Avanza — Your pay within reach

AVANZA Platform Privacy Notice

This Privacy Notice explains, in a clear and simple manner, how AVANZA processes the personal data of employees — in their capacity as data subjects — through AVANZA's technology platform (the “PLATFORM”).

The PLATFORM allows employees who freely and voluntarily decide to do so to access services related to facilitating the assignment of payroll collection rights, in accordance with the terms, conditions, contracts, authorizations, and other documents that each user accepts or signs on the platform.

1. Roles in the processing of personal data

AVANZA is the company that administers the PLATFORM through which employees may, if they so wish, access services facilitating the assignment of payroll collection rights.

Through the PLATFORM, the employee may register, validate their identity, check the availability of amounts, request the assignment of payroll collection rights, accept applicable conditions, assign payroll collection rights, receive disbursements, authorize deductions, check transactions, and manage requests related to the service.

In this regard, two moments relevant to the processing of personal data:

1.1. First moment: information shared by the employer to enable the PLATFORM

The employee's employer may share, communicate, transfer, or grant access to certain personal data in favor of AVANZA. This occurs so that AVANZA can register, identify, validate, configure, and enable the employee as a potential user of the platform. At this stage, the employer acts as the data controller with respect to the personal data it maintains within the framework of the employment and payroll relationship.

AVANZA receives and processes such information solely for the purposes related to the enablement, initial operation, and administration of the platform, in accordance with the master agreement or contract executed with the employer and applicable regulations.

1.2. Second moment: direct relationship between the user and AVANZA

When the employee accesses the platform, activates their user account, accepts terms and conditions, requests the assignment of collection rights, signs documents, authorizes deductions, assigns collection rights, or carries out any transaction directly with AVANZA, a direct relationship between the user and AVANZA is established. At this stage, AVANZA acts as the data controller with respect to the personal data. In certain cases, AVANZA may share personal data with the employee's employer for the execution of payroll collection rights assignments.

AVANZA's contact information is as follows:

Legal address: Quito, Pichincha, Ecuador
Email: legal@tuavanza.com
Phone: +593995550265

2. Categories of personal data

AVANZA may process the personal data that is necessary, relevant, and proportional to operate the platform and provide its services. Such data may include, as applicable:

Identification data: Names, surnames, national ID or identification document number, signature, electronic acceptance, username or identifier on the platform.
Contact data: Email address, phone number, address.
Employment data: Employer, position, area, employment status, salary, remuneration, available limit, reference limits, outstanding amounts, present or future employment earnings, amounts subject to deduction or reconciliation.
Banking data: Bank, account type, account number, account ownership.
Transactional data: Requests for the assignment of collection rights, amounts, dates, transaction statuses, disbursements, deductions, payments, balances, reconciliations, and assignments of collection rights.

AVANZA will not request personal data that is not necessary for the purposes disclosed, unless there is an additional lawful purpose and a valid legal basis for doing so. Additionally, it is hereby stated that AVANZA does not collect biometric data, but only interacts with data stored on the employee's device to facilitate the employee's onboarding process to the platform, if the employee so wishes.

3. Source of personal data

AVANZA may obtain personal data from the following sources:

The employer: when it shares data necessary to register, identify, validate, configure, or enable the employee as a potential user of the platform.
The user: when the user registers, accesses the platform, updates their information, requests the assignment of collection rights, accepts terms, signs documents, assigns collection rights, or communicates with AVANZA.
The AVANZA platform: when data is generated through use of the platform, traceability, acceptances, requests, transactions, disbursements, reconciliations, or support.
Third parties authorized or necessary for the operation: no personal data will be received from third parties.

