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In this Privacy and Personal Data Processing Policy, “we”, “us”, “El Dorado” or “the Company” refers to EL DORADO LABS PY INC 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 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, what it is processed for, what the rights of the Personal Data Holder are, and the mechanisms available 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 this Policy, imply that the Holder accepts that his Personal Data be processed in accordance with what is established 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 within the framework of the development of its corporate purpose and its commercial activities, present or future, regardless of the specific services through which said activities are carried out.
The Policy also includes data of legal entities when it is appropriate to process the data of their legal representative, attorney or shareholders, for the purposes of corporate compliance, identity verification (KYC) and prevention of money laundering, terrorist financing and proliferation of weapons of mass destruction (ML/TF/FPADM).
“Authorization”: is the prior, express and informed consent that the Holder grants to El Dorado for the Processing of his Personal Data.
“Database”: an organized set of Personal Data that is processed by El Dorado.
“Non-Public Personal Information (NPI)” : refers to the non-public financial and transactional information of users, obtained within the framework of the provision of the Visa Prepaid Card service.
“Consultation”: a request made by the Holder to find out what information El Dorado has about him in its Databases.
“Personal Data”: any information relating to a natural person that identifies or makes him or her identifiable.
“Sensitive Data”: data that affects the privacy of the Data Subject or whose misuse may generate discrimination, such as racial or ethnic origin, political orientation, religious or philosophical beliefs, trade union membership, health data, sexual life and biometric data.
“Data Processor”: natural or legal person, public or private, who alone or in association with others carries out the Processing of Personal Data on behalf of and following the instructions of El Dorado, in its capacity as Controller.
“Purpose”: the purpose for which El Dorado processes the Holder’s Personal Data.
“Platform”: El Dorado website and application through which the Services are provided.
“Claim”: request from the Holder to exercise their rights related to their Personal Data.
“Data Controller”: natural or legal person who decides on the Processing of Personal Data, that is, who determines its purpose.
“Services”: services provided by El Dorado to its users, which can be accessed through its website and application.
“Data Subject”: natural person whose Personal Data is subject to Processing.
“Processing”: any operation on Personal Data, such as collection, storage, use, circulation, transmission, transfer, updating, correction or deletion, whether at the national or international level.
“Transmission”: delivery of Personal Data to a Processor, inside or outside of Panama, so that the Processor may carry out the Processing following the instructions of El Dorado.
“Transfer”: delivery of Personal Data to another Data Controller, within or outside of Panama, for the latter to process them autonomously.
The processing of personal data by El Dorado is governed by the following principles:
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.
The Data Controller for the Personal Data covered by this Policy is EL DORADO LABS PY INC, a company incorporated under the laws of the Republic of Panama, and identified with RUC No. 155778564-2-2026.
EL DORADO LABS PY INC may transmit and/or transfer Personal Data, nationally and internationally, to the Processors and Controllers with whom it is related for the development of its activities, for which it will adopt the relevant legal and contractual mechanisms that guarantee the principles indicated in this Policy, as detailed in Section 9.
El Dorado collects Personal Data from Data Subjects, among others, in the following cases:
In general, from all Data Subjects, El Dorado may collect, among other things: names and surnames or company name/denomination, depending on whether it 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 the company's incorporation registration; 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 information may be collected from Platform clients and users: commercial and transactional profile information; data on the account(s) or wallet(s) used to operate on the Platform; P2P transaction history; browsing history on the Platform; history of open cases with customer service; information contained in national and international restricted lists; age; type and number of identity document, along with a legible and valid image thereof; biometric verification of the client's liveness; and information on their economic activity and the origin of their funds. When the client is a legal entity, the following information 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 number or authorization and the issuing authority; name, address and email address of its Compliance Officer; Identification of its ultimate beneficial owners, shareholders, and whether any of them are politically exposed persons or subject to international sanctions; information on its geographic scope, its clients, and its program for the prevention of money laundering, terrorist financing, and proliferation of weapons of mass destruction (ML/TF/WMD); and supporting documentation such as recent financial statements, certificate of incorporation, articles of association or partnership agreement, register of shareholders, register of directors or officers, and proof of address, as well as any other type of information required for the fulfillment of the Processing purposes stated in Section 7 of this Policy, and the proper provision of El Dorado's Services.
In addition to the general data indicated in section 6.2, the following documents may be collected from candidates, workers, shareholders and investors of El Dorado: resume or curriculum vitae; personal and work references; academic records and certifications; personal identity card or passport; proof of address; and, where applicable, shareholder or social participation certificate and documentation on the origin of the funds contributed or invested.
