Legal
Privacy and Personal Data Processing Policy
Version 2.2 · effective August 12, 2026
This English version is provided for convenience. If it differs from the Spanish version, the Spanish version prevails. At Daleki Trade we respect your privacy and process your personal data in accordance with the Ley Orgánica de Protección de Datos Personales del Ecuador (LOPDP, Ecuador's Personal Data Protection Law), its General Regulation (Reglamento General) and the international regulations applicable to foreign trade operations. This Policy describes what data we process, for what purpose, on which legal bases we rely, with whom we share it and how you may exercise your rights.
1. Data controller
This Policy governs the processing of personal data carried out by Daleki Trade, a brand operated by D-Legacy SAS, a company incorporated in the Republic of Ecuador and domiciled in Quito (Metropolitan District), and by D-Legacy USA LLC, a company incorporated in the State of Florida (United States of America), as applicable to the operation giving rise to the processing. For the purposes of the Ley Orgánica de Protección de Datos Personales del Ecuador (LOPDP), published in Registro Oficial Suplemento No. 459 (Official Registry Supplement No. 459) of May 26, 2021, and of its General Regulation issued by Decreto Ejecutivo No. 904 (Executive Decree No. 904), D-Legacy SAS acts as Data Controller (Responsable del Tratamiento) with respect to the data collected through dalekitrade.com, the ATLAS digital consultant and the commercial channels of Daleki Trade. Operations contracted with D-Legacy USA LLC are additionally governed by the applicable federal and Florida state rules.
2. Contact details and channel for exercising rights
For any inquiry, request or exercise of rights related to personal data, you may write to privacidad@dalekitrade.com or trade@dalekitrade.com with the subject "LOPDP". You may also contact us by WhatsApp at +593 99 785 4652 or by mail at the registered business address in Quito. The company will designate and publish in due course the information of its Data Protection Officer (Delegado de Protección de Datos) when the circumstances provided for in article 47 of the LOPDP arise; in the meantime, all requests are handled by the company's legal department.
3. Personal data we process
We process the following categories of data when you contact Daleki Trade, complete forms, subscribe to the newsletter, converse with ATLAS or contract our services. Identification and contact data: first and last names, national identity card (cédula) or passport number, RUC (Ecuadorian taxpayer registration number), company name, position, email address, telephone number, city and delivery address. Newsletter data: the email address you voluntarily provide when subscribing. Operational and commercial data: description of goods, supplier links, proposed tariff headings, volumes, FOB values, logistics operation data and banking data strictly necessary to issue collections and invoicing. Compliance data (KYC): information required to prevent money laundering under the regulations of the Unidad de Análisis Financiero y Económico (UAFE, Financial and Economic Analysis Unit) and tax obligations before the Servicio de Rentas Internas (SRI, Internal Revenue Service). Technical and browsing data: IP address, browser type, operating system, device identifiers, pages visited and referrer. We do not request or process special categories of data within the meaning of article 25 of the LOPDP (sensitive, biometric, health, ethnic origin, union or political affiliation data, among others). If you voluntarily provide sensitive data through ATLAS or a form, we will ask you to withdraw it or, failing that, we will delete it.
4. Purposes of processing
Your data is processed for specified, explicit and legitimate purposes, including: managing commercial inquiries and issuing formal import or export quotes; performing the contracted service agreement, including coordination with suppliers at origin, freight forwarders, shipping lines and airlines, customs brokers authorized before SENAE and local carriers; issuing electronic receipts, invoices and other tax documentation required by the SRI; complying with customs obligations before the Servicio Nacional de Aduana del Ecuador (SENAE, National Customs Service of Ecuador), the Comité de Comercio Exterior (COMEX, Foreign Trade Committee), ARCSA, ARCOTEL, INEN, AGROCALIDAD and other regulatory entities depending on the goods; complying with obligations to prevent money laundering and the financing of other crimes required of reporting entities by the UAFE regulations; providing support and after-sales service; sending the foreign trade newsletter when you voluntarily subscribe (tariffs, landed cost and routes), based on your prior, free, specific, informed and unequivocal consent, which you may withdraw at any time at https://www.dalekitrade.com/en/newsletter/unsubscribe or by writing to privacidad@dalekitrade.com; sending other commercial communications about our services when there is a lawful basis to do so; and improving the quality and security of the platform and of the ATLAS digital consultant.
5. Lawful basis
Each processing activity is based on one or more of the lawful bases provided for in article 7 of the LOPDP. The performance of pre-contractual measures and the performance of the contract support the processing of the data necessary to quote, contract and carry out the import or export. Compliance with legal obligations supports the retention of tax, accounting and customs information, as well as the obligations to prevent money laundering. Legitimate interest supports the processing of technical data for platform security, fraud prevention and service improvement. Consent, prior, free, specific, informed and unequivocal, supports the sending of unsolicited commercial communications and the use of non-essential analytics and measurement cookies, and may be withdrawn at any time without affecting the lawfulness of prior processing.
6. ATLAS, digital consultant with artificial intelligence
ATLAS is a digital consultant powered by generative artificial intelligence models that answers foreign trade inquiries and provides reference calculations of total import cost. The information you enter into ATLAS (text, descriptions, links, images you attach) is processed to generate the response and may be reviewed by our team in aggregate form to improve the quality of the service. Daleki Trade does not use your inquiries to train third-party artificial intelligence models. ATLAS does not make legal decisions or produce legal effects on its own within the meaning of article 16 of the LOPDP: formal quotes and the opening of an operation always involve human intervention by the Daleki Trade team. ATLAS keeps, associated with a random identifier of your browser and without the need for registration, a brief memory of the commercial context that you yourself provide (company, product, origin or destination market, volume, approximate budget, timeframe, language and the pending inquiry) for the sole purpose of continuing the conversation without asking you for the same data again. That memory is automatically deleted after sixty (60) days of inactivity, is not used for advertising and does not include credentials, passwords, card data or identity documents: the system discards that information before storing it. You may request its immediate deletion by writing to the privacy email address indicated in this Policy. We recommend that you do not enter personal data of third parties, sensitive data or confidential information of your company that is not strictly necessary for the inquiry.
