Privacy and Personal Data Protection Policy
Last Updated: May 19, 2025
At JXBS S.A.S. (hereinafter “JXBS”), we value your privacy and are committed to protecting your personal data. This Privacy and Personal Data Protection Policy describes how we collect, use, and protect your personal data when you use our website and provide us with your information. Please read this policy carefully to understand our procedures and practices.
1. Legal Framework and Legal Basis.
In compliance with the Constitution of the Republic, the Organic Law on Personal Data Protection (“LOPDP”), its General Regulations (“Regulations”), and other applicable legislation, JXBS publishes this Privacy and Personal Data Protection Policy (hereinafter, the “Policy”) to inform how we safeguard your personal data, your rights as a data subject, how the law protects you, and the criteria under which JXBS processes the personal data that it collects, handles, stores, and uses.
2. Data Controller
JXBS acts as the data controller. Below are the contact details of the company.
RUC No.: 0195153892001
Address: Victor Manuel Albornoz 555
Phone number: 0995284006
Email address: protecciondedatos@jxbs.ai
3. Scope of Application
This Policy is mandatory for employees, consultants, business partners, suppliers, and related parties acting on behalf of JXBS.
Compliance with this Policy is essential when handling Personal Data. This commitment also extends to the public domain, as the Policy is published on JXBS’s website to ensure general awareness.
4. Definitions
i. Personal Data Protection Authority: Refers to the Superintendency of Personal Data Protection.
ii. Database: A structured set of data, regardless of the format, creation method, storage, organization, support type, processing, location, or access—centralized, decentralized, or distributed geographically or functionally.
iii. Personal Data: Information that identifies or makes a natural person identifiable, directly or indirectly.
iv. Sensitive Data: Data related to ethnicity, gender identity, cultural identity, religion, ideology, political affiliation, criminal history, migration status, sexual orientation, health, biometric data, genetic data, and any data whose misuse could lead to discrimination or infringe on fundamental rights and freedoms.
v. Data Protection Officer: A natural person responsible for informing the controller or processor about their legal obligations regarding data protection, ensuring compliance, and cooperating with the Personal Data Protection Authority. They serve as the contact point between the Authority and the data controller.
vi. Recipient: A natural or legal person to whom Personal Data has been communicated.
vii. Processor: A natural or legal person, public or private, public authority, or other entity that processes Personal Data on behalf of the data controller.
viii. Controller: A natural or legal person, public or private, public authority, or other entity that alone or jointly determines the purposes and means of processing Personal Data.
ix. Data Subject: A natural person whose Personal Data is subject to processing.
x. Processing: Any operation or set of operations performed on Personal Data, whether automated, partially automated, or manual, such as collection, recording, organization, structuring, storage, adaptation, modification, erasure, indexing, consultation, use, possession, distribution, communication, transfer, interconnection, restriction, destruction, and, in general, any use of Personal Data.
xi. Transfer or Communication: Any disclosure, delivery, consultation, interconnection, assignment, transmission, dissemination, or other form of communication of Personal Data to a third party other than the Data Subject, controller, or processor. Communicated data must be accurate, complete, and up to date.
5. Rights of Data Subjects
JXBS recognizes and guarantees the following rights to Data Subjects, as established by the LOPDP:
5.1 Information: The right to be informed about how we collect and process your Personal Data, including information about who we are, how we use your data, and your rights regarding such data.
5.2 Access: The right to know whether JXBS is processing your Personal Data and to access the Personal Data processed by JXBS.
5.3 Rectification and Updating: The right to have incorrect or inaccurate Personal Data rectified or updated by JXBS.
5.4 Deletion: The right to request the deletion of your Personal Data when the processing: (i) does not fulfill a legal obligation; (ii) is unnecessary; (iii) has achieved its purpose; (iv) has exceeded the retention period; (v) affects fundamental rights; or (vi) when consent has been withdrawn.
5.5 Objection: The right to object to the processing of your Personal Data when it does not affect fundamental rights and is not related to public or general interest information.
5.6 Portability: The right to request JXBS to provide your Personal Data in a compatible format and/or to transfer your data to another controller.
5.7 Suspension: The right to request the suspension of data processing under the following conditions: (i) dispute over data accuracy, (ii) unlawful processing with request for limitation instead of deletion, (iii) when JXBS no longer needs the data but the Data Subject requires them for claims, and (iv) pending verification of legitimate grounds following an objection.
5.8 Right to Request Review of Decisions Made Solely by Automated Processing: The right to object, request explanations, and demand human intervention in decisions made solely based on automated data processing that affect your interests.
