Policy (hereinafter, the “ Policy ”) where we tell you what Personal Data we process, what we process it for, what your rights are as a Personal Data Owner and the mechanisms you have to exercise them.
The use of the El Dorado Platform, the execution of employment contracts, commercial alliances or the provision of services, and/or the express and unequivocal acceptance of the Policy, imply that you accept that we process your Personal Data in accordance with the provisions of this Policy.
How can you better understand this Policy?
1. Definitions. To help you better understand the Policy, we've explained what each word we use throughout this document means.
“Authorization” : is the prior, express and informed consent that you give us to process your Personal Data.
“Database”: is the organized set of Personal Data that is subject to Processing.
“ Consultation”: is the request that you, as the Data Subject, make to find out what information we have about you in our Databases.
“Anonymized Data” : This is data that does not personally identify you and that may be used by El Dorado for statistical analysis.
“Personal Data”: is any information that can be used to identify you.
“Non-Public Personal Information (NPI)” : This refers to non-public financial and transactional information of users, obtained within the framework of the provision of the Visa Prepaid Card service.
“Private Personal Data”: is data that, due to its intimate or confidential nature, is only relevant to you as the Data Subject.
“Semi-private Personal Data”: This refers to data that is neither intimate, confidential, nor public in nature, and whose knowledge or disclosure may be of interest not only to you (the Data Subject) but also to a specific sector or group of people, or to society in general. For example, financial, credit, commercial or service activity data, social security data, etc.
“ Public Data”: is data classified as such by law and all those that are not semi-private, private or sensitive.
“Sensitive Data”: is data that affects your privacy or whose misuse may generate discrimination, for example, data that reveals racial or ethnic origin, political orientation, religious or philosophical beliefs, trade union membership, as well as data relating to health, sex life and biometric data, such as fingerprints, among others.
“Data Processor”: This refers to the natural or legal person, public or private, who processes Personal Data, based on instructions from the Data Controller. El Dorado may contract certain individuals or companies to act as Data Processors for your Personal Data.
“Purpose”: is the purpose for which El Dorado will process your Personal Data.
“Source”: is the person, entity or organization that receives or knows Personal Data of Holders by virtue of a commercial or any other relationship, and that supplies this data to an information Operator, who in turn delivers it to the Holder.
“Operator”: is the person, entity or organization that receives Personal Data from the Source about several Holders, manages them and makes them known to the Holders under the parameters of Law 1266 of 2008 and other complementary regulations.
“Platform”: refers to the El Dorado website and application through which the Services are provided.
“Claim”: is the request you make to exercise your rights related to your Personal Data.
“Data Controller”: This refers to the natural or legal person, public or private, who decides on the processing of personal data, that is, who determines the purpose. In this case, the Data Controller of your personal data is El Dorado.
"Services": This refers to the different services that El Dorado provides to its users, which can be consulted through its website:https://eldorado.io/
“Owner”: is you, the natural person whose Personal Data or Non-Public Personal Information (NPI) is subject to Processing.
“Processing” means any operation we perform on your Personal Data or Non-Public Personal Information (NPI), such as the collection, storage, processing, analysis, use, circulation, transfer, transmission, updating, correction, or deletion of Personal Data, among others. Processing may be national or international.
“Transmission”: is the delivery of Personal Data to a Processor to carry out Processing on the Personal Data, according to the instructions given by the Controller within or outside the territory of El Salvador in accordance with current regulations.
“Transfer”: is the delivery of Personal Data so that another Data Controller can process the Personal Data independently, within or outside the territory of El Salvador in accordance with current regulations.
2. Scope . This Policy applies to all Personal Data or Non-Public Personal Information (NPI) held by El Dorado, who acts as the Data Controller.
3. Principles of Personal Data Processing. Personal Data Processing We will do so in accordance with the principles contained in the Law on the Protection of Personal Data and Habeas Data of El Salvador , and the regulations that update or modify them, and especially by the following principles :
▪ Purpose: The processing must have a legal purpose in accordance with the Constitution and the law, which we must inform you about.
▪ Necessity and reasonableness: The Personal Data that El Dorado has must be necessary to fulfill the purposes of the Processing.
▪ Time frame: the time during which we process Personal Data must be the time necessary to achieve the purpose for which we collected it.
