PRIVACY POLICY AND PERSONAL DATA PROCESSING
EL DORADO
In this privacy and personal data processing policy, "we," "us," "El Dorado," or "Company" refer 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 construed 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 interested parties in El Dorado's services. For this reason, it has implemented this Privacy and Personal Data Processing Policy (from now on, the "Policy") where we tell you what Personal Data we process, why we process it, what your rights are as the Owner of Personal Data, and the mechanisms you have to exercise them.
The use of the El Dorado Platform, the conclusion of employment contracts, commercial alliances, or the provision of services, and the express and unequivocal acceptance of the Policy imply that you agree that we process your Data according to the provisions of this Policy.
How can you better understand this policy?
Definitions. We will explain the meaning of each word used throughout this document to help you better understand the policy.
“Authorization”: is the prior, express, and informed consent you give us to process your Personal Data.
“Database”: is the organized set of Personal Data subject to Processing.
“Query”: is the request that you, as the Owner, make to know the information we have about you in our databases.
“Anonymized Data”: is data that does not personally identify you and that El Dorado may use for statistical analysis.
“Personal Data”: is any information that can be used to identify you.
“Private Personal Data”: is data that is only relevant to you as the Data Subject due to its intimate or reserved nature.
“Semi-private Personal Data”: is data that is not intimate, reserved, or public and whose knowledge or disclosure may interest you (the Owner) and a particular sector or group of people or society in general. For example, financial data, credit data, commercial or service activity data, social security data, etc.
“Public Data”: all data that is not semi-private, private, or sensitive.
“Sensitive Data”: is data that affects your privacy or whose misuse may lead to discrimination. Examples include data that reveals racial or ethnic origin, political orientation, religious or philosophical beliefs, union membership, health, sexual life, and biometric data, such as fingerprints.
“Data Processor”: the natural or legal person, public or private, that processes Personal Data based on the instructions given by the Data Controller. El Dorado may hire persons 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”: the person, entity, or organization that receives or knows Personal Data of Data Subjects by a commercial or any other relationship and that supplies this data to an Information Operator, who in turn delivers it to the Data Subject.
“Operator”: the person, entity, or organization that receives Personal Data from the Source on several Owners, manages them, and makes them known to the Owners under 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”: the natural or legal person, public or private, who decides on the processing of personal data, which is the one who determines the purpose. In this case, the Controller of your Personal Data is El Dorado.
"Services": refers to the Platform's services, which include exchanging crypto assets under a peer-to-peer (P2P) model. This model allows registered users to buy and sell crypto assets through the Platform, with practical applications ranging from buying and selling operations between users to sending crypto assets to wallets abroad to convert them into fiat money. Services may also include other related services that are launched on the Platform.
“Holder”: you are the natural person whose Personal Data is being processed.
“Processing”: any operation we perform on your Personal Data such as collection, storage, processing, analysis, use, circulation, transfer, transmission, updating, correction, or deletion of Personal Data, among others. The Processing may be national (within Colombia) or international (outside Colombia).
“Transmission”: is the delivery of Personal Data to a Data Processor to carry out Processing of the Personal Data, according to the instructions given by the Data Controller within or outside the territory of the Republic of Colombia.
“Transfer”: is the delivery of Personal Data so that another Data Controller processes the Personal Data autonomously, within or outside the territory of the Republic of Colombia.
Scope. This Policy applies to all Personal Data held by El Dorado, the Data Controller.
Principles of Personal Data Processing. We will process Personal Data according to the principles contained in the Personal Data Protection and Habeas Data Law of El Salvador and the regulations that update or modify them, and in particular, according to the following principles:
Purpose: The Processing must have a legal purpose, as required by the Constitution and the law, which we must inform you about.
Necessity and reasonableness: El Dorado must hold personal data necessary to fulfill the purposes of the Processing.
Temporality: The period during which we process Personal Data must be the time necessary to achieve the purpose for which we have collected it.
