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Block 3 — Privacy Policy · Seto Copilot

Courtesy translation. This English version is provided for convenience only. The Spanish version is the legally binding original; in case of any discrepancy, the Spanish version prevails.

Data controller: Paul Francisco López, doing business under the trade name "Seto Systems" ("Seto Copilot", "the Platform", "we", "us"). RUC (Ecuadorian taxpayer ID): 1723523682001 · Domicile: Quito, Ecuador. Contact / exercise of rights: hola@setosystems.tech · Version: 1.0 · Effective as of: July 10, 2026.

1. Purpose and scope

1.1. This Privacy Policy explains how Seto Copilot collects, uses, shares and protects the personal data of Platform users, in compliance with the LOPDP, its Regulations and other applicable Ecuadorian law.

1.2. By using the Service, you declare that you have read and understood this Policy. It forms an integral part of the Terms and Conditions and the Service Agreement.

2. Roles: controller and processor

2.1. Account data. With respect to registration, billing and Platform-usage data (name, email, tax data, activity), the Provider acts as the data controller.

2.2. User Content. With respect to the data you process through the Service and that resides on your own Odoo instance (which may include personal data of your customers, suppliers or employees), you are the data controller and the Provider acts as the data processor, processing it solely according to your instructions and to provide the Service.

3. Personal data we process

We process the following categories of data:

  • Identification and contact data: full name, email address, job title, company.
  • Access data: password (stored in hashed, encrypted form, never in plain text), session tokens.
  • Billing data: RUC or ID number, company name, address, and the data handled by the payment gateway (we do not store full card numbers).
  • Technical credentials: Odoo URL, database and API key, stored encrypted at rest (Fernet/AES).
  • Technical and usage data: IP address, browser type (user-agent), date and time of access, logs of the operations executed by the AI (which tool, on which module, outcome).
  • Legal acceptance record: version of the accepted documents, fingerprint (hash), IP and user-agent at the time of acceptance.

We do not deliberately collect special categories of data (health, ethnic origin, etc.); you undertake not to introduce such data without a valid lawful basis.

4. Purposes and lawful basis

We process your data for the following purposes, with the indicated lawful basis:

  • Providing and operating the Service (connecting your Odoo with AI assistants) — performance of the contract.
  • Managing your account, authentication and support — performance of the contract.
  • Billing and collection — performance of the contract and legal obligation (SRI regulations).
  • Security, fraud prevention and operation logging — legitimate interest and legal obligation.
  • Complying with requests from competent authorities — legal obligation.
  • Communications about the Service (operational notices, changes) — performance of the contract. Marketing communications will be sent only with your consent, revocable at any time.

5. Processors and sub-processors

5.1. To provide the Service we rely on technology providers acting as processors or sub-processors, bound to equivalent levels of protection:

  • Cloud infrastructure and hosting (servers where the Platform and its database run).
  • Payment gateways: Payphone and PayPal.
  • Artificial-intelligence model providers: Anthropic and OpenAI (they process natural-language instructions to operate on your Odoo).

5.2. We do not sell or transfer your personal data to third parties for commercial purposes.

6. International transfers

Some of our sub-processors (AI providers, hosting and gateways) may be located outside Ecuador. Such transfers are made under the mechanisms provided by the LOPDP (adequate contractual safeguards). By using the Service, you are informed of these transfers.

7. Retention

7.1. We retain Account data while the contractual relationship is in force. After termination, we may delete Account data after 90 days, except where retention is legally required (e.g. accounting/tax backups).

7.2. Legal acceptance records and billing receipts are retained for the periods required by law.

7.3. User Content resides on your own Odoo instance, outside our control; its retention depends on you.

8. Data subject rights

8.1. You may exercise, free of charge, your rights of access, rectification, updating, erasure, objection, portability, and not to be subject to automated decisions with legal effects, as well as to restrict processing and to withdraw consent, in accordance with the LOPDP.

8.2. To exercise them, write to hola@setosystems.tech stating your name, the right you wish to exercise and a copy of your identification. We will respond within the legal deadlines.

8.3. If you believe your rights were not addressed, you may file a complaint with Ecuador's Superintendencia de Protección de Datos Personales.

9. Security measures

We apply reasonable technical and organizational measures: encryption at rest of Odoo keys (Fernet/AES), encrypted transmission (TLS), permission-based access control, password hashing, operation logging, and instant access revocation. No system is 100% infallible; we undertake to manage and notify breaches in accordance with the LOPDP.

10. Cookies and similar technologies

10.1. We use strictly necessary cookies for authentication (session cookie) and security (CSRF protection), and a functional cookie to remember your language, set only when you choose the language. These cookies do not require additional consent as they are essential or activated by you.

10.2. Our public pages may load third-party resources (fonts and style libraries), which entails transmitting your IP to those providers. We do not use advertising or third-party tracking cookies.

11. Minors

The Service is intended for businesses and professionals of legal age. We do not knowingly collect data from minors.

12. Changes to this Policy

We may update this Policy. Changes will be published at https://app.setosystems.tech/legal indicating the effective date. Where the change is substantial, we will notify you by email or within the Platform with reasonable advance notice.

13. Contact

For any questions about this Policy or about the processing of your personal data, write to us at hola@setosystems.tech.

Document version 2026-07-10b.