1. Data controller
SimCodec, located in Quito, Ecuador. Contact: info@simcod.ec.
Data Protection Officer (DPO): privacidad@simcod.ec. Direct inquiries and rights exercises to this address.
2. Legal framework
We process your data under Ecuador's Organic Law on Personal Data Protection (LOPDP) and its regulations.
3. Data we collect
- What you submit: name, email, phone and the message content from the contact form or WhatsApp.
- Browsing data (only with consent): anonymous/pseudonymized analytics (page views, device, approximate IP-based location).
- Technical preferences: language, theme and your cookie choice (necessary cookies).
4. Purposes and legal basis
- Respond to your requests and provide support — basis: your request / pre-contractual steps.
- Improve the site via analytics — basis: your consent.
- Send commercial information if you authorize it — basis: your consent.
5. Processors and third parties
We use providers that may process data on our behalf:
- Cloudflare (hosting/CDN, USA) — infrastructure and security.
- Google (Analytics/Tag Manager, USA) — web analytics, only if you accept analytics cookies.
- Meta (Pixel, USA) — conversion measurement, only if you accept marketing cookies.
- Ahrefs (analytics, Singapore/USA) — SEO attribution, only if you accept analytics cookies.
- Microsoft Clarity (USA) — session recordings and heatmaps, only if you accept analytics cookies.
- TikTok (Pixel, Singapore/USA) — campaign measurement, only if you accept marketing cookies.
These services may involve international data transfers outside Ecuador. Where transfers go to countries without an adequacy decision, we rely on approved Standard Contractual Clauses (SCC) or other safeguards required by the LOPDP.
6. Retention
- Contact/request data: while the relationship lasts and up to 2 years after the last contact.
- Analytics data (pseudonymized): 26 months (GA4 setting) / 13 months (Clarity).
- Technical preferences (language, theme, consent): 1 year from last update.
After these periods, data is deleted or irreversibly anonymized.
7. Your rights
You have the right to access, rectification, erasure, objection, portability and not to be subject to automated decisions with legal effects. Exercise them by writing to privacidad@simcod.ec or info@simcod.ec. We will respond within the LOPDP timelines (max. 15 business days, extendable).
8. Complaints
You may file a complaint with Ecuador's Superintendence of Personal Data Protection.
9. Security and changes
We apply reasonable technical and organizational measures (encryption in transit/TLS, role-based access, minimization, analytics pseudonymization). We may update this policy; the latest date and version will be shown.