Freedom: We can only process your personal data with prior, express, and informed consent. The personal data we collect cannot be obtained or disclosed without your prior consent or 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 you the right to obtain information about the existence of your Personal Data in El Dorado's databases at any time and without restrictions.
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 technical, human, and administrative measures necessary to ensure the security of Personal Data and prevent its unauthorized or fraudulent modification, loss, consultation, use, or access.
Confidentiality: All persons involved in processing Personal Data that is not public must guarantee the confidentiality of the information.
Non-discrimination: We will not discriminate based on the Personal Data collected.
Compensation: We must compensate for any damages caused by possible failures in the Processing of Personal Data.
Limitation on collection: We will only collect the Personal Data necessary to fulfill the purposes of the Processing.
When do we collect your Personal Data, and what do we collect?
Data Collection. El Dorado collects Personal Data from Data Subjects in the following cases:
When Data Subjects visit our Platform and are interested in the Services.
When the Owners contract the Services of the Platform.
When Data Subjects provide Personal Data voluntarily, for example, by completing El Dorado physical or digital forms.
When Data Subjects provide their Personal Data so that El Dorado can perform a check in public databases through identity validation tools.
When the Owners are interested in joining the El Dorado team, send their resume, or undergo a selection process.
When a person has provided us with the Personal Data of a Data Subject.
When you enter into a contract of any kind with El Dorado, for example, an employment contract, a service provision contract, a business alliance contract, a partnership contract, a mandate contract, or any other type of contract.
Information collected: El Dorado may ask you for or collect, except for exceptions related to sensitive data or data of children and adolescents, the data necessary to fulfill the purpose, which is—among others—the following:
Data that we collect from all Owners: name and surname, 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, recent photographs, sex, financial information, Personal Data that El Dorado receives from third parties, including economic, 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 Owners,” we will also collect professional credentials, employment, clinical or health history, academic and property history, references, judicial or disciplinary information, occupational medical history, workplace, position or profession of the Holder and his/her spouse or permanent partner and relatives, resume, health affiliation certificate, pension and severance fund information, 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 Owners,” we will also collect data from the legal representative, references, business history, shareholding composition, data from its 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 customers: in addition to the data mentioned in “Data we collect from all Owners,” we will also collect commercial information, judicial and criminal records, bank account information, browsing history on the Platform, history of open cases with customer service, information stored in credit bureaus, risk centers, and other public lists, and any other data that may be necessary to achieve the purposes described in the Policy. We clarify that we use identity validation tools, allowing us to consult your information in public databases such as the attorney general's office, registry, comptroller's office, single transit registry, social security system information, national police, and international restrictive lists.
Sensitive data and its treatment. Taking into account the characteristics of our service, El Dorado requires the processing of some Sensitive Data such as the photo of your identity document that contains your fingerprint and your photos, and in some cases, it requires the analysis of 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 obliged to provide Sensitive Data or authorize its Processing. If you cannot authorize the processing of your Sensitive Data, El Dorado will not be able to continue with the identity validation process and, therefore, it will be impossible for us to continue with the Services. If you authorize us 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 Personal Data related to minors that are public. Such processing will be solely to plan and carry out activities related to employees' and their minor children's personal and family well-being. Only adults or minors duly represented by their guardians may access El Dorado's Services.
Image Data. By participating in any videoconference or event sponsored by El Dorado, you agree and authorize that your names and images appear in programs, publications, and other advertising media and, in general, in any promotional or commercial disclosure material that El Dorado wishes to make during a term of 50 years, without this implying the obligation to remunerate or compensate your participation. By accepting this Policy, you waive any claim against El Dorado for image rights.
Why do we collect your Personal Data?
