Privacy Policy

Ejecutivos de Élite (app registered as “Ejecutivos de Élite – Gestión”) — operated by Lucas Albo LLC · Last updated: September 16, 2026

This Privacy Policy explains how Lucas Albo LLC (“we”), through the Ejecutivos de Élite platform —registered on Meta as “Ejecutivos de Élite – Gestión”— available at app.ejecutivosdeelite.com (the “App”), collects, uses, stores, shares and protects personal data. By using the App, you accept this policy.

1. Controller and contact

Controller: Lucas Albo LLC. Questions or requests: lucas@lucasalbo.com.

2. Who this applies to

• App users: people who use the App with their account to manage their advertising campaigns and their leads.
• Leads: people who complete a user’s instant lead form on Meta, whose data the App displays to the user who owns the campaign.

Regarding leads, each user is the controller of their own leads’ data; Lucas Albo LLC acts as a processor handling that data on their behalf.

3. Data we collect

• User account data: name, email and in-app activity.
• Connected Facebook Pages: when a user voluntarily connects their Page, we access the list of their Pages and an access token to read their leads.
• Leads: name, phone, email and the answers submitted in Meta’s instant form.
• Notifications: the device’s push subscription, if the user enables it.
• Technical data: minimal session data for operation and security.
• Sign-in log: so we can resolve “I can’t log in” reports, for each sign-in attempt we store: date and time, the email used to request access, the account identifier if one exists, the address that was opened, where it ended up, and whether the visit came from the installed app or from a browser. We do not store IP addresses, device identifiers, any device fingerprint, or the content of what a person writes or views inside the App.

4. How we collect data

• Directly from the user on sign-up and login.
• Through Meta’s APIs, via the permissions the user explicitly authorizes (section 7).
• Automatically, technical session data and the sign-in log described in section 3.

5. How we use data

• Give each user access to their account and the App’s features.
• Show each user only their own leads.
• Send notifications (push and/or email) when a new lead arrives.
• Operate, maintain and secure the App.

We do not use leads’ data for our own advertising, we do not sell it, and we do not reuse it for any purpose other than displaying it to the user who owns the campaign.

6. Legal basis

We process data based on consent, performance of a contract, and our legitimate interest in operating the platform securely.

7. Meta permissions we request

For the sole purpose of reading and displaying the leads of the Pages the user voluntarily connects:

• pages_show_list — list the user’s Pages so they can choose which to connect.
• leads_retrieval — read that Page’s leads.
• pages_read_engagement — read basic Page information.
• pages_manage_metadata — subscribe the Page to new-lead notifications.

We do not publish content, send messages or take any other action on behalf of the Page. We comply with the Meta Platform Terms and Developer Policies.

8. Who we share data with

We do not sell or rent personal data. We only share it with providers acting as processors under contract:

• Airtable — database.
• Vercel — hosting.
• Resend — transactional email.
• Meta Platforms — source of the leads’ data.

We may also disclose data if required by law or to protect rights and safety.

9. Retention

We keep data while the account is active and necessary. The user may disconnect their Page or request deletion at any time; we delete data within 30 days, unless legally required to retain it.

The sign-in log is kept for 90 days and is then deleted automatically. It is used only to diagnose access problems and can be consulted only by the platform’s administration.

10. Security

We apply reasonable measures: HTTPS, tokens stored server-side (never exposed to the browser) and restricted access.

11. Your rights

• Access, rectification, deletion, objection, restriction and portability.
• Withdraw consent by disconnecting your Page or disabling notifications.

To exercise them: lucas@lucasalbo.com.

12. Data deletion

You can delete your data from the App (My Leads → disconnect your Page) or by email. Instructions: Data deletion.

13. International transfers

Lucas Albo LLC is based in the USA, and our providers may process data in the USA or other countries, with appropriate safeguards.

13 bis. Cookies and similar technologies

This policy also covers the public websites of Ejecutivos de Élite (ejecutivosdeelite.com and its subdomains, including lead pages such as afinador.ejecutivosdeelite.com and serie.ejecutivosdeelite.com). We use three kinds of cookies:

• Necessary: make the site work (for example, your session in the App and your cookie choice). They do not require consent.
• Statistics: let us measure how many people visit each page and how they use it.
• Marketing: the Meta pixel, which lets us measure the results of our ads and show you relevant ads on Facebook and Instagram.

Statistics and marketing cookies are only activated if you accept them in the notice shown when you arrive. You can accept all, only the necessary ones, or choose by category. Your choice is stored in your browser for 12 months and you can change it at any time from the “Cookies” link in the footer of each site, or by clearing the site data in your browser. Declining statistics or marketing cookies does not limit your use of the site.

In Chile, Law 21.719 on personal data protection (in force from December 1, 2026) requires prior, informed and revocable consent for this kind of processing; this mechanism is designed to comply with it.

14. Minors

The App is intended for adults. We do not knowingly collect data from minors.

15. Changes

We may update this policy; the current version with its date will be published on this page.

16. Contact

Lucas Albo LLC · lucas@lucasalbo.com