Privacy Policy

1. Controller and scope

The data controller is Servicios ESOL Operations Leaders, C.A. ("ESOL"), tax identification number RIF J-50603293-7, a Venezuelan company registered with the Second Commercial Registry of Anzoátegui State on September 25, 2024, under No. 4, Volume 45-A.

Location: El Tigre, Anzoátegui.

This Policy applies to website visitors, prospects, customers, suppliers, operating partners and contact persons communicating with ESOL through digital channels. Contracts, employment relationships or regulated processes may include supplemental notices; if there is a conflict, the notice specific to the relevant processing will apply.

2. Data we may collect

We collect only the data reasonably necessary to answer an inquiry, assess a requirement, prepare a proposal, coordinate a service or protect our systems.

• Identity and contact data: full name, company, position, email address, telephone number and WhatsApp number.
• Operational requirement data: equipment type and quantity, location, expected start date, duration, scope, access conditions and coordination details.
• Industrial Bases requests: owner or investor status, asset type, location, intended transaction and, when an opportunity proceeds to private review, descriptive, economic and ownership data and property documents supplied by authorized persons.
• Professional profiles: current role, company, location, specialty, experience, availability, certifications, declared projects or clients, LinkedIn profile and a PDF résumé submitted for assessment for possible inclusion in ESOL's private specialist network.
• Supplier and contractor registrations: company name, contact person, email, WhatsApp, operating city and state, selected service categories, declared capacity or equipment, language, source path, UTM parameters and referring page. Tax records, certifications, HSE documents and other evidence are requested only at a later stage through a private channel when needed.
• Commercial and documentary information: quotations, orders, communications, billing information, supplier or equipment documents and files that a person chooses to submit.
• Technical and analytics data: IP address, date and time, browser, device, operating system, requested URL, referring page, security logs and server diagnostics; if you accept Google Analytics 4, also pseudonymous identifiers, parameter-free page path, language and limited interaction events.
• Interaction history: emails, WhatsApp messages, requests, responses, contact preferences and records of authorizations or rights requests.

3. Data sources and contact channels

Data may come directly from you, the organization you represent, a customer or supplier that designates you as a contact, legitimate business records or your technical interaction with the website. If you provide another person's data, you represent that you are authorized to do so and agree to inform that person about this Policy.

When you use the WhatsApp button, you leave the ESOL website and enter a service operated by WhatsApp/Meta. That provider may process identifiers, metadata, address-book information and communications under its own terms and privacy policy. Do not send passwords, full banking data, health data, unnecessary identity documents or other sensitive information through WhatsApp; request a secure channel when the service requires confidential documents.

4. Purposes of processing

• Answer inquiries and verify the identity and authority of the contact person.
• Assess requirements, availability, location, route, logistics, personnel, HSE conditions and equipment documentation.
• Prepare quotations, proposals, contracts, service orders and pre-contractual communications.
• Assess and connect, subject to human review, industrial real-estate opportunities submitted by owners and property requirements submitted by investors, and coordinate contacts, visits and negotiations where appropriate.
• Prequalify and verify, subject to human review, supervision, inspection, coordination and control professionals for possible inclusion in the private specialist network and, where there is a fit, contact the individual regarding a specific operational requirement; registration is not an employment offer or a guarantee of assignment.
• Register, classify and review, with human involvement, the capacity declared by suppliers and contractors; request verification documents when there is a potential fit and send compatible requests for quotation. Registration is free, does not automatically verify a business and does not guarantee contracts, awards or work.
• Schedule, coordinate, control and document the performance and closeout of industrial and oilfield services.
• Manage customer, supplier and operating-partner relationships, including billing, collection, compliance and audit.
• Maintain website security, availability, traceability and performance, and prevent fraud, abuse, incidents or unauthorized access.
• Comply with legal, tax, accounting, regulatory, judicial and industrial-safety obligations.
• Improve processes, service quality, digital architecture and planning through statistical analysis, automation and artificial intelligence subject to human controls.

5. Grounds for processing

Depending on the relationship and applicable jurisdiction, ESOL processes data because you consent; because processing is necessary to take steps at your request before entering into or performing a contract; because a legal obligation applies; or because ESOL has legitimate business interests such as answering B2B requests, managing suppliers, securing systems, preventing fraud and improving operations, after balancing individual rights.

Optional measurement through Google Analytics 4 is based on consent and remains disabled until acceptance. Where consent is the basis, you may withdraw it at any time without affecting prior lawful processing. If data is essential to a proposal, contract, security measure or compliance duty, failure to provide it may prevent ESOL from handling or performing the request.

6. Automation and artificial intelligence

ESOL may use automation and artificial-intelligence tools to classify requests, detect missing fields, summarize communications, support planning, analyze capacity and improve the website. Data minimization, access controls and, where reasonable, pseudonymization or anonymization are applied.

ESOL does not use the website to make solely automated decisions that produce legal or similarly significant effects on an individual. Commercial, technical, documentary, HSE and allocation decisions require human review. Customer data is not used by ESOL to train public or general-purpose models unless there is express authorization, a sufficient legal basis and specific safeguards.