Generalities of the Purpose. El Dorado will process the Personal Data according to the conditions established by the Owner for the development of its economic activity. In general, El Dorado will collect, store, organize, circulate, use, transmit, and transfer the Personal Data for the purposes set forth below:
Purposes common to all Owners: Comply with the corporate purpose of El Dorado; preserve and manage information on the employment, civil, or commercial relationship of the Holders; comply with the legal, accounting, commercial, and regulatory duties that apply to El Dorado; access, collect, and process personal data that El Dorado receives from third parties, including financial, commercial, and credit information centers; control and preserve the security of El Dorado's people, property, and information; fulfill the purpose of the employment, commercial, or civil relationship that El Dorado has with the Owners; host the Owner'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; prevent and verify the commission of crimes or criminal conduct by the Owners, for which different databases, national and international restrictive lists, and sources such as Interpol, FBI, OFAC databases, among others, as well as the corresponding social networks may be consulted; comply with the regulations for the prevention of money laundering and terrorist financing; maintain direct communication with the Owners for issues related to their employment, civil, or commercial situation and for contractual, informational, and commercial purposes; perform statistical, commercial, financial, social, administrative, or technical analysis; share the information with government authorities or regulatory entities as required by applicable law or pursuant to an administrative, court, or similar order; check and verify the identity and criminal, judicial, disciplinary, financial, and credit records of the Holders; transmit, transfer, and provide the information and Personal Data of the Holders to the parent company or other companies of the El Dorado business group, so that they store, consult, or act as Data Processors or Controllers as the case may be; contact the Holder through the internet or by 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; transmit, transfer, and provide the information and Personal Data of the Holders to business partners or other national and/or international companies or persons that El Dorado commissions to process the information and fulfill the purposes described in this Policy and the object of the commercial or civil relationship with the Owners, or for said third parties to assume the position of Controllers; carry out marketing activities, such as market research, and perform service promotion acts, among other similar concepts; transmit, transfer, and provide the information and Personal Data of the Owners to national or international third parties, in cases where El Dorado has the interest of marketing the Personal Data as a commercial asset; respond to Queries, requests, applications, actions, and Claims made by the Owner; 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 El Dorado candidates, employees, shareholders, and investors: Protect the health of El Dorado employees and contractors; verify conflicts of interest, as well as inabilities or incompatibilities; select personnel, administer hiring, manage labor and social relations, and grant benefits to its employees by itself or through third parties, as well as allow employees access to El Dorado's IT resources; keep a record of disciplinary sanctions imposed on El Dorado contractors and employees; transmit, transfer, and provide the information and Personal Data of the Owners to third parties in charge or responsible for the Processing, in cases where there is an employer substitution or where El Dorado transfers its contractual position, or when it is part of a business acquisition or integration process; make contributions to the general social security system; transmit, transfer, and provide the information and Personal Data of the Holders to third parties to provide employment and/or professional references about the Holders; evaluate and develop selection processes and their history; exercise and develop the rights of the shareholders and the operation of the general meeting of shareholders, among others.
Purposes for which we process the Personal Data of our suppliers and partners: Provide commercial references; manage the payment of remunerations, commissions, discounts, and tax or parafiscal withholdings; send invoices; issue contractual or commercial certificates.
Purposes for which we process our clients' Personal Data: Consult and validate the information of the Holders in public and restrictive lists and determine the risk profile of the Holder; comply with 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 Holders to national and/or international business partners so that they may contact the Holders to offer their products, information, or services that, in El Dorado's opinion, may be of interest to the Holder; improve services and all activities associated with the commercial relationship or link existing or to be established with El Dorado, as well as evaluate the need for new services and products for our clients; contact the Holder by email to send statements, billing statements, and account statements related to the obligations arising from the contract entered into with El Dorado; perform commercial profiling actions, prospecting, consumer habits analysis, analytics, identification of marketing trends, definition of patterns, with or without the use of artificial intelligence tools, among other methods of leveraging data to improve the Services; define customer consumption profiles to perform statistical analysis or improve the marketing and sales processes of El Dorado services; carry out marketing and advertising studies and strategies; perform marketing tasks and send advertising for El Dorado and/or third-party business partners; track customer behavior within the Platform and determine customer intentions; optimize the functionalities of the Platform; carry out risk models and business growth analysis to advance adequate risk management; manage collections or remunerations; validate the information of the Holder in restrictive lists through identity validation tools; inform control entities about transactions carried out with crypto assets; report on the scope and characteristics of El Dorado services, new and existing solutions.
