In compliance with the Organic Law on Personal Data Protection (LOPDP), published in Official Registry Supplement No. 459 of May 26, 2021, and in recognition of the fundamental right to data protection and privacy enshrined in the Constitution of the Republic of Ecuador, RESPONSIBILITY-RSG S.A.S. (hereinafter, “RESPONSIBILITY-RSG” or the “Firm”) presents this Privacy Policy, Data Protection Policy, and Cookie Policy (hereinafter, the “Policy”). This document details the procedures for the collection, processing, storage, use, transfer, and deletion of personal data, as well as the use of cookies on our website, ensuring lawful, transparent, and secure data handling.

​

1. Identification of the Data Controller

​

RESPONSIBILITY-RSG S.A.S., is domiciled in the province of Pichincha, city of Quito, at Av. Shyris N32-88 and Av. Eloy Alfaro, Edificio Shyris 186, Office 602. For matters related to this Policy, please contact us at legal@rspfirm.com or by phone at +593 99 621 4993.

​

2. Terms and Definitions

• LOPDP: Organic Law on Personal Data Protection, published in Official Registry Supplement No. 459 of May 26, 2021.

• Data Controller: RESPONSIBILITY-RSG, which determines the purposes and means of processing personal data.

• Data Subject: A natural person whose personal data is processed.

• Personal Data: Information that identifies or makes a natural person identifiable, directly or indirectly.

• Sensitive Data: Data relating to ethnicity, gender identity, religion, ideology, political affiliation, criminal history, migration status, sexual orientation, health, biometric data, genetic data, among others, whose improper processing may lead to discrimination or affect fundamental rights.

• Cookies: Data files stored on the user’s device to improve the browsing experience, personalize content, or analyze website usage.

• Business Partner: An entity or individual with whom RESPONSIBILITY-RSG maintains commercial relationships.

• Service Provider: An individual or entity that provides services to RESPONSIBILITY-RSG related to the processing of personal data.

• Client: A natural or legal person who receives services from RESPONSIBILITY-RSG.

• Employee: A natural person who provides services to RESPONSIBILITY-RSG under an employment contract.

• Candidate: A natural person who submits their résumé for recruitment processes at RESPONSIBILITY-RSG.

3. Scope

​

This Policy applies to all personal data collected by RESPONSIBILITY-RSG in the course of providing its legal services, including data obtained from clients, employees, candidates, business partners, service providers, and users of our website (www.rspfirm.com). It also governs the use of cookies and similar technologies on our website. Its purpose is to inform data subjects about the purposes of processing, the use of cookies, the rights available to them, and the procedures to exercise such rights, in compliance with the LOPDP.

​

4. Personal Data Processed and Sources

RESPONSIBILITY-RSG collects personal data through the following modalities and sources:

​

Modalities:

• Data provided by the data subject: Information provided directly (e.g., name, ID number, email address, phone number).

• Data generated through contractual relationships: Data obtained during the provision of legal services or commercial relationships.

• Inferred data: Information derived from analysis or profiling, with prior consent.

• Third-party data: Information from public sources (public records, social media, credit information systems) or strategic partners.

Sources:

• Forms on the website (www.rspfirm.com)

• Emails, WhatsApp messages, phone calls, event forms, or invoices.

• Interactions on social media (when enabled).

• CRM systems and service proposals.

• Data transfers from authorized strategic partners.

• Cookies and tracking technologies on the website (see Section 9).

Types of data processed:

• Clients and prospective clients: First and last names, address, phone number, email address, nationality, credit information, occupation, billing data, bank or personal references.

• Employees: Basic data (name, phone number, email), employment data, health data (handled confidentially), image.

• Candidates: Contact information, résumé, work history, references, academic background.

• Service providers/Business partners: Contact information, banking details, details of contracted services.

• Website users: IP addresses, location data, browsing preferences, cookie information.

• Sensitive data: Image, voice, biometric data, health data, or judicial information, processed only with explicit authorization.

5. Principles Governing Data Processing

RESPONSIBILITY-RSG adheres to the principles set forth in the LOPDP:

• Lawfulness: Compliance with Ecuadorian regulations.

• Fairness and Transparency: Clear and accessible information about data collection and use.

• Purpose Limitation: Processing for specific, legitimate, and disclosed purposes.

• Relevance and Data Minimization: Collection of strictly necessary data.

• Proportionality: Appropriate, relevant, and non-excessive processing.

• Confidentiality: Protection against unauthorized use.

• Quality and Accuracy: Accurate, complete, and up-to-date data.

• Retention: Storage only for as long as necessary for the intended purpose.

• Security: Technical and organizational measures against risks.

• Proactive Accountability: Demonstrable compliance through audits.