▪ Freedom: We can only process your Personal Data with your prior, express, and informed consent. The Personal Data we collect may not be obtained or disclosed without your prior authorization, or without a legal or judicial mandate.
▪ Truthfulness: The information subject to processing must be true, complete, accurate, up-to-date, verifiable, and understandable. We will not process partial, incomplete, fragmented, or misleading data.
▪ Transparency : We must guarantee your right to obtain from El Dorado, at any time and without restrictions, information about the existence of your Personal Data in El Dorado's Databases.
▪ Restricted access and circulation : Personal Data that is not public will only be processed by those who need to do so to fulfill the purpose.
▪ Security : The Controller and Processor of Personal Data must comply with all necessary technical, human and administrative measures to ensure the security of Personal Data, preventing its modification, loss, consultation, use or unauthorized or fraudulent access.
▪ Confidentiality: all persons involved in the Processing of Personal Data that is not of a public nature, must guarantee the confidentiality of the information.
▪ Non-discrimination: We will not discriminate based on the Personal Data collected.
▪ Compensation : it is our obligation to compensate for damages caused by possible failures in the Processing of Personal Data.
▪ Limitation on collection : we will only collect Personal Data that is necessary for the fulfillment of the purposes of the Processing.
In turn, the processing of Non-Public Personal Information (NPI) associated with the Visa Prepaid Card service will also be done in compliance with applicable regulations in the United States.
4. When do we collect your Personal Data and what Personal Data do we collect?
Data Collection . El Dorado collects Personal Data from Data Subjects in the following cases:
▪ When the Holders visit our Platform and are interested in the Services.
▪ When the Holders contract the Platform Services.
▪ When Data Subjects voluntarily provide Personal Data, for example, when filling out El Dorado forms, whether physical or digital.
▪ When the Holders provide their Personal Data so that El Dorado can perform a check in public databases, through identity validation tools.
▪ When the starters are interested in joining the El Dorado team and send their resume or undergo a selection process.
▪ When a person has provided us with the Personal Data of a Data Subject.
▪ When you are going to enter into any type of contract with El Dorado, for example, employment, service provision, commercial alliance, partnership, mandate or any other type.
Information collected: El Dorado may request or collect, except for exceptions related to sensitive data or data of children and adolescents, the data that is necessary to fulfill the purpose, which are –among others– the following:
▪ Data we collect from all Data Subjects: name and surnames, nationality, age, marital status, identification number and photocopy of the identity document, date and place of birth, correspondence address and city of residence, contact telephone number, email address, recent photographs, sex, financial information, Personal Data that El Dorado receives from third parties including financial, commercial and credit information centers and authorized social security information operators, among others and, any other Personal Data that may be necessary to achieve the purposes described in the Policy.
▪ Data we collect from candidates, employees and shareholders of El Dorado: In addition to the data mentioned in “data we collect from all Data Subjects”, we will also collect professional card, work history, medical or health history, academic and financial history, references, judicial or disciplinary information, occupational medical history, workplace, position or profession of the Data Subject and of their spouse or permanent partner and of their relatives, resume, certificate of affiliation to health , pension and severance fund, and any other data that may be necessary to achieve the purposes described in the Policy.
▪ Data we collect from our partners and suppliers: In addition to the data mentioned in “data we collect from all Data Subjects”, we will also collect data from the legal representative, references, business history, shareholding structure, data of your employees or collaborators with whom El Dorado has contact, permits and authorizations required to provide services or sell products, and any other data that may be necessary to achieve the purposes described in the Policy and an adequate provision of the Services.
▪ Data we collect from our clients: In addition to the data mentioned in “Data we collect from all Data Subjects,” we also collect commercial information, criminal and judicial records, bank account details, browsing history on the Platform, history of open cases with customer service, information held by credit bureaus, risk centers, and other public lists, and any other data necessary to achieve the purposes described in this Policy. We clarify that we use identity verification tools, which allow us to consult your information in public databases such as the Attorney General's Office, the National Registry, the Comptroller General's Office, the Single Transit Registry, your social security information, the National Police, and international restricted lists.
▪ Sensitive data and its processing. Taking into account the characteristics of Our service, El Dorado It requires processing some sensitive data, such as the photo of your ID card containing your fingerprint and photos, and in some cases requires analyzing this information through biometric techniques. However, El Dorado will only collect and process Sensitive Data in cases permitted by law. In these cases, we will inform you that you are not obligated to provide Sensitive Data or authorize its Processing. If you are unable to authorize the Processing of your Sensitive Data, El Dorado will not be able to continue with the identity verification process, and therefore we will be unable to continue providing the Services. If you give us your authorization to process your Sensitive Data, we will collect and process it only for the purposes described in this Policy.
