Privacy Policy

Who We Are

Clear Money Path operates the website clear-money-path.com. We provide educational content and resources related to personal financial management for entrepreneurs based in Ecuador. Our registered contact address is Av. Ruminahui y Av. Los Shyris 06-132 y, 180202 Ambato. For any data-related enquiries, you may reach us at info@clear-money-path.com.

This Privacy Policy applies to all visitors and users of clear-money-path.com and any subpages, in both the English (/en/) and Spanish (/es/) versions of the site.

Legal Framework

This policy is drafted in compliance with Ecuador's Ley Orgánica de Protección de Datos Personales (LOPDP), enacted on 26 May 2021 and in full force as of 26 May 2023, as well as its implementing regulations. The LOPDP establishes the rights of data subjects and the obligations of data controllers operating within or directing activities toward Ecuador.

Where applicable, we also observe internationally recognised data protection principles including purpose limitation, data minimisation, storage limitation, and transparency.

What Data We Collect

We collect only the personal data necessary to operate our educational platform and respond to enquiries. The categories of data we may collect include:

• Contact information: Name, email address, and phone number submitted through the contact form.
• Communication content: The subject and message body of any enquiry you send us.
• Technical data: IP address, browser type, device type, pages visited, and time spent on pages, collected automatically through cookies and server logs.
• Cookie preferences: Your consent choices stored as a cookie on your device.

We do not collect sensitive personal data as defined under Article 26 of the LOPDP (such as health data, biometric data, or political opinions) and we do not knowingly collect data from individuals under 15 years of age.

How We Use Your Data

Personal data collected through this website is used for the following purposes, each grounded in a lawful basis under the LOPDP:

• Responding to enquiries (legitimate interest / consent): When you submit the contact form, we use your name, email, phone, and message to respond to your question or request.
• Website operation and security (legitimate interest): Technical data is used to maintain site functionality, diagnose errors, and protect against misuse.
• Analytics (consent): If you consent to analytics cookies, anonymised usage data helps us understand how visitors interact with our content so we can improve it.
• Legal compliance (legal obligation): We may retain certain records where required by applicable Ecuadorian law.

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

Cookies

This website uses cookies. A cookie is a small text file stored on your device by your browser. We use the following categories of cookies:

• Strictly necessary cookies: Required for the website to function. These cannot be disabled.
• Analytics cookies: Help us understand how visitors use the site. Only activated with your consent.
• Marketing cookies: Used for relevant content and advertising. Only activated with your consent.
• Preference cookies: Remember your settings and choices. Only activated with your consent.

You can manage your cookie preferences at any time through the cookie consent panel, which appears when you first visit the site. For full details, see our Cookie Policy.

Data Sharing and Third Parties

We do not sell, rent, or trade your personal data to third parties. We may share data in the following limited circumstances:

• Service providers: We may use trusted third-party services (such as hosting providers or email delivery services) who process data on our behalf under contractual data processing agreements consistent with the LOPDP.
• Legal requirements: We may disclose data to competent authorities when required by Ecuadorian law or a valid legal order.
• Business transfers: In the event of a merger, acquisition, or transfer of assets, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

Any third party receiving personal data is required to handle it in accordance with applicable data protection law.

International Data Transfers

Some of our service providers may be located outside Ecuador. Where personal data is transferred internationally, we take steps to ensure that adequate protections are in place, including reliance on standard contractual clauses or transfers to countries recognised as providing an adequate level of data protection under Ecuadorian standards.

You may request information about the specific safeguards in place for any such transfer by contacting us at info@clear-money-path.com.

Data Retention

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

• Contact form submissions are retained for up to 24 months from the date of receipt, or until the matter is resolved, whichever is earlier.
• Technical and server log data is retained for a maximum of 12 months.
• Cookie consent records are retained for the duration of the consent period (12 months) plus a reasonable period for audit purposes.

After the applicable retention period, data is securely deleted or anonymised.

Your Rights Under the LOPDP

As a data subject under Ecuador's Ley Orgánica de Protección de Datos Personales, you have the following rights:

• Right of access (Art. 68 LOPDP): You may request a copy of the personal data we hold about you.
• Right to rectification (Art. 69 LOPDP): You may ask us to correct inaccurate or incomplete data.
• Right to erasure (Art. 70 LOPDP): You may request deletion of your personal data where there is no legitimate reason for us to continue processing it.
• Right to restriction (Art. 71 LOPDP): You may ask us to restrict processing of your data in certain circumstances.
• Right to data portability (Art. 72 LOPDP): You may request your data in a structured, commonly used, machine-readable format.
• Right to object (Art. 73 LOPDP): You may 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@clear-money-path.com with the subject line "Data Subject Request." We will respond within the timeframe established by the LOPDP (generally 15 business days). You also have the right to lodge a complaint with the Autoridad de Protección de Datos Personales (ADPP) in Ecuador.

Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include encrypted data transmission (HTTPS), access controls, and regular security reviews. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals, in accordance with the LOPDP.

Children's Privacy

Our platform is designed for adults who are starting or operating a business. We do not knowingly collect personal data from individuals under the age of 15. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly. If you believe a minor has submitted data through our site, please contact us at info@clear-money-path.com.

External Links

Our website may contain links to third-party websites or resources. We are not responsible for the privacy practices or content of those external sites. We encourage you to review the privacy policies of any third-party sites you visit.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal 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 any update constitutes acceptance of the revised policy.

Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us:

• Email: info@clear-money-path.com
• Post: Av. Ruminahui y Av. Los Shyris 06-132 y, 180202 Ambato
• Phone: +593995826923

We take all privacy-related communications seriously and will respond within the timeframe required by applicable law.