Personal data protection

ACCROACHCODE LLC, organized in the United States, is the contracting party for Registro Digital services. ACCROACHCODE S.A., holding an Ecuadorian RUC, acts as representative in Ecuador for the purposes of the LOPDP and issues local electronic invoices. Requests concerning the personal data of data subjects in Ecuador are handled by ACCROACHCODE S.A.

We are committed to protection, privacy and transparency in the processing of personal data, applying technical, organizational and administrative security measures that ensure its confidentiality, integrity and availability.

Registro Digital acts in a dual role depending on the context:

• As controller: for its customers' data, including account, billing, domain holder contact and access data.
• As processor: for the data that customers host on their services, such as the content of their websites, their databases and their mailboxes. That data is processed solely to provide the service and on the customer's instructions, in accordance with the LOPDP.

The controller's identification and contact details are as follows:

Contracting party

ACCROACHCODE LLC · 111 NE 1st St, 8th Floor Suite #88844, Miami, Florida 33132, United States

Representative in Ecuador and electronic invoicing

ACCROACHCODE S.A. · RUC (Ecuadorian tax ID) 0992879955001

Address in Ecuador

Víctor Emilio Estrada 706B y Ficus, Guayaquil, Ecuador

Phone

+593 4 460 5253

Website

www.registrodigital.com.ec

Support and billing

soporte@registrodigital.com.ec

Personal data and data protection officer

privacidad@registrodigital.com.ec

ACCROACHCODE S.A. has appointed a Personal Data Protection Officer under article 48 of the LOPDP, responsible for overseeing compliance with this policy and handling data subjects' enquiries.

Contact email: privacidad@registrodigital.com.ec

Through this channel data subjects may exercise their rights of access, rectification and updating, erasure, objection, portability and suspension of processing.

• Registro Digital does not own the data that its customers host on the services, nor the data of their website visitors or email recipients.
• As processor, Registro Digital may handle private and potentially sensitive data contained in its customers' websites, databases and email, without accessing it except where necessary to provide support, for security reasons or by order of a competent authority.
• The customer must ensure the lawfulness of the processing it carries out with its services and, where applicable, obtain its own users' consent under the LOPDP.

As controller, with our customers' data

• Managing the contractual and commercial relationship: accounts, invoicing and collections.
• Registering, renewing and transferring domains and issuing SSL certificates with third parties.
• Providing the contracted hosting and email services.
• Providing technical support and customer service.
• Ensuring platform security and preventing fraud.
• Notifying expirations, renewals, maintenance and changes to the service.
• Complying with applicable legal obligations in Ecuador.

As processor, with the data hosted by our customers

• Storing and serving their websites, applications and databases.
• Receiving, storing and sending their email.
• Performing backups and technical operations needed for the service.

Under no circumstances will Registro Digital use the data hosted by its customers for its own or advertising purposes, or share it with third parties unrelated to the provision of the service.

• Customer data: kept for the duration of the contractual relationship and, afterwards, blocked for the mandatory legal periods before final deletion.
• Data hosted by customers: kept while the service is active. Services suspended for more than 30 days may be cancelled and their data securely deleted, in accordance with the Terms and conditions.

• From customers: the processing needed to provide the services is based on performance of the contract accepted on sign-up; consent is requested for the purposes that require it, such as analytics and marketing cookies or marketing communications.
• From the customer's users: it is the customer's sole responsibility to have a lawful basis, including consent where applicable, to process the data of its website visitors and contacts, under article 7 of the LOPDP.

Data subjects may withdraw at any time the consent given over their own data by writing to privacidad@registrodigital.com.ec, without affecting the lawfulness of prior processing.

Under the LOPDP, data subjects have the right of access, rectification and updating, erasure, objection, portability, suspension of processing, and not to be subject to decisions based solely on automated assessments.

• If you are a Registro Digital customer: you may exercise your rights over your account data by writing to privacidad@registrodigital.com.ec and proving your identity. We will respond within the time limits set by the LOPDP.
• If your data is on a website or in the email of one of our customers: you must exercise your rights directly with that customer, who is the controller. Registro Digital, as processor, will assist it in handling them.

If you believe your rights have not been honored, you may file a complaint with the Superintendency of Personal Data Protection.

Providing the services involves entities and infrastructure that may be located outside Ecuador:

• Domain registries and registrars in other countries, and ICANN itself, for generic domains.
• Certificate authorities that issue SSL certificates.
• Payment processors and cloud infrastructure providers.
• Technical and support processes managed by ACCROACHCODE LLC, the contracting party for the service, in the United States.

These transfers are necessary to perform the contract. ACCROACHCODE S.A. seeks to ensure that they are made to entities offering appropriate safeguards and a level of protection equivalent to or higher than that required in Ecuador, in accordance with articles 55 et seq. of the LOPDP.

In compliance with the LOPDP, the following measures, among others, are applied:

• Encryption of communications over HTTPS/TLS.
• Password storage using hashing algorithms.
• Role-based access controls and the principle of least privilege.
• Logging of access and critical operations.
• An incident management procedure, including notification of breaches to the authority and to data subjects within the legal time limits.
• Periodic review of infrastructure security.

ACCROACHCODE LLC, ACCROACHCODE S.A. and their staff undertake to keep confidential all personal data processed, especially the content that customers host on the services, which we handle as processor.

We do not sell, share or assign personal data to third parties, except where strictly necessary to provide the service or when required by a competent authority.