4. Purposes of the processing of personal data

On the PLATFORM, personal data will be used for the following purposes:

To register, identify, authenticate, and validate the user on the PLATFORM.
Legal basis: Consent and compliance with pre-contractual and contractual obligations.
To configure quotas, limits, or reference amounts available for the assignment of collection rights.
Legal basis: Compliance with pre-contractual and contractual obligations.
To allow the user to view information related to the service.
Legal basis: Compliance with pre-contractual and contractual obligations.
To manage requests for the assignment of payroll collection rights made by the user, document them, and send notifications.
Legal basis: Consent and compliance with pre-contractual and contractual obligations.
To make disbursements, transfers, or payments to the user.
Legal basis: Compliance with pre-contractual and contractual obligations.
To coordinate with the employer the information necessary for deductions, withholdings, reconciliations, offsets, or collections arising from transactions accepted by the user.
Legal basis: Compliance with pre-contractual and contractual obligations.
To address inquiries, requests, complaints, technical support, operational incidents, or user requirements.
Legal basis: Compliance with pre-contractual and contractual obligations.
To prevent, detect, and manage fraud, unauthorized access, misuse of the platform, or security incidents.
Legal basis: Compliance with legal obligations and legitimate interest.
To comply with legal obligations or requirements of a competent authority.
Legal basis: Compliance with legal obligations, judicial order, a mission carried out in the public interest.
To improve the security, stability, functionality, and user experience of the PLATFORM.
Legal basis: Compliance with pre-contractual and contractual obligations.

It should be noted that the platform does not perform automated assessments or decisions.

5. Exercise of rights

Personal data protection regulations grant data subjects rights over their personal data. Without prejudice to the provisions of the applicable regulations, the rights afforded to you are:

Right to information: to be informed about the personal data that is subject to processing in accordance with applicable regulations.
Right of access: to know and obtain free access to your personal data processed by AVANZA.
Right of rectification and updating: to request the rectification and updating of your personal data.
Right of erasure: to request the deletion of your personal data in the cases provided for by applicable regulations.
Right of opposition: to object to or refuse the processing of your personal data, in the cases contemplated by applicable regulations.
Right to data portability: to request your personal data in a compatible format or to require its transfer to another controller, where applicable.
Right to suspension of processing: to request the temporary or permanent suspension of the processing of all or part of your personal data, when the conditions established in applicable regulations are met.
Right not to be subject to decisions based on automated assessments: not to be subject to decisions based exclusively on automated assessments that may affect your rights, except in cases permitted by applicable regulations.

To ensure that employees can exercise their rights and/or revoke their consent, when consent is the applicable legal basis, they may contact AVANZA through the email address legal@tuavanza.com.

The email must include at least the following information: full name, identification number, home or email address, description of the data with respect to which you wish to exercise your right, description of your request, identification of the right to be exercised, information proving your identity or that of your representative, and any other information that may be useful for AVANZA to process your request.

Once your request has been received, AVANZA will process it and respond within the timeframes provided for by applicable regulations. With respect to requests you make to the Personal Data Protection Authority, you must follow the procedures determined by such authority.

6. Data transfers and/or communications

AVANZA may communicate or transfer your personal data, when necessary and in accordance with applicable regulations, to the following recipients:

Providers of technology services, information hosting, and system maintenance.
Administrative, judicial, tax, regulatory, or oversight authorities, when there is a legal obligation, a valid request, or a need to defend rights.

In the event that international transfers of personal data are carried out, these will be performed in accordance with the mechanisms, safeguards, and requirements provided for by applicable personal data protection regulations.

7. Retention of your personal data

Personal data will be retained for the time necessary to fulfill the purposes described in this Notice, including management of the business relationship, handling of requests, compliance with legal, tax, accounting, contractual, administrative, or regulatory obligations, as well as for the defense of the rights of AVANZA or third parties.

Once the purposes of the processing have been fulfilled or the applicable legal retention periods have expired, the personal data will be deleted, anonymized, or blocked, as applicable and in accordance with applicable regulations.

8. Protection measures

AVANZA has implemented reasonable technical, organizational, administrative, and security measures to protect personal data against loss, unauthorized access, alteration, disclosure, destruction, or misuse.

9. Modifications to this Notice

AVANZA may modify this Privacy Notice when necessary, for example, as a result of regulatory changes, updates to internal processes, the addition of new services, changes to the purposes of processing, or changes to service channels.

When material changes are introduced, AVANZA will endeavor to inform data subjects through the PLATFORM.

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