Privacy Policy

Ejecutivos de Élite (app registered as “Ejecutivos de Élite – Gestión”) — operated by Lucas Albo LLC · Last updated: June 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.

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.

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We do not publish content, send messages or take any other action on behalf of the Page.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.

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.

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