7. ASAD TECHNOLOGIES L.L.C-FZ support and international transfers

ASAD TECHNOLOGIES L.L.C-FZ, an independent legal entity established in Dubai, United Arab Emirates, provides ESOL with technology support, digital architecture, automation and AI-assisted optimization. When it accesses data on ESOL's behalf, it must process that data for documented purposes and under confidentiality, security, minimization, access-restriction and deletion or return obligations.

Technical data and information strictly necessary to provide support may therefore be stored, accessed or processed from the United Arab Emirates and, where cloud or communications providers are used, from other countries. ESOL assesses its providers and applies reasonable contractual, organizational and technical safeguards to maintain an appropriate level of protection, taking into account Venezuelan constitutional and statutory requirements and, where applicable, UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data or other applicable laws.

If ASAD TECHNOLOGIES L.L.C-FZ independently determines purposes and means for separate processing, it is responsible for that processing and must provide its own notice. Its technology role does not make it an ESOL subsidiary, branch or commercial representative.

8. Recipients and service providers

ESOL does not sell or rent personal data. It may disclose data on a limited, need-to-know basis to:

• ASAD TECHNOLOGIES L.L.C-FZ and hosting, infrastructure, backup, cybersecurity, email and web-support providers.
• Google and the entities providing Google Analytics 4 and Google Tag Manager, only when you accept analytics and under the applicable regional terms.
• WhatsApp/Meta and other communications providers when you choose to use their channels.
• Operating partners, equipment owners, carriers, HSE personnel, customers or contractors when necessary to quote, validate or perform a service and a lawful ground exists.
• Banks, insurers, auditors, accountants, lawyers and advisers subject to professional duties.
• Authorities, courts or competent bodies when required by law, a valid order or the protection of rights and safety.
• A successor entity in a reorganization, merger or business transfer, subject to confidentiality and continuity of protection.

9. Retention and deletion

ESOL retains data for the time needed for the stated purpose and periodically reviews that need. The following general periods apply unless a legal duty, dispute, investigation, security need or agreement justifies a different period:

10. Information security

ESOL uses measures proportionate to risk, including HTTPS, access controls, least privilege, backups, event logging, updates, anti-spam measures, confidentiality duties and provider review. Access is limited to personnel and third parties that need the data for their duties.

No system is completely infallible. If an incident affecting personal data is confirmed, ESOL will seek to contain and document it, reduce its impact and provide notifications required by applicable law.

11. Individual rights

Under Article 28 of the Constitution of the Bolivarian Republic of Venezuela and other applicable rules, you may request access to data held about you, learn how and why it is used, and seek its updating, correction or deletion when it is inaccurate or unlawfully affects your rights. Where the applicable jurisdiction provides, you may also object, request restriction or portability and withdraw consent.

To exercise a right, use the contact details below, describe your request and provide enough information to verify your identity. ESOL will not request more data than necessary and may require proof of representation. It will respond within the applicable period. Rights may be limited by legal duties, trade secrets, third-party rights, security, claims or freedom of expression. If dissatisfied, you may apply to the courts or another competent authority in your jurisdiction.

12. Cookies and technical logs

The website integrates Google Analytics 4 with Consent Mode and deferred loading. Analytics remains denied by default and gtag.js is not downloaded until you accept; declining does not restrict the website. After acceptance, GA4 may create pseudonymous identifiers and measure pages and contact events without intentionally receiving form fields, names, emails or telephone numbers. ESOL keeps Google Signals, advertising personalization and advertising storage disabled. You may change the choice through “Cookie preferences”. See /en/cookies/ for the current inventory, duration and controls.

13. Children and sensitive data

The ESOL website and services are business and industrial in nature and are not directed to persons under 18. ESOL does not knowingly collect children's data through the website. If you believe a child has submitted information, contact us so that deletion can be assessed.

Do not send sensitive categories or excessive personal documentation through public forms, email or WhatsApp. If a service requires specially protected data, ESOL will identify the appropriate channel, purpose and safeguards.

14. Third-party links and services

The website links to external services. ESOL does not control their practices, security or content, and this Policy does not replace their notices. Review their terms before providing data. A link does not mean ESOL and the third party are the same entity or that ESOL generally endorses all of its activities.

15. Changes, governing framework and language versions

ESOL may update this Policy for legal, operational or technological changes. The published version will show the revision date; where a change is material, ESOL will seek to provide reasonable advance notice if required by law.

This Policy is interpreted under the applicable laws of the Bolivarian Republic of Venezuela, including constitutional guarantees of privacy and data access, without excluding mandatory rules of another jurisdiction that apply. The English and Arabic versions are faithful translations for convenience. If they differ, the Spanish version prevails to the extent permitted by law.

Operators and equipment owners portal

The private portal supports confirmed email accounts, company registration, declared equipment, supplier/owner/operator relationships, availability and documents. It may include photographs and assigned personnel identification where relevant. Provide third-party data only when authorized.

Supabase manages authentication and private storage. The browser retains the session; sign out on shared devices. Portal files are not automatically published in the public catalog. Access is restricted to authorized representatives and ESOL personnel according to their duties.

ESOL records changes, reviews and decisions for traceability. A linking request based on a tax ID, plate or serial does not grant access by itself. Document review, inspection and operation-specific clearance are separate processes; registration does not guarantee work.