7. Recipients and data processors
To perform the service we share the strictly necessary data with: suppliers and manufacturers at origin (China, the United States, Panama, Mexico, Peru, European Union countries and others) selected or validated according to your instructions; freight forwarders, shipping lines, airlines and courier operators; customs brokers authorized before SENAE, who file the Declaración Aduanera de Importación (DAI, Customs Import Declaration) or Export Declaration on your behalf; banks, payment gateways and financial processors that execute the collections under the 50/50 model; technology providers acting as data processors, including our hosting provider (Vercel Inc.), our database provider (Supabase Inc.), our artificial intelligence providers for ATLAS (OpenRouter, Inc. as request router and Anthropic, PBC as model provider) and the email and analytics services we use; and competent authorities (SENAE, SRI, UAFE, the Función Judicial or Judiciary) when there is a binding legal requirement. With each processor we maintain a data processing agreement that imposes obligations of confidentiality, security and use limited to the authorized purposes, in accordance with article 49 of the LOPDP. We do not sell, rent or assign your data to third parties for their own commercial purposes.
8. International transfers
Due to the nature of foreign trade and of the technology infrastructure used, your data may be transferred to countries other than Ecuador, including the United States, China, Panama, European Union countries and others from or to which the goods move. These transfers are carried out under one of the authorizations of Chapter VIII of the LOPDP: the performance of the contract and of pre-contractual measures requested by the data subject, compliance with customs and tax legal obligations, the existence of adequate safeguards (contractual clauses and security policies of the international processors), or the express consent of the data subject when no other basis applies. When we work with international processors, we prefer providers that offer contractual commitments on security and no secondary use of the data.
9. Retention periods
We retain data for the period necessary to fulfill the purposes for which it was collected and, thereafter, for the periods required by law. Tax, accounting and supporting information for customs operations: seven (7) years, in accordance with the Código Tributario (Tax Code), the Reglamento de Comprobantes de Venta (Sales Receipts Regulation) and the Reglamento al Título de Facilitación Aduanera para el Comercio (Regulation to the Title on Customs Facilitation for Trade) of the COPCI (Código Orgánico de la Producción, Comercio e Inversiones, Organic Code of Production, Trade and Investment). Anti-money laundering information: ten (10) years, in accordance with the Ley Orgánica para la Prevención, Detección y Erradicación del Delito de Lavado de Activos y del Financiamiento de Otros Delitos (Organic Law for the Prevention, Detection and Eradication of the Crime of Money Laundering and the Financing of Other Crimes). Data of leads and commercial prospects that did not result in an operation: up to twenty-four (24) months from the last contact, unless the data subject requests deletion earlier. Conversations with ATLAS with no associated operation: up to twelve (12) months, in aggregated and dissociated form for quality analysis. ATLAS session context memory: sixty (60) days from the last use, with automatic deletion. Newsletter data: while the subscription is active and up to twenty-four (24) months after unsubscribing, to evidence the withdrawal of consent. Marketing data: until the data subject withdraws consent. Once the applicable period has elapsed, the data is deleted or irreversibly anonymized.
10. Rights of the data subject
As the data subject you have the rights recognized in Chapter III of the LOPDP: access, rectification, updating, deletion, objection to processing, portability, suspension of processing, as well as the right not to be subject to decisions based solely or partially on automated assessments that produce legal effects against you or significantly affect you. To exercise them, send a communication to privacidad@dalekitrade.com stating your identity, the right you are exercising and the data to which it relates. To withdraw your consent to the newsletter you may use https://www.dalekitrade.com/en/newsletter/unsubscribe without needing to identify yourself beyond the subscribed email address. We will respond to your request within the fifteen (15) day period provided for in the LOPDP, which may be extended when its complexity so justifies. If you believe your request was not adequately addressed, you may file a complaint with the Superintendencia de Protección de Datos Personales del Ecuador (SPDP, Ecuador's Superintendency of Personal Data Protection), the supervisory authority in this matter.
12. Information security
We apply reasonable technical and organizational measures proportionate to the risk to protect your data against unauthorized access, loss, alteration or disclosure, in accordance with Chapter VI of the LOPDP. These measures include encryption in transit (TLS), role-based access control, strengthened authentication for internal staff, audit logs, segregation of environments, confidentiality agreements with staff and providers and periodic security reviews. No platform is absolutely invulnerable, so we maintain a process of continuous improvement and incident response.
13. Security breaches
In the event of a security breach affecting your personal data, we will notify the Superintendencia de Protección de Datos Personales within five (5) days of becoming aware of it, in accordance with article 45 of the LOPDP, and you as the data subject when the breach may create a significant risk to your rights, indicating the nature of the incident, the measures taken and the recommendations to mitigate its effects.
14. Children and adolescents
Daleki Trade offers commercial services aimed at adult businesses and entrepreneurs. We do not offer products or services intended for children or adolescents and we do not knowingly collect data from minors. If we detect that we have received data from a minor without the authorization of their legal representative, we will delete it.
15. Changes to this Policy
We may update this Policy to reflect regulatory, service or internal practice changes. The date of the last update is indicated at the beginning. Version in force: 2.2 of August 12, 2026. When the changes are material, we will notify active clients by email and through a visible notice on the site. Continued use of the service after the update implies knowledge of the new version.