In addition to the general data indicated in section 6.2, the following documents may be collected from El Dorado's partners and suppliers, among others: notice of operation, articles of incorporation or certificate of incorporation duly registered in the Public Registry (or equivalent entity); Unique Taxpayer Registry number (RUC) (or equivalent tax identification document); commercial references; personal identity card of the legal representative or attorney; the power of attorney or document that accredits said representation; and other documentation necessary for the execution of the corresponding contract or commercial relationship.
Given the characteristics of the Service, El Dorado may process some Sensitive Data, such as the image of the Holder's identity document and their photograph, obtained through biometric verification of proof of life carried out as part of the identity verification process (KYC), as well as any other Sensitive Data that is necessary for the fulfillment of the purposes described in this Policy and the proper provision of the Services.
El Dorado will only collect and process Sensitive Data in permitted cases and will always inform the Data Subject that they are not obligated to provide it or authorize its processing. If the Data Subject does not grant such authorization, El Dorado will not be able to continue with the identity verification 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 Holder 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 appropriate, in photographs, videos, recordings, transmissions, interviews, testimonials and other audiovisual or graphic content generated on the occasion of said activities.
This authorization includes the use of these contents in advertising pieces, communication and marketing campaigns, social networks, websites, digital platforms, audiovisual material, printed material, commercial communications, presentations, events, brand activations, promotional dynamics, contests, institutional publications and other means or channels of communication, current or that may be developed in the future, for informative, institutional, promotional, advertising or commercial purposes related to El Dorado, its products, services, activities, initiatives or brand.
In principle, the Holder's participation and authorization to use their name, image, voice, and/or participation will not entitle them to any remuneration, royalty, compensation, or other consideration. However, the parties may agree in good faith, before or after a specific activity, to a specific economic consideration or condition when, due to the characteristics, scope, duration, nature, or purpose of the participation or the use of the content, they deem it appropriate. Any agreed-upon consideration must be specified in the terms defined by the parties for the corresponding activity.
The Owner understands and accepts that the content may be used individually or jointly with other content, as well as edited, cut, adapted or incorporated into different pieces or formats, provided that its use does not imply an illegitimate impairment of his honor, good name or dignity.
6.8. 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:
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.
6.9. User rights and limitations on the use of the NPI
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
El Dorado will process Personal Data to: fulfill its corporate purpose and provide its services; maintain and manage information related to the employment, civil, or commercial relationship with the Data Subjects; comply with legal, accounting, commercial, and regulatory obligations; control and preserve the security of El Dorado's persons, assets, and information; store Personal Data on its servers or those of its Processors; disclose information when necessary to comply with legal processes, prevent fraud, or protect the security of El Dorado or third parties; prevent and verify the commission of crimes, for which it may consult national and international databases and restricted lists; comply with regulations on the prevention of money laundering, terrorist financing, and the proliferation of weapons of mass destruction (ML/TF/WMD); maintain direct communication with the Data Subjects for contractual and informational purposes; conduct statistical, commercial, financial, and administrative analyses; and address inquiries, requests, and complaints.
For customers and users of the Platform, El Dorado will also process Personal Data for:
Evaluate and advance the personnel selection process, based on the resume, references and educational documentation provided by the candidate; verify the identity and contact information of candidates, employees, shareholders and investors using their personal identity card or passport and proof of address; accredit the status of shareholder or investor, based on the shareholder or social participation certificate, and facilitate the exercise of their corporate rights; and verify the origin of the funds contributed or invested, in accordance with the policies for the prevention of money laundering, financing of terrorism and proliferation of weapons of mass destruction (ML/FT/WMD) applicable to El Dorado.
Formalize the commercial relationship with partners and suppliers, verifying their legal existence based on the social pact or certificate of incorporation and their Unique Taxpayer Registry number (RUC) (or the tax identification number that replaces it); evaluate their commercial suitability based on the commercial references provided; verify the identity and powers of the legal representative or attorney based on their personal identity card and the corresponding power of attorney; and manage the execution of the contract, including the payment of the sums, commissions or withholdings that may be due and the issuance of invoices and other contractual or commercial records.
To fulfill the purposes described in this Policy, El Dorado may use Data Processors, that is, third parties who process Personal Data on behalf of El Dorado and exclusively following its instructions. The actions of a Data Processor do not relieve El Dorado of its responsibility as the Data Controller towards the Data Subject.
Notwithstanding the foregoing, depending on the type of relationship the Data Processor has with El Dorado, and when deemed appropriate given the nature of that relationship, the Processor may contract directly with the Data Subjects to offer its own services. In such cases, the Processor will act as the Data Controller with respect to the Personal Data it processes by virtue of 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) maintain confidentiality regarding Personal Data, even after the contractual relationship has ended; (iv) not subcontract the Processing without prior authorization from El Dorado; (v) delete or return Personal Data upon termination of the contractual relationship, unless legally obligated to retain it; and (vi) collaborate with El Dorado to promptly address the Inquiries and Complaints of Data Subjects.