▪ Personal data related to minors . El Dorado will only use, store, and process publicly available personal data of minors. The purpose of such processing will be solely to plan and carry out activities related to the personal and family well-being of employees and their children. Only adults, or minors duly represented by their legal guardians, may access El Dorado's services.
▪ Image Data . By participating in any videoconference or event sponsored by El Dorado, you agree and authorize the use of your name and image in programs, publications, and other advertising media, and in general, in all promotional or commercial materials that El Dorado may wish to use for a period of 50 years, without any obligation to remunerate or compensate you for your participation. By accepting this Policy, you waive any claim against El Dorado regarding image rights.
5. Why do we collect your Personal Data?
General Information on the Purpose. El Dorado will process Personal Data in accordance with the conditions established by the Data Subject for the development of its economic activity. In general, El Dorado will collect, store, organize, circulate, use, transmit, and transfer Personal Data in accordance with the purposes set forth below:
▪ Common purposes for all Holders: To fulfill the corporate purpose of El Dorado; to preserve and manage information about the employment, civil or commercial relationship of the Holders; to comply with the legal, accounting, commercial and regulatory duties that apply to El Dorado; to access, collect and process the personal data that El Dorado receives from third parties, including financial, commercial , credit and credit information centers; to control and preserve the security of El Dorado's people, assets and information; to fulfill the purpose of the employment, commercial, or civil relationship that El Dorado has with the Data Subjects; to store the Data Subject's Personal Data on El Dorado's servers; when the information must be disclosed to comply with laws, regulations, or legal processes, to stop or prevent fraud, attacks on the security of El Dorado or others, as well as to prevent technical problems or protect the rights of others; to prevent and verify the commission of crimes or criminal conduct by the Data Subjects, for which various databases, national and international restricted lists, and sources such as Interpol, FBI, OFAC databases, among others, as well as the corresponding social networks, may be consulted; to comply with regulations for the prevention of money laundering and the financing of terrorism; to maintain direct communication with the Data Subjects for matters related to their employment, civil, or commercial status and for contractual, informational, and commercial purposes; and to carry out statistical, commercial, financial, social, administrative, or technical analyses. To share information with government authorities or regulatory entities as required by applicable law or in accordance with an administrative, court, or similar order; to verify the identity and criminal, judicial, disciplinary, financial, and credit history of the Data Subjects; to transmit, transfer, and supply the information and Personal Data of the Data Subjects to the parent company or other companies within the El Dorado business group, so that they may store, consult, or act as Processors or Controllers of the Personal Data, as applicable; to contact the Data Subject via the internet or telephone calls, physical and telephone correspondence, text message, WhatsApp, Instagram, Facebook, Twitter, LinkedIn, Telegram, Messenger, or any other social network and/or videoconferencing platform for the purpose of contractual development; to transmit, transfer, and supply the information and Personal Data of the Data Subjects to business partners or other national and/or international companies or individuals that El Dorado commission the processing of information to fulfill the purposes described in this Policy and the object of the commercial or civil relationship with the Data Subjects, or for said third parties to assume the position of Controllers; carry out marketing activities, such as market research, and carry out acts of promotion of services, among other similar concepts; transmit, transfer and supply the information and Personal Data of the Data Subjects to national or international third parties, in those cases in which El Dorado has the interest of marketing in any way the Personal Data as an asset of a commercial nature; attend to Inquiries, requests, applications, actions and Claims, made by the Data Subject; make invitations to events; the Personal Data may be used, among others, as evidence in any type of process.
▪ Purposes for which we process the Personal Data of candidates, employees, shareholders, and investors of El Dorado: To protect the health of El Dorado's employees and contractors; to verify conflicts of interest, as well as disqualifications or incompatibilities; to select personnel, manage hiring, handle labor and social relations, and provide benefits to its employees directly or through third parties, as well as to allow employees access to El Dorado's computer resources; to keep a record of disciplinary sanctions imposed on El Dorado's contractors and employees; to transmit, transfer, and supply the information and Personal Data of the Data Subjects to those third-party Processors or Controllers, in cases where there is a change of employer or in cases where El Dorado assigns its contractual position, or when it is part of an acquisition or business integration process; to make contributions to the general social security system; to transmit, transfer and supply the information and Personal Data of the Holders to third parties, in order to give employment and/or professional references about the Holders; to evaluate and develop selection processes and their history; for the exercise of the development of the rights of the shareholders and the operation of the general shareholders' meeting, among others.
