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Privacy Policy

How Active Cash Flow collects, processes, and protects personal data.

1. Identity and Contact Details of the Data Controller

The data controller responsible for processing your personal data is:

Business Name: Active Cash Flow
Website: active-cash-flow.com
Address: Edificio Altamira, Rio Papallacta, y y Rio Misahualli, oficina 301, 180207 Ambato
Email: info@active-cash-flow.com
Phone: +593983523087

For any questions, requests, or concerns regarding the processing of your personal data, you may contact us directly at the email address listed above. We will respond to data-related requests within the timeframes established by Ecuadorian law.

2. What Personal Data We Collect

We collect personal data only when you voluntarily provide it through our contact form or when it is automatically generated by your use of the website. The categories of data we may collect include:

Data provided directly by you:

  • Full name
  • Email address
  • Phone number
  • The subject and content of your message or inquiry

Data collected automatically:

  • IP address and approximate geographic location
  • Browser type and version
  • Operating system
  • Pages visited and time spent on each page
  • Referring website or source
  • Date and time of visit

We do not collect sensitive personal data as defined under Article 26 of the LOPDP, including health data, political opinions, religious beliefs, biometric data, or financial account details.

3. Legal Basis for Processing

Under the LOPDP of Ecuador, we process your personal data on the following legal bases:

  • Consent (Art. 7 LOPDP): When you submit the contact form, you provide explicit consent by checking the privacy checkbox. You may withdraw consent at any time by contacting us.
  • Legitimate interest (Art. 7 LOPDP): For analytics data collected automatically, we rely on our legitimate interest in understanding how the website is used in order to improve its content and functionality. This interest does not override your fundamental rights and freedoms.
  • Compliance with legal obligations: In cases where we are required by Ecuadorian law to retain or disclose data.

We do not process personal data for purposes incompatible with those stated at the time of collection.

4. Purposes of Data Processing

We use the personal data collected for the following specific purposes:

  • To respond to inquiries submitted through our contact form
  • To provide information about our educational guides, tools, and group sessions
  • To improve the content, structure, and usability of the website based on aggregate usage data
  • To comply with legal obligations applicable to data controllers in Ecuador
  • To maintain records of communications for administrative purposes

We do not use your personal data for automated decision-making or profiling as defined under the LOPDP. We do not sell, rent, or trade personal data to third parties for their own marketing purposes.

5. Data Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law.

  • Contact form submissions: Retained for up to 24 months from the date of submission, after which they are securely deleted unless an ongoing communication relationship requires longer retention.
  • Analytics data: Retained in aggregated, anonymized form. Individual session data is not retained beyond the analytics platform's standard retention period.
  • Cookie data: Retained for the duration specified in our Cookie Policy, which varies by cookie category.

When data is no longer needed, it is securely deleted or anonymized in accordance with applicable data protection standards.

6. Data Sharing and Third Parties

We do not share your personal data with third parties except in the following limited circumstances:

  • Service providers: We may share data with trusted third-party service providers who assist in operating our website (such as hosting providers and analytics platforms). These providers are contractually bound to process data only on our instructions and in accordance with applicable law.
  • Legal requirements: We may disclose personal data if required to do so by a court order, regulatory authority, or other legal obligation under Ecuadorian law.
  • Business transfers: In the event of a merger, acquisition, or transfer of business assets, personal data may be transferred as part of that transaction, subject to equivalent data protection obligations.

Any international transfer of personal data outside Ecuador will be carried out only to countries or organizations that provide an adequate level of protection, or with appropriate safeguards in place, as required by Article 54 of the LOPDP.

7. Your Rights Under the LOPDP

As a data subject under the Ley Orgánica de Protección de Datos Personales of Ecuador, you have the following rights with respect to your personal data:

  • Right of access (Art. 19 LOPDP): To obtain confirmation of whether we process your data and to receive a copy of that data.
  • Right to rectification (Art. 20 LOPDP): To request correction of inaccurate or incomplete data.
  • Right to erasure (Art. 21 LOPDP): To request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw consent.
  • Right to restriction of processing (Art. 22 LOPDP): To request that we limit how we use your data in certain circumstances.
  • Right to data portability (Art. 23 LOPDP): To receive your data in a structured, commonly used, machine-readable format.
  • Right to object (Art. 24 LOPDP): To object to processing based on legitimate interest.
  • Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@active-cash-flow.com. We will respond within the timeframes established by the LOPDP. You also have the right to lodge a complaint with the Superintendencia de Protección de Datos Personales, the supervisory authority in Ecuador.

8. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

  • Secure HTTPS encryption for all data transmitted through the website
  • Access controls limiting who within our organization can access personal data
  • Regular review of our data processing practices and security procedures
  • Secure deletion protocols for data that is no longer required

While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining appropriate safeguards consistent with the LOPDP.

9. Cookies and Tracking Technologies

This website uses cookies and similar tracking technologies. Cookies are small text files stored on your device that help us understand how the site is used and improve the user experience. Our use of cookies is governed by our separate Cookie Policy, which provides detailed information about the types of cookies used, their purposes, and how to manage your preferences.

When you first visit the website, you will be presented with a cookie consent notice that allows you to accept all cookies, reject non-essential cookies, or customize your preferences by category. Your choices are stored in a cookie on your device and can be changed at any time.

10. Children's Privacy

This website is not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe that a minor has provided personal data through this website without appropriate parental or guardian consent, please contact us at info@active-cash-flow.com and we will take steps to delete such data promptly.

In accordance with the LOPDP and Ecuador's constitutional protections for minors, we apply heightened care to any data that may relate to individuals under 18.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or operational requirements. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

Continued use of the website after changes are posted constitutes your acknowledgment of the updated policy. If changes are significant, we will take reasonable steps to notify users through a notice on the website.