Personal Data Processing Policy

InnerChispa uses purpose limitation, data minimization, access control, documented retention and human governance when processing personal data.

Scope

This policy applies to personal data processed through the official website and public communication channels. Customer deployments, employee processes, access-control projects, payroll workflows or other business systems require separate notices, agreements, security assessments and retention rules appropriate to the actual project.

Processing principles

• Lawfulness, fairness and transparency.
• Specific and documented purposes.
• Collection limited to reasonably necessary information.
• Accuracy, security, confidentiality and controlled access.
• Retention only for a justified period.
• Human review for sensitive or high-impact actions.

Operational safeguards

Measures may include role-based permissions, approval gates, logging, separation of public and private scopes, local processing where appropriate, encryption offered by infrastructure providers, backups, incident investigation and deletion or anonymization when data is no longer required.

AI and automated assistance

AI may assist with classification, summaries, retrieval, recommendations or drafts. Pricing, payroll, contractual commitments, sensitive profiling and other high-impact actions require defined human review. Model output is treated as assistance rather than unquestionable fact.

International processing

InnerChispa is a United States company and may use approved service providers in more than one jurisdiction. Customer-specific processing must identify controller and processor roles, relevant locations, safeguards and subprocessors when required. InnerChispa does not claim a legal establishment or legal representative in Ecuador.

Rights and requests

Requests concerning personal data may be sent to privacy@innerchispa.us. Reasonable identity verification may be required. The request will be assessed and answered within the period required by the law applicable to the specific processing.