▪ Purposes for which we process the Personal Data of our suppliers and partners: To provide commercial references; to manage the payment of remunerated sums, commissions, discounts and withholdings of a tax or parafiscal nature; to send invoices; to issue contractual or commercial certificates.
▪ Purposes for which we process the Personal Data of our clients: To consult and validate the information of the Data Subjects in public and restricted lists and determine the risk profile of the Data Subject, fulfill the value proposition and the level of service offered to each client and provide the Services; transmit, transfer and supply, free of charge or for a fee, the information and Personal Data of the Data Subjects to national and/or international business partners so that they may contact the Data Subjects to offer them their products, information or services that in El Dorado's judgment may be of interest to the Data Subject; improve services, and all those activities associated with the commercial relationship or link existing or to exist with El Dorado, as well as evaluate the need for new services and products for our clients; contact the Data Subject by email to send statements, invoices and account statements in relation to the obligations arising from the contract entered into with El Dorado; To carry out commercial profiling, prospecting, analysis of consumption habits, analytics, identification of marketing trends, and definition of patterns, with or without the use of artificial intelligence tools, among other data utilization methods for the purpose of improving the Services; to define customer consumption profiles in order to perform statistical analyses or improve the marketing and sales processes of El Dorado's services; to conduct marketing and advertising studies and strategies; to carry out marketing activities and send advertising from El Dorado and/or third-party business partners; to monitor customer behavior within the Platform and determine customer intentions; to optimize the functionalities of the Platform; to perform risk models and business growth analyses to advance adequate risk management; for collection or remuneration management; to validate the Holder's information on restricted lists through identity validation tools; to inform control entities about transactions carried out with crypto assets; to inform about the scope and characteristics of El Dorado's services, new and existing solutions.
▪ Transmission and Transfer of Personal Data: El Dorado may transfer or transmit Personal Data to one or more Processors or Controllers located within or outside the territory of El Salvador when you authorize us to do so, or when required by law or an administrative or judicial order. By accepting this Policy, you authorize us to transfer or transmit your Personal Data to our partners, suppliers, our Parent Company, or cloud computing service providers solely for the Purposes established in this Policy. It is important to clarify that if El Dorado transmits your data to third parties, they will process your Personal Data in accordance with this Policy, but if we transfer your Personal Data, your Personal Data will be processed in accordance with the data protection policy of the new Data Controller.
6. Non-Public Personal Information (NPI) – Visa Prepaid Card Service:
For the provision and administration of the Visa Prepaid Card service, and in compliance with applicable regulations in the United States, El Dorado may collect, use and process Non-Public Personal Information (NPI) from users.
Non-Public Personal Information (NPI) includes, but is not limited to, financial and transactional information related to the use of the product. Non-Public Personal Information collected in connection with the Visa Prepaid Card will be used exclusively for routine business purposes, including, but not limited to:
● The issuance, activation and administration of the Visa Prepaid Card.
● The processing, authorization, and settlement of transactions.
● The maintenance and operational management of the services associated with the card, including its support.
● Fraud prevention, compliance with obligations regarding the prevention of money laundering and terrorist financing, and other applicable legal and regulatory obligations.
● Other associated purposes.
For these purposes, the Company shares the NPI with Bridge Ventures LLC and Lead Bank (in its capacity 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 unaffiliated 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 the NPI will be carried out in accordance with applicable legislation, agreements with the issuing bank and the principles of confidentiality, security and data minimization.
7. What happens to the authorization you give us to process your Sensitive Data or if we are going to use your Personal Data for another Purpose?
Authorization for the Processing of Sensitive Data: When El Dorado collects Sensitive Data or data from minors, the following requirements must be met:
▪ Your authorization must be explicit;
▪ We will inform you that you are not obliged to authorize the processing of this information.
