(Tour Operator, in compliance with the LODPP Ecuador - Organic Law on Personal Data Protection, 2021)
1. OBJECTIVE
To guarantee the legal, secure, and transparent processing of personal data of clients, suppliers, and collaborators, in compliance with the LODPP (2021) and its Regulations, minimizing risks of unauthorized access, loss, or misuse.
2. SCOPE OF APPLICATION
Applies to all personal data collected through:
Web forms, emails, WhatsApp, phone calls, or in-person interactions.
Reservations, payments, surveys, contracts, and partnerships with suppliers.
Internal systems (CRM, databases, payroll).
3. GOVERNING PRINCIPLES
Legality: Data is collected only with prior and informed consent.
Purpose: Exclusive use for contracted tourist purposes (e.g., reservations, billing, support, national park registration, transport bookings).
Minimization: Only strictly necessary data is collected (e.g., marital status is not requested if irrelevant).
Accuracy: Data must be up to date (clients may correct it).
Confidentiality: Restricted access to authorized personnel only.
4. TYPES OF DATA PROCESSED
Category
Examples
Legal Basis
Identification
Names, ID/passport, birth date
Consent (Art. 9 LODPP)
Contact
Phone, email, address
Contract execution (Art. 10.2)
Sensitive
Allergies, disabilities, health*
Explicit consent (Art. 11)
Financial
Card details, transfers
Legal obligation (billing)
*Only collected if essential (e.g., adventure tours).
5. CONSENT
Format:
Digital: Checkbox on web forms.
Written: Evaluation surveys.
Content:
Specific purpose (e.g., sending promotions, generating statistics).
Right to revoke at any time.
6. DATA SUBJECT RIGHTS
Clients may exercise their ARCO rights via written request to
Database encryption (AES-256) and secure communications (SSL).
Strong passwords and multi-factor authentication.
Organizational:
Annual employee training.
Confidentiality agreements with suppliers (e.g., hotels, transporters).
Physical:
Physical files under lock (e.g., emergency forms on tours).
8. INTERNATIONAL TRANSFERS
External providers (e.g., Booking.com, PayPal, WeTravel) must comply with standards equivalent to the LODPP. Clients will be informed if their data is stored outside Ecuador (e.g., on U.S. servers).
9. RETENTION AND DELETION
Retention Periods:
Financial data: 5 years (Art. 85 Tax Code).
Contact data: Until consent is revoked.
Deletion: Secure methods.
10. INCIDENTS AND NOTIFICATIONS
Report to the Superdatur within 72 hours if security breaches affect rights (Art. 30 LODPP).
Notify affected parties if risk is high (e.g., sensitive data leaks).
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Functional
Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes.The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