6. Exercising Data Subject Rights
Data Subjects may exercise their rights to access, rectification and updating, deletion, suspension, objection, portability, and to not be subject to decisions based solely on automated processing. To exercise these rights, Data Subjects must verify their identity using one of the following mechanisms:
6.1 Request via email: protecciondedatos@jxbs.ai
In accordance with the LOPDP, JXBS will respond to rights requests within fifteen (15) days of receipt, unless clarification or additional information is required.
If clarification is needed, JXBS will request it within five (5) days of receiving the request. The Data Subject will have ten (10) days from the next day to provide the requested information.
If the Data Subject does not provide the clarification or information within the set timeframe, JXBS will file the request and notify the Data Subject, without prejudice to their right to submit a new request.
The Data Subject has the right to file a complaint with the Personal Data Protection Authority if they believe their rights have been violated or if they have not received a response within the legal period.
Please note that the exercise of these rights may be subject to limitations established by applicable data protection regulations.
10. Retention of Personal Data
JXBS retains Personal Data for as long as necessary to fulfill the purposes that justify its processing, in accordance with applicable regulations and considering administrative, accounting, tax, legal, and historical requirements.
Personal Data is stored in an information system specifically designed for this purpose, ensuring its security.
Once the purposes for processing have been fulfilled—and unless otherwise required by law—Personal Data will be deleted. However, if anonymized, such data will no longer be considered personal and may be used freely by JXBS.
Notwithstanding the above, Personal Data must be retained when required to fulfill a legal, contractual, or audit obligation, and up to the statute of limitations for legal actions.
11. Refusal to Provide Data
If the Data Subject refuses to provide Personal Data or objects to its processing, JXBS will be unable to fulfill the purposes set out in this Policy and will not be able to meet your requests.
12. Inaccurate or Incorrect Data
Providing inaccurate or incorrect Personal Data affects our ability to fulfill the purposes outlined in this Policy. Therefore, the Data Subject is solely responsible for ensuring the data provided is accurate, complete, and up to date.
The Data Subject shall be responsible for any false, inaccurate, or outdated information provided voluntarily, as well as for any direct or indirect damages it may cause. If required data is not provided, JXBS will not be able to fulfill the purposes stated in this Policy.
13. Use of Personal Data
13.1 Limitation of Use
The personal data collected will be used solely for the purposes stated by JXBS in this Policy and will not be used for other purposes.
JXBS S.A.S. commits to maintaining an appropriate and optimal privacy and data handling policy to protect users’ interests while such data remains under its control and not in the hands of unrelated third parties.
With regard to third-party transfers or disclosures, their purpose and activities will always align with those of JXBS S.A.S.
14. Security Measures
JXBS implements appropriate technical and organizational measures to safeguard Personal Data, ensuring its confidentiality, integrity, and availability. These measures are designed to prevent loss, alteration, unauthorized access, or unlawful processing, taking into account the nature and volume of Personal Data, the state of technology, implementation costs, and associated risks.
Employee training and awareness are fundamental components of this Policy. For external third parties, this Policy is available on the JXBS website for public access.
15. Policy Updates
JXBS periodically reviews and updates this Policy in response to regulatory changes or directives issued by the Data Protection Authority.
You can review updates by accessing the current version, available through JXBS’s official channels. If changes are made, JXBS will notify Data Subjects accordingly.
The most recent update to this Policy was made on May 19, 2025.
7. Personal Data Processed
7.1 Types of Personal Data
JXBS processes personal data voluntarily provided by you when using our website, sending us emails, or communicating through any officially recognized platform enabled by JXBS. This personal data may be stored in digital formats or as recordings (such as interviews), and may include, but is not limited to:
- Identification data: Names, surnames, ID number.
- Contact data: Home addresses, email address, phone numbers.
- Academic data: Academic background (degrees), degree registry, languages.
- Professional data: Information included by each candidate as part of their CV, letters of recommendation, work experience, and skills.
- Interview videos: If required by the employer during the recruitment process.
- Psychometric and technical test results.
- Case study evaluations.
- Reviewing and evaluating CVs and candidate information.
- Communicating with candidates regarding job opportunities, interviews, and selection processes.
- Analyzing test and assessment responses.
- Analyzing and providing feedback on interview videos, psychometric tests, and case studies.
- Drawing conclusions based on the analysis of videos, tests, and case studies.
- Statistical analysis, professional skills assessment, and related services.
- Customer service activities, including responding to inquiries, suggestions, or complaints.
- Sending information related solely to employability and education, such as job or course offers.