▪ We will inform you explicitly and in advance what Sensitive Data we will process and the Purpose of the Processing;
Authorization for new uses or purposes: El Dorado will request your authorization for new uses of your Personal Data. We will publish any changes to this Policy on our Platform or through any other means we deem appropriate, and we will notify you of the change. If you do not agree with the new purposes, you may revoke your authorization, and we will delete your Personal Data, provided we have no legal obligation to retain it.
Abstention from collecting data related to criminal records . El Dorado will only process your Personal Data related to criminal records for the sole and exclusive purpose of ensuring the legality of its operations, the security of El Dorado and its stakeholders, and to prevent fraud and money laundering and terrorist financing.
8. What are “Cookies” and what do we use them for?
Cookies . A cookie is a harmless file that is downloaded to your device when you access certain websites. Cookies allow us, among other things, to store and retrieve information about a user's browsing habits and trends, or their computer. El Dorado uses its own cookies and third-party cookies (for example: HubSpot, Core, or Google Analytics).
Information stored by cookies. Cookies store technical information, such as personal preferences, content customization, information you have previously entered in a form to avoid having to fill it out again, your interactions with our Platform, among other information that allows us to remember you.
Purposes for which we use the information collected through cookies. El Dorado uses cookies to provide you with a high-value service by saving your preferences, how, when, and in what way you use our Platform, as well as all information that may be useful for tracking your consumption habits. We also use them to personalize your browsing experience, to generate metrics and analytics about visitors to our Platform, and to gather information that allows us to improve our content and services. We will not collect debit or credit card numbers, or other financial or credit information. You can refuse the use of cookies through the appropriate settings in your browser; however, please note that if you do so, we will not track your information when you visit our Platform, and it may not function properly. If you choose to disable cookies, we will only use a cookie in your browser to remember your preference not to use cookies.
9. What are you indicating when you click on “I authorize the processing of my Personal Data” in accordance with El Dorado's Personal Data Processing Policy?
Declarations of Personal Data Holders . When voluntarily providing your Personal Data and/or granting written authorization, you declare that:
▪ You voluntarily provide us with your Personal Data and expressly and unequivocally authorize us to collect your Personal Data and any other information you provide, and to carry out any other Processing of your Personal Data, in accordance with this Policy.
▪ You were informed and understand that Sensitive Data is data that affects the privacy of the Data Subject or whose misuse may lead to discrimination. Likewise, you understand that this may include data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, membership in social organizations, data related to health status, sex life, and biometric data.
▪ You were informed that, in the event of collection of Sensitive Data, you have the right not to provide the requested data and you understand and accept that in some cases, if you do not grant us authorization for the Processing of your Personal Data, we will not be able to continue with the validation of your identity, and therefore we will not be able to provide our Services.
▪ You were informed about the purposes for which your Personal Data and Sensitive Data collected will be used, which are described in this Policy.
▪ You were informed and understand the security measures that El Dorado implements to provide protection to the Personal Data it collects and, therefore, you accept them.
▪ You were informed about your rights in relation to your Personal Data and mechanisms to exercise them.
▪ If you are a customer, you were informed that you will enter into or have a current contract with El Dorado, and therefore El Dorado needs to be in constant contact with you and your right to update your Personal Data will be subject to us verifying that you actually have access to the new contact information you are providing.
10. How long will we process your data?
Term of Authorization: We will process your Personal Data from the moment you grant us the Authorization, until the day El Dorado is dissolved and liquidated or until the purpose for which the Personal Data was collected is fulfilled.
11. How do we protect your Personal Data?
Security measures for the protection of Personal Data and other information . The security measures with which El Dorado's account seeks to protect the data of its users to prevent its alteration, loss, unauthorized use, and unauthorized access. El Dorado diligently implements human, administrative, and technical protection measures that are reasonably within its reach, such as having an access management system and sharing information in encrypted form, among others. By accepting this Policy, you expressly accept these forms of protection and declare that you consider them appropriate and sufficient to protect your Personal Data.
Policy for the deletion and/or erasure of Personal Data. Once the purpose of processing your Personal Data has been fulfilled, and provided there is no contractual or legal obligation preventing it, El Dorado will proceed to delete or erase your Personal Data, in accordance with the following parameters:
▪ El Dorado will annually evaluate the information it holds about Data Subjects and, based on its characteristics and status, will select the data it deems, at its discretion, to be deleted or removed. In making these decisions, it will consider whether Data Subjects have rights that prevent the deletion of their Personal Data or whether there are legal, contractual, or constitutional obligations that prevent its removal.
