Draft: this notice is pending legal review
Privacy notice
Version 2026-10-25
How PKBX processes your personal data under Ecuador's Organic Law on Personal Data Protection (LOPDP).
Data controller
The controller of your personal data at PKBX is:
- Legal name
- [RAZÓN SOCIAL]
- RUC (tax id)
- [RUC]
- Address
- [DIRECCIÓN]
- Privacy contact email
- [CORREO]
Data we process
We process only the data the app needs to work:
- Account and player profile. Your email address, your password (stored only as a hash), your player handle, your language and, if you give it, your phone number. If you sign in with Google, Apple or GitHub, that provider gives us your email, your name and, if it has one, your profile picture. We record when you accepted this notice, its version and how (sign-up, profile completion or the arena desk) and, for each signed-in session, the IP address and the browser.
- Date of birth and age verification. Your date of birth tells whether you are under 18 and lets each arena apply its age and curfew rules. At your first check-in at each arena, staff verify your age against an identity document or record that you are clearly an adult; we keep the method, the date, the arena and who verified it, not the document number.
- Guardian consent, for minors. If you are under 18, your guardian gives consent in person at each arena before your first session there. Staff record their name, the type and number of their document (the number encrypted) and, if they give it, their email, to send them the invoices. The guardian can revoke the consent at the arena.
- Bookings and sessions. Your bookings (arena, station type, time and status), the waitlist, your play sessions and extensions, recorded no-shows, your prepaid hours, memberships, orders and payments.
- Billing profile and comprobantes. On your first payment: your id type and number (cédula, RUC or passport; the number is stored encrypted), name or legal name, email and, if you give it, address. Each electronic comprobante (invoice) keeps a copy of those details and of the purchase.
- Support tickets. The subject and text of the tickets you open, and the arena, booking or payment you link to them.
- Station technical data. The arenas' PCs and consoles run a PKBX agent that reports its platform, the agent version, its public key, the lock state and health signals (disconnections, tampering attempts, invalid signatures). They describe the arena's equipment, not you, but are linked to the session running on the station.
Purposes and legal basis
We use your data for these purposes, each with its legal basis:
- Performance of the service. Creating and keeping your account; managing bookings, check-in, sessions and locking and unlocking stations; taking payment at the desk; applying each arena's age rules; sending you notices about your bookings; answering your tickets, and protecting the platform against fraud and abuse (for example, by limiting sign-in attempts and recording actions in the audit log).
- Tax obligation (SRI). Issuing the electronic comprobantes for your payments, sending them to the SRI for authorisation and keeping them for the period tax rules require.
- Consent. You accept this notice when your account is created: at sign-up, when completing your profile or at the arena desk. For minors, their guardian's consent, recorded in person at each arena, is added. You can withdraw your consent by deleting your account; this does not affect processing already done or the comprobantes the law requires us to keep.
We do not sell your data or use it for advertising.
Recipients and processors
We share your data only with those who need it to provide the service:
- The arenas where you book or play. Each arena sees the data it needs to serve you: your player handle, whether you are a minor, your bookings, sessions, payments and comprobantes at that arena, and your guardian consent recorded there. Each arena issues its invoices under its own RUC. [PENDING: define whether each arena acts as a controller or as a processor.]
- The Internal Revenue Service (SRI). Receives the electronic comprobantes, with the buyer's billing details, to authorise them.
- The email provider (Mailgun). Sends the verification, password reset, invitation, notice and comprobante emails; it receives your email address and the content of each message.
- File storage ([PROVEEDOR DE ALMACENAMIENTO]). Stores the files the app produces: the electronic comprobantes (XML and PDF) and your data exports.
- Hosting ([PROVEEDOR DE ALOJAMIENTO]). Runs the application and the database where your data is stored.
- Google, Apple or GitHub, only if you choose to sign in with them. They confirm your identity when you sign in; we do not send them your bookings or payments.
- Competent authorities. Only when a law or a court order requires it.
International transfers
Some providers may process your data outside Ecuador: Mailgun, [PROVEEDOR DE ALOJAMIENTO] and [PROVEEDOR DE ALMACENAMIENTO], in [PAÍSES]. We give them only what is needed to provide the service. [PENDING: describe the safeguards the LOPDP accepts for each international transfer.]
Retention periods
- Electronic comprobantes: seven (7) years, as tax rules require, even if you delete your account.
- Account, profile, billing, bookings and sessions: while you keep your account. Deleting it erases or anonymises what identifies you: the profile, the billing profile, your guardian's details, the text of your tickets, your signed-in sessions and your exports.
- After the account is deleted: the records of bookings, sessions, payments and age verifications remain, without your name, email or profile, tied to an internal identifier, for the arenas' accounting and the integrity of the audit log.
- Exports of your data: the file is deleted after 7 days and its download link expires after 1 hour.
Your rights
The LOPDP grants you, among others, these rights:
- Access: to know which of your data we process and get a copy.
- Rectification: to correct or update your data if it is inaccurate or incomplete.
- Deletion: to ask us to erase your data, except what the law requires us to keep.
- Objection: to object to a specific processing of your data.
- Portability: to receive your data in a structured, machine-readable format.
How to exercise them in the app
- Access and portability: in My account › Privacy, request an export and download a JSON file with your account, profile, billing, booking, session, payment and comprobante data. You can request one every 24 hours.
- Rectification: change your player handle, language and phone in Profile, and your billing details in Billing. The date of birth cannot be changed in the app: ask for the correction in Support.
- Deletion: in Privacy you see what is lost (upcoming bookings, prepaid hours, memberships) and confirm with your player handle and your password, or by signing in again if your account has no password. The account cannot be deleted while you have unpaid charges or a session in progress, or if you are the last owner of an arena.
To object to a processing or for any other request, write to [CORREO] and include your account email. We will answer within the period the LOPDP sets.
If you are not satisfied with the answer, you can file a complaint with the Superintendency for Personal Data Protection.
Security
- Cédula, RUC and passport numbers, yours and your guardian's, are stored encrypted (AES-GCM); lookups use an index that does not reveal the number.
- Passwords are stored only as a hash: nobody at PKBX can read them.
- Lock and unlock commands to the stations are digitally signed and each station identifies itself with its own key; comprobantes are electronically signed, as the SRI requires.
- Download links for your data are signed and expire after 1 hour.
- A write-only audit log records who did each action and when (bookings, payments, age verifications, profile changes, exports, account deletions); it keeps identifiers, not personal data.
- Each arena's staff see only what their role allows, and sign-in limits repeated attempts.
Cookies
We use only the cookies the app needs to work:
- Session: keeps you signed in; it is removed when you sign out or when it expires.
- Language (NEXT_LOCALE): remembers the language you chose, for one year.
- If you sign in with Google, Apple or GitHub, a temporary cookie is also used during sign-in to complete it.
- Your theme preference (light or dark) is kept in your browser's local storage, not in a cookie, and is not sent to PKBX.
We do not use analytics, advertising or third-party cookies.
Changes to this notice
If we change this notice, we will publish the new version on this page with its date. Each acceptance is recorded with the version in force at that moment.
Version in force: 2026-10-25.