Privacy Policy

Last updated: July 3, 2026

1. Who We Are

COMPANIA ECUATORIANA DEL TE CA CETCA (“CETCA,” “we,” “us,” or “our”), RUC 1790017397001, is located at Av. Interoceánica S/N y S12G, Puembo, Quito, Pichincha, Ecuador. This Privacy Policy describes how we collect, use, and protect personal data, in compliance with Ecuador’s Organic Law on Personal Data Protection (LOPDP) and, where applicable to visitors and customers located in the United States, with the general principles reflected in comprehensive U.S. state privacy laws such as the California Consumer Privacy Act (CCPA/CPRA).

Contact for data protection matters: cetca@tedelecuador.com

(If the volume or nature of data processing requires it under Article 44 of the LOPDP, CETCA will appoint and register a Data Protection Officer (DPD) with Ecuador’s Superintendencia de Protección de Datos Personales (SPDP). This section will be updated with that appointment if applicable.)

2. Scope

This Policy applies exclusively to personal data we collect through our WhatsApp sales and customer service chatbot (CETCA). It does not cover any other channel, website, or service.

3. Personal Data We Collect

Through our WhatsApp channel, we may collect:

• Identification and contact data: name, phone/WhatsApp number, email address
• Order data: products requested, quantities, delivery address, purchase history
• Conversation content: messages exchanged with the chatbot and, if escalated, with our customer service team
• Technical data: conversation metadata (date, time, order status)

We do not intentionally request or collect sensitive personal data (ethnicity, health, sexual orientation, political affiliation, biometric data, or similar categories) through this channel. If a user voluntarily provides such data, it will not be used for any purpose other than order handling and may be deleted upon request.

4. How We Use Your Data

We process your personal data to:

1. Manage and confirm orders placed via WhatsApp
2. Respond to inquiries and provide customer support
3. Improve the quality of our automated customer service
4. Comply with contractual, tax, and accounting obligations arising from the commercial relationship
5. Send order-status communications (non-marketing, unless you provide separate express consent)

5. Legal Basis for Processing

We process your data based on:

• Your consent, given when you initiate a conversation with our WhatsApp chatbot
• Performance of a contract, when processing is necessary to fulfill your order
• Compliance with legal obligations applicable to CETCA (tax, commercial regulations)

6. Use of Third-Party AI Tools

Our WhatsApp chatbot uses third-party artificial intelligence models to generate automated responses. Specifically, conversation content is processed through:

• Anthropic PBC (Claude API) — for understanding and generating conversational responses
• OpenAI (GPT-4.1 Nano model) — for specific cost-optimization and query-processing functions

These providers act as data processors and handle data solely on our instructions, for the purpose of generating responses to users. We also use Meta Platforms, Inc.’s WhatsApp Business API as our messaging channel, which is additionally subject to Meta’s own privacy practices.

7. International Data Transfers

The providers listed in Section 6 (Anthropic, OpenAI, Meta) process data on servers located outside Ecuador, primarily in the United States. We take reasonable steps to ensure these transfers are subject to appropriate safeguards — including reliance on each provider’s contractual terms, security certifications, and privacy commitments — and we limit transfers to the data strictly necessary for the stated purpose.

8. Data Storage and Retention

Order and conversation data is stored in our internal databases (SQLite/PostgreSQL). We retain personal data only as long as necessary to:

• Fulfill the purpose for which it was collected
• Comply with legal, tax, or accounting obligations (generally up to 7 years under Ecuadorian tax regulations)

After this period, data is securely deleted or anonymized.

9. Security Measures

We implement reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, or alteration, including access controls on our databases and monitoring of our digital infrastructure.

10. Your Privacy Rights

If you are located in Ecuador, under the LOPDP you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Delete/cancel your data when no longer necessary
• Object to processing under certain circumstances
• Portability of your data in a structured format
• Restrict processing temporarily
• Withdraw consent at any time

You may lodge a complaint with Ecuador’s Superintendencia de Protección de Datos Personales (SPDP) if you believe your rights have not been adequately addressed.

If you are a resident of a U.S. state with a comprehensive privacy law (such as California, Colorado, Connecticut, Virginia, or similar), you generally have the right to:

• Know what personal information we collect and how it is used
• Request access to or a copy of your personal information
• Request deletion of your personal information
• Correct inaccurate personal information
• Opt out of the sale or “sharing” of personal information for cross-context behavioral advertising — note: CETCA does not sell or share personal data with third parties for advertising purposes
• Non-discrimination for exercising any of these rights

To exercise any of these rights, contact us at cetca@tedelecuador.com. We will respond within the timeframes required by applicable law.

11. Children’s Privacy

Our services are directed at individuals 18 years of age or older. We do not knowingly collect data from minors through our sales chatbot.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this document reflects the current version. Material changes will be communicated through our official channels.

13. Contact Us

COMPANIA ECUATORIANA DEL TE CA CETCA RUC: 1790017397001 Av. Interoceánica S/N y S12G, Puembo, Quito, Pichincha, Ecuador Email: cetca@tedelecuador.com