▪ El Dorado will inform Data Subjects in advance of the decision and the grounds for the deletion of their Personal Data. Data Subjects may exercise their right to submit inquiries, requests, or complaints regarding this decision within fifteen (15) business days following notification, through the established channels. Inquiries, requests, or complaints will follow the procedures established in this Policy. If no complaint or request is received regarding the decision, the data will be deleted.
▪ El Dorado will submit the corresponding minutes and records regarding the processes of suppression and elimination of the Personal Data of the Holders, for the purposes of traceability of the procedure.
Confidentiality, fundamental rights, and anonymization of Personal Data. El Dorado respects the fundamental rights to privacy, freedom of expression, and the good name and honor of the Data Subjects, and therefore will take the measures it deems appropriate regarding confidentiality, such as the following:
▪ It will refrain from disclosing, in whole or in part, the confidential information received to any natural or legal person, governmental or private entities, that has not been previously authorized.
▪ You will refrain from using, exploiting, employing, publishing or disclosing confidential information in a manner other than as authorized in the Policy.
▪ It will instruct all those who may eventually have access to confidential information on how to handle, use, manage security measures and so forth, so that said information remains properly handled and protected.
▪ The use of confidential information will be carried out observing the principles of ethics and good practices in the protection of Personal Data.
▪ El Dorado will anonymize the Personal Data of Data Subjects when it considers that such anonymization may affect their right to privacy, reputation, and honor. In any case, El Dorado, upon request from Data Subjects and upon presentation of the reasons for doing so, will carry out the corresponding anonymization of any Personal Data.
Policies on truthfulness and quality of information . In accordance with the principle of truthfulness and quality of information, El Dorado will take the necessary measures to ensure that the information contained in its databases is true, complete, accurate, up-to-date, verifiable, and understandable. Therefore, it requests from data subjects the information necessary and comprehensive for the purposes of the respective processing. Likewise, it will request the necessary supporting documentation to ensure that the information in its databases is verifiable and accurate. For the aforementioned purposes, El Dorado will implement the following measures:
▪ It will take all necessary measures to ensure that the information collected from Data Subjects is complete, accurate, up-to-date, verifiable, and understandable. To this end, it will implement due diligence measures in the data collection methods used for such purposes.
▪ It will refrain from processing the Personal Data of the Holders with partial, incomplete, fragmented or confusing information.
▪ It will verify the identity of the Holders and the information provided to it, requesting the accreditation documents that are necessary in each particular case, and may request, among others, the following: Citizenship card, RUT, judicial and police records, credit history, certifications from private and/or public entities.
12. What are your rights as a Data Subject and how can you exercise them?
Rights of Data Subjects . You have the right to know, update, and correct your information, and/or revoke your consent for the processing of your personal data. Here we explain your rights in detail:
▪ You have the right to know, update, and correct your Personal Data. To do this, we need to verify your identity beforehand to prevent unauthorized access to your Personal Data. If you wish to update your Personal Data, we must first verify that you have access to the new Personal Data you will be providing. We will implement a mechanism to confirm this. If we are unable to verify your access, you will only be able to update one of your contact details (email address, phone number, bank account, etc.). This is because we need to maintain direct communication with you to fulfill our contractual obligations and yours. In any case , for technical reasons and due to the development of the products and services offered, there may be limitations regarding changes to some personal data, such as email address or phone number. In such cases, we may not be able to grant your update request, and you will have the right to request the deletion of your personal data.
▪ Request proof of the Authorization granted, unless it is a case in which authorization is not necessary, in accordance with current legislation.
▪ To be informed, upon request, regarding the use that has been made of your Personal Data.
▪ You may revoke your authorization and/or request the deletion of your Personal Data. In this case, we will delete your personal data according to our deletion policy when possible. For technical reasons and due to the Holder's historical data, it may not be possible to delete your transaction history on the Platform, including for tax, government reporting, and accounting purposes.
▪ Access your Personal Data that has been processed, free of charge.
▪ Please refrain from answering questions about sensitive data or data concerning children and adolescents. In this case, we will inform you that you are not obligated to provide authorization for the processing of sensitive data or data concerning children and adolescents.
▪ The request for deletion of information and revocation of the Authorization will not proceed when you have a legal or contractual duty to remain in the El Dorado Database.