Transmission and Transfer of Personal Data: El Dorado may transfer or transmit Personal Data to one or more Data Processors or Controllers located within or outside the territory of El Salvador when you authorize us to do so or when the law or an administrative or judicial mandate orders us to do so. By accepting this Policy, you permit us to transfer or transmit your Personal Data to our partners, suppliers, 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 treat your Personal Data according to this Policy, but if we transfer your Personal Data, your Personal Data will be treated according to the data protection policy of the new Controller.
What happens with 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 said information.
We will inform you explicitly and in advance what Sensitive Data we are going to 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, for which we will publish the changes to the Policy on our Platform or in any other medium we deem appropriate, and we will notify you of the change. If you do not agree with the new Purposes, you may revoke the Authorization, and we will delete your Personal Data, provided that we do not have any legal obligation to retain it.
Refraining from collecting data relating to criminal records: El Dorado will only process your Personal Data relating to criminal records for the sole and exclusive purpose of guaranteeing the legality of its operations, the security of El Dorado and its stakeholders, and preventing fraud and money laundering and terrorist financing operations.
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 web pages. Cookies allow us, among other things, to store and retrieve information about the browsing habits and trends of a user or their computer. El Dorado uses its own 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 filled out on 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 added value service, as it saves your preferences, the way, time, and manner in which you use our Platform, as well as all the information that may be useful to track 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 make improvements to content and services. We will not collect data on debit or credit card numbers or other financial or credit information. You can reject the use of cookies by configuring your browser appropriately; however, you should know that if you do so, we will not track your information when you visit our Platform, and it may not work properly. If you choose to disable cookies, we will only use a cookie in your browser to remember your preference not to use cookies.
What are you stating when you click on “I authorize the processing of my Personal Data” in accordance with El Dorado’s Personal Data Processing Policy?
Declarations of the Owners of Personal Data: 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 perform any other Processing of your Personal Data, in accordance with the provisions of this Policy.
You have been informed and understand that Sensitive Data is that which affects the privacy of the Holder or whose misuse may lead to discrimination. Likewise, they can be identified as those of racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, data related to health status, sexual life, and biometric data.
You have been informed that, in the event of the 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 have been informed about the purposes for which your Personal Data and Sensitive Data collected will be used, which are described in this Policy.
You have been informed and understand the security measures that El Dorado implements to protect the Personal Data it collects and, therefore, you accept them.
You have been informed about your rights in relation to your Personal Data and the mechanisms to exercise them.
If you are a customer, you have been informed that you will enter into or have a current contract with El Dorado, and for this reason, El Dorado needs to be in permanent 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 that you are providing us.
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 on which El Dorado is dissolved and liquidated or until the purpose for which the Personal Data was collected is completed.
How do we take care of your Personal Data?
Security measures for the protection of Personal Data and other information: The security measures in El Dorado's policy seek to protect the data of the Holders to prevent their adulteration, loss, unauthorized use, and 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 an encrypted manner, among others. Through this Policy, you expressly accept these forms of protection and declare that you consider them convenient and sufficient to protect your Personal Data.
Policy for the elimination and/or deletion of Personal Data: Once the Purpose of the Processing of your Personal Data has been fulfilled, and provided that there is no contractual or legal obligation that prevents it, El Dorado will proceed to the deletion or elimination of your Personal Data, according to the following parameters:
El Dorado will annually evaluate the information it has on the Holders, and according to its characteristics and status, it will proceed to select those data that it considers, at its discretion, should be deleted or eliminated. For these, it will take into account whether there are rights held by the Holders that prevent the deletion of the Personal Data or whether there are legal, contractual, or constitutional obligations that prevent the elimination.
