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GALAXI S.A. Personal Data Protection Policy
1. Purpose
This Personal Data Protection Policy aims to establish the guidelines for the processing of personal data collected by GALAXI S.A., ensuring respect for the rights of data subjects and the confidentiality, integrity, and availability of information, in accordance with the Organic Law on Personal Data Protection, its General Regulations, and other applicable legislation.
2. Scope
This Personal Data Protection Policy applies to the processing of personal data carried out by GALAXI S.A. in the course of its commercial and operational activities, through its official channels and other means authorized by the company.
This Policy applies to personal data collected through:
- Corporate website.
- Corporate email.
- Physical and electronic forms.
- Requests for quotations.
- Commercial and operational documentation related to the provision of services.
- Telephone communications and electronic means authorized by the company.
- Any other official means through which GALAXI S.A. collects personal data.
Furthermore, this Policy applies to the processing of personal data of customers, prospective customers, suppliers, contractors, employees, job applicants, and other data subjects whose personal data is processed by GALAXI S.A., as well as by third parties acting on behalf of the company, in accordance with applicable legislation.
3. Data Controller
GALAXI S.A. is the data controller responsible for the personal data it collects and processes in the course of its commercial and operational activities, in accordance with the Organic Law on Personal Data Protection and other applicable legislation.
The company is committed to processing personal data lawfully, securely, and confidentially, implementing the necessary measures to protect the rights of data subjects.
4. Personal Data Collected
GALAXI S.A. may collect and process personal data from customers, prospective customers, suppliers, contractors, employees, job applicants, visitors, and other data subjects, according to the nature of their relationship with the company.
The personal data processed may include, among others:
- Identification data:
first and last names, identity document, RUC (Taxpayer Identification Number), nationality, and signature, where applicable. - Contact information:
address, email address, telephone number, and business contact information. - Employment and professional information:
position, company, résumé/CV, and professional experience, where applicable. - Financial and tax information:
information necessary for invoicing, payments, and compliance with legal obligations. - Data related to the provision of logistics services:
information necessary to manage import, export, transportation, and other services provided by GALAXI S.A. - Data obtained through electronic means:
information provided through the website, contact forms, email, WhatsApp Business, and other official channels, as well as technical data resulting from their use. - Video surveillance data:
images captured by security systems installed at GALAXI S.A.’s facilities.
Personal data will be processed solely for the purposes described in this Policy and in accordance with applicable legislation.
5. Purposes of Processing
GALAXI S.A. will process personal data solely for specified, explicit, and legitimate purposes related to the performance of its commercial, operational, and administrative activities, in accordance with the Organic Law on Personal Data Protection.
Personal data may be used for the following purposes:
a) Provision of Logistics Services
To manage the provision of cargo consolidation and other logistics services, including the coordination of import, export, and transportation operations, as well as the management of the documentation required for their execution.
b) Commercial Management and Customer Service
To respond to inquiries, requests for information, quotations, requirements, and complaints, and to provide follow-up regarding contracted services.
c) Administrative and Financial Management
To manage contractual relationships with customers and suppliers, issue tax documents, manage payments and collections, and comply with administrative and accounting obligations.
d) Compliance with Legal Obligations
To comply with obligations established under applicable legislation and respond to requests from competent authorities.
e) Human Resources Management
To manage recruitment, hiring, training, and other activities related to employee management.
f) Security
To protect the safety of individuals, property, and facilities through access controls and video surveillance systems, as well as to protect the information managed by GALAXI S.A.
g) Communications
To maintain communication with customers, suppliers, employees, and other data subjects through the company’s official channels, as well as to send information related to contracted services or commercial information when a lawful basis for doing so exists.
Personal data will not be processed for purposes other than those described in this Policy unless there is a lawful basis provided for under the Organic Law on Personal Data Protection.
6. Lawful Basis for Processing
GALAXI S.A. will process personal data only when there is a lawful basis provided for under the Organic Law on Personal Data Protection and other applicable legislation, such as the consent of the data subject, the performance of pre-contractual measures or contractual obligations, compliance with legal obligations, or legitimate interests, as applicable.
In all cases, processing will be carried out in accordance with the principles and rights established under applicable legislation.
7. Retention of Personal Data
GALAXI S.A. will retain personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal, contractual, or regulatory obligations.
Once the purpose of the processing has been fulfilled and the retention periods established by applicable legislation have expired, personal data will be deleted, anonymized, or blocked, as appropriate and in accordance with the company’s internal procedures.
8. Disclosure and Transfer of Personal Data
GALAXI S.A. may disclose or transfer personal data to third parties when necessary for the provision of its services, compliance with legal or contractual obligations, or when another lawful basis exists under the Organic Law on Personal Data Protection.
When required by the nature of the operation, personal data may be disclosed or transferred, among others, to:
- Competent authorities, in compliance with legal obligations or duly substantiated requests.
- Suppliers and strategic partners supporting the provision of GALAXI S.A.’s services.
- International agents, carriers, shipping lines, airlines, and other parties involved in the logistics chain.
- Technology service providers supporting the company’s operations.
GALAXI S.A. may also use technology platforms provided by third parties for the storage, management, or processing of information, ensuring that such providers implement appropriate measures for the protection of personal data.
GALAXI S.A. will adopt reasonable measures to ensure that any disclosure or transfer of personal data is carried out in accordance with applicable legislation and under appropriate security and confidentiality conditions.
9. Rights of Data Subjects
Data subjects may exercise the rights recognized under the Organic Law on Personal Data Protection, including the rights of access, rectification and updating, erasure, objection, portability, suspension of processing, and withdrawal of consent, where applicable.
10. Security Measures
GALAXI S.A. adopts reasonable technical, organizational, and administrative measures to protect personal data against unauthorized access, use, alteration, disclosure, loss, or destruction, in accordance with the Organic Law on Personal Data Protection and other applicable legislation.
Furthermore, GALAXI S.A. promotes the confidentiality of information through staff training, the implementation of internal controls, and the continuous improvement of its security processes.
11. Amendments to this Policy
GALAXI S.A. may update or amend this Personal Data Protection Policy when necessary to adapt it to changes in applicable legislation, its internal processes, the services it provides, or the means used for processing personal data.
12. Contact
Av. 9 de Octubre 1911 y Esmeraldas,Edificio Finansur – 17th Floor, Office 3
Guayaquil – Ecuador info@galaxi-corcomercial.com
www.galaxi-corcomercial.com