Privacy Policy

I.           INTRODUCTION

At COFIMAR S.A., we respect and protect your privacy. This Privacy Policy aims to provide you with clear information on how we collect, use, store, share and protect your personal data, in accordance with the Organic Law for the Protection of Personal Data (LOPDP) and its General Regulations, in force in Ecuador. We believe in an ethical and transparent management of personal information, so we implement the best security and privacy practices to guarantee your rights.

II.        SCOPE OF APPLICATION AND SCOPE

This policy applies to the processing of personal data collected through the website https://www.cofimar.ec, contact forms, institutional emails, official social networks and other channels of digital or face-to-face interaction provided by COFIMAR S.A. It does not apply to third party sites linked from our page, which have their own privacy policies. This site is intended for persons of legal age; we do not collect data from minors without verifiable consent of their legal representatives. If we identify data of minors, we will proceed with its immediate elimination.

III.      PERSON RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

• Company name: COFIMAR S.A.
• RUC: 0991329331001
• Address: Inmaconsa Industrial Park, Eucalyptus Street between Cedros and Teca, Guayaquil, Ecuador.
• DPD contact email: protecciondedatos@cofimar.com.ec

COFIMAR has appointed a Personal Data Protection Officer (DPD), who oversees compliance with legal obligations regarding data protection and serves as a point of contact for personal data owners.

IV.       COLLECTION OF PERSONAL DATA

Personal data is any information that makes it possible to identify a natural person, either directly or indirectly. This includes details such as name, address, identification number, contact details, among others.

Most of the services and information published on our website do not require any registration by the user, which allows the user to visit the site anonymously. However, other services do require the user to provide personal data to achieve the purpose for which they were designed described in section "5 purposes of the processing of personal data" of this privacy notice. The data that could be collected are:

• Identity data: Names, surnames, address, e-mail, telephone.
• Browsing Data: Information about your interaction with our website, such as IP address, browser type, and pages visited, time spent and links clicked. For more information review our Cookie Policy.
• Professional or labor data: resume, work experience, studies, in case of selection processes.
• Other data provided voluntarily on work with us forms, contact, whatsapp button or through emails.

COFIMAR does not request sensitive data or data of minors through its website. In case they are necessary, they will be exceptionally collected under express and informed consent, as established in the current regulations.

V.         PURPOSES OF THE PROCESSING OF PERSONAL DATA

In COFIMAR S.A., the personal data collected through our website in the forms are treated according to the purposes established in our Personal Data Protection Policy.

For detailed information on these purposes and the guidelines for the processing of personal data, we invite you to consult our Personal Data Protection Policy, available at https://www.cofimar.ec/.

VI.       LEGAL BASIS FOR PROCESSING

The processing of personal data carried out by COFIMAR is based on the following legal bases:

• The consent given by the holder for one or more specific purposes.
• The execution of pre-contractual or contractual measures requested by the owner.
• Compliance with legal and regulatory obligations imposed by applicable Ecuadorian and international regulations.

When the processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of the processing previously carried out.

VII.    NATIONAL AND INTERNATIONAL TRANSFER OF PERSONAL DATA

COFIMAR may communicate your personal data to public or private entities when there is a legal, judicial or administrative obligation to do so.

In cases where it is necessary to transfer personal data to third parties outside of Ecuador, compliance with Article 46 of the LOPDP will be ensured through:

• Standard contractual clauses or other legal mechanisms established by the Superintendence of Personal Data Protection.
• Evaluation of adequate protection guarantees, including providers adhering to international privacy and security standards.

VIII.  PRESERVATION OF PERSONAL DATA

Personal data will be kept only for the time strictly necessary to fulfill the specific purpose for which it was collected. Subsequently, they will be securely deleted or anonymized, unless there is a legal or contractual obligation for additional retention (e.g. tax, accounting, financial, etc.). COFIMAR periodically reviews the established retention periods.

IX.       RIGHTS OF THE HOLDER OF THE PERSONAL DATA

In accordance with current legislation, the Organic Law on Personal Data Protection (LOPDP), you have rights related to the processing of your personal data, such as: access, rectification, deletion, opposition, portability, revocation of consent and not being subject to automated decisions. Consult our Personal Data Protection Policy for further details of your rights.

To revoke your consent, you may send a written request to the e-mail: protecciondedatos@cofimar.com.ec, indicating your full name, identification number, the reason for the revocation and any document that supports your request. You may also do so by completing the RPQR Attention Form available on our website or at our physical offices. The revocation does not have retroactive effects and will be attended within the deadlines established by law.

If you wish to limit the use or disclosure of your personal data, you may exercise your right of opposition, revoke your consent or other, as provided in the regulations in force. To do so, you can send the request through the RPQR (Requests, Petitions, Complaints, Claims) Attention Form available at:

• Our website https://www.cofimar.ec/
• COFIMAR S.A. offices in Guayaquil.
• Or send it by e-mail to protecciondedatos@cofimar.com.ec

We will respond to your request within the deadlines established by current regulations, and always with the utmost respect for your rights.

X.         SECURITY MEASURES

At COFIMAR S.A., we guarantee the protection of personal data by implementing technical, administrative and physical measures designed to prevent unauthorized access, loss, alteration or destruction of information. These actions include encryption technologies, access controls and strict internal security policies.

In addition, we apply complementary measures such as access control differentiated by roles, periodic vulnerability assessments, penetration tests on our technological platforms, encrypted data backup and contractual confidentiality agreements with third parties that handle personal data, among other measures adopted by the company.

In addition, we encourage users to take extra precautions and to keep the security systems on their devices up to date in order to reinforce the protection of their information while surfing the Internet. The security of personal data is a shared priority between our company and users.

COFIMAR recommends the use of modern and updated browsers (such as Google Chrome, Mozilla Firefox, Microsoft Edge or Safari) for a safe and compatible experience with our digital services. COFIMAR does not guarantee the proper functioning of the website on browsers that have been discontinued or are not supported by the manufacturer.

XI.       COOKIE POLICIES

This site uses its own and third-party cookies to improve the user experience, measure site performance and offer personalized content. Cookies may be technical, analytical or advertising. The user can configure their browser to reject or accept certain cookies. For more information, see our Cookies Policy.

XII.     UPDATE AND VALIDITY

COFIMAR may modify this Privacy Policy at any time as a result of regulatory or technological changes or due to the implementation of new services or internal practices. Any modification will be communicated in a timely manner through our website. We encourage you to review it periodically to stay informed about how we protect your information.

Effective from: 07/01/2025