By accepting this Policy, the Holder authorizes El Dorado to transmit their Personal Data, within or outside of Panama, to the corresponding 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 of Panama, when authorized by the Data Subject, when permitted by law, or when required by an administrative or judicial order. Personal Data may be transferred, among other cases, for: (i) the proper provision of El Dorado's Services; (ii) compliance with requirements of governmental, judicial, or regulatory authorities, including competent authorities regarding digital assets; and (iii) the provision of services by technology or infrastructure providers located outside of Panama.
If El Dorado transfers Personal Data to a Processor, the Processor will process it in accordance with this Policy. If El Dorado transfers Personal Data to another Controller, the Personal Data will be processed in accordance with that new Controller's data protection policy, which El Dorado will endeavor to inform the Data Subject of.
For all international transfers of Personal Data, El Dorado will adopt the necessary contractual and technical measures to ensure that the receiving third party is aware of and agrees to observe the principles of this Policy, guaranteeing that the information received is used only for the purposes authorized by the Data Subject and related to the provision of the Services.
El Dorado requires the free, prior, express and informed consent of the Data Subject for the Processing of their Personal Data, except in cases where the law does not require it.
Authorization may be obtained through electronic documents, data messages, forms on the Platform or any other mechanism that allows the unequivocal verification of the Holder's consent.
When El Dorado substantially modifies the purposes of the Processing, it will publish the changes on the Platform and request 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 obligation preventing such deletion.
The Holder has the following rights:
The request for cancellation of information and the revocation of authorization will not proceed when the Holder has a legal or contractual duty to remain in the El Dorado Database.
The Data Subject who wishes to exercise their rights must send an email to support.admin@eldorado.io, addressed to EL DORADO LABS PY INC, specifying: (i) name and identification of the Data Subject or the authorized person; (ii) precise and complete description of the facts that give rise to the Inquiry or Complaint; (iii) claim; (iv) email address to send the response; and (v) the relevant documents and other evidence.
When the Data Subject wishes to consult the information held in the Database, El Dorado will respond to the request within a maximum period of fifteen (15) business days from its receipt. If it is not possible to respond to the request within this period, the Data Subject will be informed of the reasons for the delay and the date on which it will be addressed, which in no case may exceed five (5) business days following the expiration of the first period.
When the Data Subject believes that their Personal Data should be rectified, canceled, or objected to, or when they notice a suspected breach of this Policy, they may file a Complaint with El Dorado. If the Complaint is incomplete, El Dorado may request the Data Subject to complete it within five (5) business days of receiving it; if two (2) months elapse without the Data Subject providing the required information, it will be understood that they have withdrawn the Complaint.
El Dorado will address the Claim within a maximum of fifteen (15) business days from the day following its receipt. If it is not possible to address it within this period, the Holder will be informed of the reasons for the delay and the new date of service, which may not exceed eight (8) business days following the expiration of the first period.
The removal or cancellation of Personal Data will not be permitted when there is a legal or contractual obligation to remain in the El Dorado Database.
Any incident related to information security breaches will be reported internally to the Compliance Officer or Data Protection Officer of El Dorado, who will coordinate with the Technology area the adoption of the relevant corrective measures and, when appropriate, will inform the competent authorities and the affected Data Subjects.
El Dorado will process the Holder's Personal Data from the moment the Holder grants their authorization until the purpose for which it was collected is 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 to authorities, including those related to the prevention of money laundering, terrorist financing, and the proliferation of weapons of mass destruction (ML/TF/WMD).
In any case, the Holder may revoke their authorization at any time through the institutional channels indicated in Section 12, after verification of their identity.
El Dorado implements reasonable and proportionate human, administrative, and technical safeguards to ensure the confidentiality, integrity, and availability of Personal Data, preventing its alteration, loss, unauthorized or fraudulent access, use, or disclosure. These measures include, among others: an access management system with differentiated privileges based on user role; encryption of sensitive information both in transit and at rest; the definition of internal responsibilities for the preservation and protection of Personal Data; and the existence of mechanisms for managing security incidents.
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 to the user'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 to personalize the browsing experience, remember preferences, generate metrics and analytics, and track consumption habits within the Platform.
The Owner may reject the use of cookies by configuring their browser.
El Dorado has appointed Catalina Ortega Osorio as its Data Protection Officer, who can be contacted at catalina@eldorado.io . Any questions, inquiries, or complaints related to this Policy can be directed to Ms. Ortega or to the institutional email address support.admin@eldorado.io.
Any modification, update or adjustment to this Policy will be notified to the User in a timely manner through the application, also referred to as the Platform.
The User accepts and acknowledges that it is their responsibility to periodically review the application for any changes. Continued use of the Platform, or express acceptance within it, will be understood as full and binding acceptance of the new Policy terms.
Last modified: September 11, 2026
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