Privacy Policy

Controller

Mauro Keller Sarmiento (KS Advisory Corp)

Address

[Address of the professional establishment]

Privacy contact

mkellersarmiento@kelsarpartners.com

KS Advisory has not appointed a Data Protection Officer. Any question about this policy or about your data can be sent to the privacy contact above.

• Correspondence. When you write to us: your name, email address and the content of your message, any documents you choose to share, and the calls and meetings that follow.
• Technical data. When you visit the Site, our hosting provider records the IP address, browser type, pages requested and time of access in its server logs, for security and to deliver the pages.
• Engagement data. If you become a client or a counterparty in a transaction we advise on, the professional and identification data needed to perform the engagement and to comply with our legal obligations.

The Site does not use cookies, analytics or advertising technologies. See our Cookies statement.

• To answer your enquiry and assess a potential engagement: steps taken at your request prior to entering into a contract (art. 6.1.b GDPR) and our legitimate interest in responding to people who contact us (art. 6.1.f).
• To provide advisory services under an engagement: performance of a contract (art. 6.1.b).
• To comply with legal obligations (art. 6.1.c), including, where applicable, anti-money-laundering and counter-terrorist-financing rules such as Spanish Law 10/2010, which may require us to identify clients and keep records of the transactions we advise on.
• To keep the Site secure and operational: our legitimate interest (art. 6.1.f).
• To keep in touch professionally with existing contacts about matters relevant to them: our legitimate interest (art. 6.1.f). We do not send newsletters or mass marketing. Where consent is required for commercial communications we will ask for it first, and you can object at any time.

We do not sell personal data. It is shared only with:

• Service providers acting on our instructions as processors: Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, United States (website hosting) and Microsoft 365 (Microsoft Ireland Operations Limited), which hosts our mailbox.
• Professional advisers (lawyers, auditors, tax advisers) bound by professional secrecy, where needed for an engagement.
• Counterparties and their advisers in a transaction, only within the scope of the mandate you have given us.
• Public authorities where the law requires it.

Our hosting provider is established in the United States. Transfers to it are covered by its data processing agreement, which incorporates the Standard Contractual Clauses approved by the European Commission. Because our practice is cross-border, data may also be shared with counterparties outside the European Economic Area in the course of a transaction; this happens only within the scope of your mandate and with appropriate safeguards.

• Enquiries that do not lead to an engagement: up to twelve months after our last exchange.
• Engagement records: for the duration of the engagement and thereafter for the periods required by law (in Spain, generally six years for commercial documentation and ten years for anti-money-laundering records) or for as long as claims could be brought.
• Server logs: for a limited period, for security purposes only.

You may ask us to access, rectify or erase your data, to restrict or object to its processing, to receive it in a portable format and, where processing is based on consent, to withdraw that consent at any time without affecting prior processing. Write to mkellersarmiento@kelsarpartners.com; we may ask you to confirm your identity.

If you believe your rights have been infringed you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) or with the supervisory authority of the EU member state where you live or work.

We apply technical and organisational measures appropriate to the risk, including encrypted connections (HTTPS), access controls and confidentiality obligations for everyone who handles data on our behalf.

We may update this policy to reflect changes in our practice or in the law. The date at the top indicates the current version.