Training or fine-tuning models on own data in Ecuador: related rules

Training, fine-tuning or grounding models on customer, employee or public data. It requires a legal basis to reuse personal data, dataset documentation and, when developing a general-purpose model, provider duties.

Risk classification

Jurisdiction	Level	Date	Note
Ecuador	Data protection	March 10, 2026	SPDP general rule on AI and the legitimate interest resolution (2025).

Obligations related to this use case

Document the balancing test when relying on legitimate interest

SPDP Res. 2025-0041-RRes. SPDP-SPD-2025-0041-RIn force

Applies from November 7, 2025

When it relates: Organizations that process data with AI on the basis of legitimate interest, for example to train models, prevent fraud or personalize marketing.
What the rule provides: Apply the Superintendency's balancing methodology and document why the company's interest does not override people's rights.
Typical evidence: Signed legitimate interest analysis per processing activity
Related base documents: Legitimate Interest Assessment for AI
Supporting documents: AI Annex to the Record of Processing Activities
Verification: Verified in the official source on November 4, 2026Checked against the text published by the SPDP: art. 2 (mandatory for anyone relying on legitimate interest; private sector only) and annex with the methodology. In force since signature on Nov 7, 2025.

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