• Data Subject–Favorable Interpretation: Interpretation in favor of the data subject in case of doubt.

6. Purposes of Personal Data Processing

Personal data is processed for the following purposes:

​

Clients and prospective clients:

• Provision of legal services in corporate law, arbitration, constitutional litigation, debt collection, administrative law, electoral law, and out-of-court conciliation.

• Sending legal newsletters, event invitations, or information about services.

• Conducting satisfaction surveys or data verification.

• Compliance with legal or contractual obligations.

• Managing inquiries, complaints, or requests.

• Personalizing services through analysis (with consent).

Employees and candidates:

• Managing recruitment and hiring processes.

• Verifying employment or academic references.

• Compliance with labor obligations.

• Ensuring facility security and assigning work tools.

Service providers/Business partners:

• Evaluating service quality and performance.

• Documenting the processing of shared data.

• Compliance with legal requirements.

Website users:

• Managing inquiries, subscriptions, or applications.

• Improving the browsing experience through cookies.

7. Consent

​

RESPONSIBILITY-RSG obtains the data subject’s prior, free, specific, informed, and unequivocal consent through forms, contracts, privacy notices, or digital platforms, including cookie banners on the website. Data subjects may deny or withdraw their consent at any time, without retroactive effect, by contacting contratos@responsibilityfirm.com. Explicit authorization is required for sensitive data and non-essential cookies. The Firm retains evidence of granted authorizations.

​

8. Data Transfers

​

RESPONSIBILITY-RSG does not sell, rent, or share personal data, except:

• With service providers or strategic partners, under confidentiality agreements.

• To comply with legal requirements or requests from authorities.

• In international transfers, only to countries with adequate levels of protection, in accordance with the LOPDP.

9. Use of Cookies and Tracking Technologies

 

Our website uses cookies and similar technologies to improve the user experience, analyze site usage, and personalize content.

 

Types of cookies used:

• Essential cookies: Necessary for the operation of the website (e.g., navigation, access to secure areas). No consent required.

• Performance cookies: Collect anonymous data about website usage to improve performance (e.g., Google Analytics).

• Functional cookies: Enable personalization of the experience (e.g., language preferences).

• Marketing cookies: Used to deliver personalized advertising, subject to consent.

Cookie management:
Users may accept, reject, or configure non-essential cookies via the cookie banner upon accessing the website. Cookies can also be managed through browser settings. Rejecting non-essential cookies may limit certain website functionalities. For more information, please contact legal@rspfirm.com.

​

10. Retention

​

Personal data and information collected through cookies are retained only for as long as necessary to fulfill the stated purposes or comply with legal obligations. Once the purpose has been fulfilled, data is deleted or anonymized, except where retention is required for public interest archiving, research, or audits.

​

11. Security Measures

​

RESPONSIBILITY-RSG implements technical and organizational measures to protect personal data and cookies, including encryption, firewalls, cloud backups, and access controls. Only authorized personnel have access to data, under strict confidentiality policies. The Firm is not liable for unauthorized access resulting from illegal interceptions or system breaches by third parties.

​

12. Data Subject Rights

​

In accordance with the LOPDP, data subjects have the following rights:

• Access: To consult the data processed by RESPONSIBILITY-RSG.

• Rectification and Updating: To correct inaccurate or incomplete data.

• Deletion: To request deletion of unnecessary data or after withdrawing consent.

• Objection: To object to processing, except for legitimate or legal grounds.

• Portability: To receive data in an interoperable format or request its transfer.

• Suspension of Processing: To request temporary suspension in specific cases.

• Not to be subject to automated decisions: To avoid decisions based solely on automated processing.

To exercise these rights, please contact contratos@responsibilityfirm.com with the subject line “Personal Data Protection.” Requests must include:

• Identification of the data subject (name, ID/passport, address).

• A clear description of the request and the right being exercised.

• Documents evidencing identity or legal representation.

RESPONSIBILITY-RSG will respond within a maximum of fifteen (15) business days. If clarification is required, the data subject will have ten (10) days to provide it after notification.

​

13. Amendments

​

RESPONSIBILITY-RSG may amend this Policy to adapt to regulatory changes or operational needs. Data subjects will be notified by publication on the website www.rspfirm.com or by email. If data subjects do not accept the changes, they may request deletion of their data or disable non-essential cookies.

​

14. Effective Date

​

This Policy enters into force in May 2025 and will be reviewed annually to ensure the accuracy and relevance of the data processed.

​

15. Contact

​

For inquiries or to exercise your rights, please contact us at:

Email: legal@rspfirm.com
Phone: +593 99 621 4993
Address: Av. Shyris N32-88 and Av. Eloy Alfaro, Edificio Shyris 186, Office 602, Quito, Ecuador