Personal Data Protection Policy

1. Objective

LETERAGO DEL ECUADOR S.A. is an Ecuadorian company engaged in the commercialization, promotion, storage, distribution, and/or conditioning of all kinds of pharmaceutical and related products.


Our privacy policy aims to inform about the processing of personal data, purposes, retention, and security of the data collected, recorded, stored, used, or processed through website navigation, the use of a mobile application, or other physical or digital channels, as well as other measures to protect your personal data.

2. Types and Categories of Personal Data

LETERAGO DEL ECUADOR S.A. and its business partners collect personal data through various processes, adhering to the organizational, administrative, technical, and legal measures set forth in the Organic Law on Personal Data Protection. The types of data processed include:

2.1 Identifying Data: Full name, national ID number, identification document number, RUC for natural persons.

2.2 Contact Data: Telephone numbers, email addresses.

2.3 Financial Data: Data necessary for the financial and accounting operations of LETERAGO DEL ECUADOR S.A. with clients, suppliers, and others.

2.4 Tracking Data: Account ID or usernames, browsing ID, IP, location data (processed only in cases of website navigation).

Sensitive and/or health-related data processed by LETERAGO DEL ECUADOR S.A. due to safety and occupational health regulations, quality procedures, security policies, and legal obligations will be treated as special category data in compliance with personal data protection regulations.

3. Purposes of Data Processing

At LETERAGO DEL ECUADOR S.A., personal data is processed for the following purposes:

  • Managing various requests from our clients or interested third parties;
  • Analyzing consumer behavior regarding our pharmaceutical products;
  • Measuring the use of our website, applications, and other physical or digital channels;
  • Improving the quality of our pharmaceutical services and expanding our business activities;
  • Managing personal data of job applicants according to LETERAGO DEL ECUADOR S.A.’s recruitment and selection processes;
  • Responding to requests from the competent authority on personal data protection or judicial orders;
  • Security and video surveillance purposes;
  • Compliance with corporate social responsibility objectives; and
  • Other purposes established in the Organic Law on Personal Data Protection, its General Regulation, or determined by the data protection supervisory authority.

4. Legal Basis for Data Processing

LETERAGO DEL ECUADOR S.A. relies on the following legal bases for personal data processing:

  • Consent: Personal data is authorized for processing through consent provided via physical or digital forms supplied by LETERAGO DEL ECUADOR S.A. or its business subsidiaries.
  • Contractual Obligations between the Data Controller and Processor: Personal data is processed through a contract, either for service provision to LETERAGO DEL ECUADOR S.A. as the data controller or in cases where LETERAGO DEL ECUADOR S.A. acts as a data processor.
  • Vital Interest: LETERAGO DEL ECUADOR S.A., as a responsible company, may process a natural person’s personal data to protect their vital interest, such as life, health, or integrity.
  • Legal Obligation or Competent Authority Order: In cases where LETERAGO DEL ECUADOR S.A. is subject to an express legal obligation or resolutions issued by the data protection supervisory authority.

5. Personal Data Retention

LETERAGO DEL ECUADOR S.A. will retain personal data only for the time necessary to fulfill the purposes outlined in Section II, “Purposes of Data Processing,” of this Privacy Policy.

Personal data processed under a contractual relationship between LETERAGO DEL ECUADOR S.A. and its clients, interested parties, or employees will be retained for the duration of the contractual relationship (civil, commercial, labor, etc.) and, after termination, for a reasonable retention period as specified in each contract.


In cases where the Data Protection Authority mandates a longer retention period for personal data, LETERAGO DEL ECUADOR S.A. will comply with such resolutions.

 

6. Specific Contractual Contact Point

In compliance with the Organic Law on Personal Data Protection and its regulations, LETERAGO DEL ECUADOR S.A. has appointed a Data Protection Officer, who can address inquiries related to this Privacy Policy.


Requests may be directed to the Data Protection Officer by sending an email to: delegadopdp@leterago.com.ec

7. Sharing of Personal Data

LETERAGO DEL ECUADOR S.A. will share personal data with third parties, companies with a business alliance, strategic business partners, and other economic activities of the company, provided that personal data processing complies with the legal guarantees established in data protection regulations.

8. Consequences of Providing Incorrect or Inaccurate Data

LETERAGO DEL ECUADOR S.A. informs that personal data provided under any legal basis must be correct and accurate. If personal data is found to be incorrect, inaccurate, misleading, or false, the company reserves the right to take internal administrative and technical actions, as well as external actions that may be pursued through administrative or judicial channels.

9. Rights of Data Subjects

Data subjects may exercise their rights of access, rectification, updating, objection, deletion, restriction of processing, and all other rights established in the Organic Law on Personal Data Protection and its implementing regulation.


LETERAGO DEL ECUADOR S.A. will provide the corresponding form for exercising these rights, requiring at least the following:

  1. Identification document proving ownership;
  2. PDP Rights Form; and
  3. Any supporting documentation justifying the exercise of the right.

 

Requests may be submitted by sending an email to: delegadopdp@leterago.com.ec

LETERAGO DEL ECUADOR S.A. may request additional clarification, expansion, or verification of the submitted request. If the requested information is not completed within ten (10) days, the request will be archived.


If LETERAGO DEL ECUADOR S.A. does not respond within fifteen (15) days, the data subject may submit the request physically at any LETERAGO DEL ECUADOR S.A. office nationwide, addressing it to the Data Protection Officer.

10. Measures Taken to Protect Personal Data

To ensure the security and confidentiality of personal data, LETERAGO DEL ECUADOR S.A. is committed to treating personal data of clients and interested parties with absolute confidentiality and using it only for the purposes indicated in this Privacy Policy.
LETERAGO DEL ECUADOR S.A. has adopted the necessary security measures in compliance with personal data protection regulations and has implemented technical and organizational security measures to guarantee the protection of personal data, preventing alteration, loss, processing, and/or unauthorized access. These measures take into account technological advancements, the nature of the stored data, and the risks posed by human actions or physical/natural events.

11.Acceptance and Modification of the Privacy Policy

Clients, suppliers, employees, and interested parties in pharmaceutical products and LETERAGO DEL ECUADOR S.A. facilities agree to the processing, purposes, and other provisions stated in this Privacy Policy, declaring that the data provided is true, correct, and accurate.

LETERAGO DEL ECUADOR S.A. reserves the right to modify this Privacy Policy when necessary. If modifications are introduced, we will communicate them through our website or other available company communication channels, allowing you to review the updated Privacy Policy terms.