El Dorado will inform the Holders in advance of the decision and the reason for the deletion of their Personal Data, who, through the enabled channels, may exercise their right to file Queries, requests, or Complaints regarding said decision within fifteen (15) business days following notification. The Queries, requests, or Complaints will follow the procedures established in this Policy. In the event that there is no Complaint or request in relation to the decision, the deletion will proceed.
El Dorado will record the corresponding minutes and records regarding the processes of deletion 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 Holders. Therefore, it will take the measures it considers pertinent in terms of confidentiality, such as the following:
It will refrain from disclosing any or all of the confidential information received to any natural or legal person, government or private entity, without prior authorization.
It will refrain from using, exploiting, employing, publishing, or disclosing the confidential information in a manner other than that authorized in the Policy.
It will instruct all those persons who may have access to confidential information on how to handle, utilize, manage security measures, etc., so that said information remains properly managed and protected.
The use of confidential information will be carried out in compliance with the principles of ethics and good practices regarding the protection of Personal Data.
El Dorado will anonymize the Personal Data of the Holders when it considers that it may affect their right to privacy, good name, and honor. In any case, El Dorado, at the request of the Holders and providing the reasons for doing so, will anonymize any Personal Data.
Policies on truthfulness and quality of information: Pursuant to 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. For this reason, it requests from the Data Subjects the information that is necessary and comprehensive for the purposes of the respective Processing. Likewise, it will request the necessary documentation so that the information in its Databases is verifiable and true. For the above purposes, El Dorado will implement the following measures:
It will take all measures to ensure that, when collecting information from the Holders, complete, accurate, up-to-date, verifiable, and understandable information is obtained. In this regard, it will implement due diligence measures in the means of data collection for such purposes.
It will refrain from processing the Personal Data of the Owners with partial, incomplete, fragmented, or confusing information.
It will verify the identity of the Holders and the information provided, requesting the necessary accreditation documents in each particular case, and may request, among others, the following: ID card, tax identification number, judicial and police records, credit history, certifications from private and/or public entities.
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, rectify your information, and/or revoke the Authorization for Processing your Personal Data. Here we detail your rights:
Know, update, and rectify your Personal Data: To do this, we need to first establish the identification of the person who intends to exercise this right to prevent unauthorized third parties from accessing your Personal Data. If you are going to update your Personal Data, we must first verify that you have access to the new Personal Data that you will provide us. Therefore, we will implement a mechanism that allows us to verify this. If we are unable to verify them, you will only be able to update one of your contact details (email, telephone, bank account, among others). This is because we need to maintain a direct communication channel with you to comply with our contractual obligations and you with yours. In any case, for technical reasons and for the development of the products and services offered, there may be limitations regarding the change of any of the personal data such as email or telephone, for which reason we may not comply with the update request, and you will be within your 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, according to current legislation.
Be informed: upon request, regarding the use of your Personal Data.
Revoke the authorization and/or request the deletion of your Personal Data: In this case, we will delete your personal data according to the deletion policy when this is possible. For technical reasons and due to the Owner's history, it may not be possible to delete the transaction history on the Platform, among others, for tax reasons, reporting to government authorities, and accounting reasons.
Access free of charge to your Personal Data: that has been subject to Processing.
Please refrain from answering questions about Sensitive Data or data of children and adolescents: In this case, we will inform you that you are not required to provide authorization for the Processing of Sensitive Data or data of children and adolescents.
The request for deletion of information and revocation of the Authorization will not proceed: when you have a legal or contractual obligation to remain in the El Dorado Database.