▪ El Dorado guarantees that any direct marketing or market research you receive via email will provide easy ways to unsubscribe from future email communications. For example, the email will include an "unsubscribe" link or an email address to submit an opt-out request. In these cases, your Personal Data will not necessarily be removed from the databases; rather, your change in direct marketing preferences will be noted and respected.
Procedure for exercising your rights . In case you wish to exercise your To exercise your rights, you must send an email to soporte@eldorado.io , which will be handled by El Dorado's data protection department. This email must be addressed to El Dorado SV SA de CV and must specify: (i) the name and identification of the data subject or their authorized representative; (ii) a precise and complete description of the facts giving rise to the claim; (iii) your demands; (iv) a physical or email address to which the response should be sent; and (v) any relevant documents and other evidence you wish to submit.
The procedure we will follow for this communication will be the following:
▪ When the Holder of the If you wish to consult the Personal Data held in the Database, El Dorado will respond to the request within a maximum period of ten (10) days.
▪ When the Data Subject considers that the information contained in the Databases should be corrected, updated or deleted, or when they believe that El Dorado is failing to fulfill its duties, they may file a complaint with El Dorado, which will be processed under the following rules:
1. The claim must be addressed to El Dorado SV SA de CV with the following information: (i) identification of the Data Subjects, (ii) a description of the facts that giving rise to the Claim, (iii) the address, (iv) the documents that are to be used as evidence will be attached. If the Claim is incomplete, El Dorado may request the Holder to complete it within five (5) days following receipt of the Claim. If two (2) months have passed since the date of the request, without the Holder submitting the required information, we will understand that the Holder has withdrawn the claim.
2. If El Dorado is not competent to resolve the Claim, we will share it with the appropriate party within a maximum of two (2) business days and inform the Holder of the situation.
3. Once we receive the complete Claim, we will add a note stating "Claim in process" where the Personal Data and the reason for the Claim are located, within a period of no more than two (2) business days. We will keep the note until the Claim is resolved.
4. El Dorado will address the Claim within a maximum of fifteen (15) business days from the day after it was received. If we are unable to address the Claim within this timeframe, we will inform the Data Subject of the reasons for the delay and the date on which their Claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the initial timeframe. The removal or deletion of Personal Data will not be permitted when there is a contractual obligation to remain in the Database of El Dorado.
13. What obligations does El Dorado have regarding the processing of your personal data?
Duties of El Dorado in its capacity as Data Controller. El Dorado She is obligated to fulfill the duties imposed by law. Therefore, she must act in such a way as to fulfill the following duties:
▪ To guarantee you, at all times, the full and effective exercise of your rights mentioned in this Policy.
▪ To process your Personal Data in accordance with the principles established in this Policy.
▪ Keep the information under the necessary security conditions to prevent its alteration, loss, consultation, use or unauthorized or fraudulent access.
▪ Update the information when necessary.
▪ Correct your Personal Data when appropriate.
▪ Provide the Data Controller only with Personal Data whose processing has been previously authorized.
▪ Ensure that the information provided to the Data Processor is truthful, complete, accurate, up-to-date, verifiable and understandable.
▪ Inform the Data Controller in a timely manner of any changes regarding the Personal Data that you have previously provided and take all other necessary measures to ensure that the information provided to the Data Controller remains up to date.
▪ Inform the Data Controller in a timely manner of any corrections made to Personal Data so that they can make the necessary adjustments.
▪ Demand that the Data Controller respect the security and privacy conditions of your Personal Data at all times.
▪ Inform the Data Controller when certain information is under discussion by the Data Subject, once the complaint has been filed and the respective process has not been completed.
▪ Report to the Superintendency of Industry and Commerce when violations of security codes occur and there are risks in the management of the information of the Holders.
▪ Comply with the instructions and requirements issued by the Superintendency of Industry and Commerce.
▪ Guarantee ARCO-POL rights according to applicable legislation.
▪ Appoint a data protection officer.
14. What other information do you need to know?
Contact. Any questions or requests for additional information will be received and processed. via the following emailsupport@eldorado.io
Delegate: Catalina Ortega Osorio - catalina@eldorado.io
Changes to the Personal Data Processing and Protection Policy. Any modification, update, or adjustment to this policy will be promptly notified to the User . through the application, also called the Platform .
Last update: January 8 , 2026 .
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