El Dorado assures you that direct marketing or market research you receive by email will provide you with an easy means to opt out: For example, in the email, El Dorado will provide you with an "unsubscribe" link or an email to submit an opt-out request. In these cases, your Personal Data will not necessarily be removed from the Databases, but the change in direct marketing preferences will be noted and respected.
Procedure to exercise your rights: If you wish to exercise your rights, you must send an email to support@eldorado.io, which will be answered by the El Dorado data protection area. This email must be addressed to El Dorado SV SA de CV and must specify: (i) name and identification of the Owner or the legitimate person; (ii) precise and complete description of the facts that give rise to the Claim; (iii) claims; (iv) physical or electronic address to send the response; and (v) documents and other relevant evidence that you wish to present.
The procedure we will follow for such communication will be as follows:
When the Holder of the Personal Data wishes to consult the information stored in the Database: El Dorado will respond to the request within a maximum period of ten (10) days.
When the Owner considers that the information contained in the Databases should be corrected, updated, or deleted, or when they believe that El Dorado is failing to comply with its duties, they may file a claim with El Dorado, which will be processed under the following rules:
The claim must be addressed to El Dorado SV SA de CV with the following information: (i) identification of the Holders; (ii) the description of the facts that give rise to the claim; (iii) the address; (iv) the documents to be presented. If the claim is incomplete, El Dorado may request the Holder within five (5) days following receipt of the claim to complete it. After two (2) months from the date of the request, if the Holder does not submit the required information, we will understand that the Holder has withdrawn the claim.
If El Dorado is not competent to resolve the claim, we will forward it to the appropriate party within a maximum period of two (2) business days and inform the Owner of the situation.
Once we receive the complete claim, we will include a legend stating "Claim in process" in the place where the Personal Data is located and the reason for the claim, within a period of no more than two (2) business days. We will maintain the legend until the claim is decided.
El Dorado will respond to the claim within a maximum period of fifteen (15) business days counted from the day following the date on which it was received. When we cannot respond to the claim within this period, we will inform the Owner of the reasons for the delay and the date on which their claim will be responded to, which in no case may exceed eight (8) business days following the expiration of the first period. The withdrawal or deletion of Personal Data will not proceed when there is a contractual obligation to remain in the El Dorado Database.
What obligations does El Dorado have regarding the processing of your personal data?
Duties of El Dorado as Controller of Personal Data: El Dorado is obliged to comply with the duties imposed by law. Therefore, it must act to comply with the following duties:
Guarantee, at all times, the full and effective exercise of your rights mentioned in this Policy.
Treat your Personal Data in accordance with the principles set forth in this Policy.
Keep the information under the necessary security conditions to prevent its adulteration, loss, consultation, unauthorized or fraudulent use or access.
Update the information when necessary.
Rectify your Personal Data when appropriate.
Provide the Data Processor only with Personal Data whose Processing has been previously authorized.
Ensure that the information provided to the Data Processor is true, complete, accurate, up-to-date, verifiable, and understandable.
Communicate in a timely manner to the Data Processor all new developments regarding the Personal Data that you have previously provided and adopt other measures necessary to ensure that the information provided to the Data Processor remains up to date.
Inform the Data Processor in a timely manner of any corrections made to Personal Data so that the Data Processor may proceed to make the relevant adjustments.
Demand that the Data Processor respect the security and privacy conditions of your Personal Data at all times.
Inform the Data Processor when certain information is being disputed by the Owner, once the claim has been submitted and the respective process has not been completed.
Inform the Superintendency of Industry and Commerce when security code violations 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 personal data protection officer.
What other information do you need to know?
Contact: Any questions or additional information will be received and processed through the following email: support@eldorado.io.
Delegate: Catalina Ortega Osorio - catalina@eldorado.io
Changes in the Personal Data Processing and Protection Policy: Any substantial change in the Policy, we will notify you in a timely manner by publishing the new version on our Platform and request your authorization through the same means.
Last Updated: This Policy was last updated on November 20, 2024.