Política de Privacidad
We (also referred to as "Our" or "Us") are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store information you provide through the https://palmo-sulteva.com website (the Palmo Sulteva).
The following principles apply:
We want you to have all the information you need to make informed decisions about how your Personal Data is used and processed. We use various methods to provide you with relevant information and, where specific details are required, we will share them with you in a timely manner. We are happy to answer any questions you may have about the limitations established by law.
1. ¿El alcance?
This policy describes the personal data Palmo Sulteva collects about individuals, and how it is processed, shared with third parties, and protected.
This policy applies to information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified directly or through a combination of additional information we hold or have access to.
"Processing" refers to any activity involving the use or collection of personal data, including its management, structuring, and storage.
Our services are intended for a general audience and are not designed for use by individuals under 18 years of age. We do not knowingly seek or collect information from persons under 18, nor do we permit them to use our services. If we become aware that we hold such information, we will delete it promptly.
2. What personal data do we hold about you?
When you access our services, service channels, or website, we collect personal data. In some cases, we may ask you to provide it directly. In others, we collect it by analyzing how you use our services or channels, or by receiving it from our third-party partners.
3. There is no requirement to disclose personal information to the company, nor any consequences for choosing not to do so.
You are not required to provide us with any personal data. In certain circumstances, withholding personal data may prevent us from delivering the Services or prevent you from accessing the website.
4. What types of personal data may we collect? When you visit our website, we will collect the following personal data from you:
This includes your online activity log, traffic data (such as IP address, access date, access time, and browser type), language settings, software error logs, and device information. This data is non-personal and cannot be used to identify you.
Personal data you provide to us: any personal data you voluntarily share when connecting to a third-party online trading platform through us.
Personal data you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.
5. Legal Basis and Grounds for Personal Data Processing
Sus Datos Personales son procesados por la Compañía para los fines descritos en esta sección, conforme a la base legal aplicable.
Sin una base legal, la Compañía no puede utilizar sus Datos Personales. Las bases legales sobre las cuales la Compañía puede procesar sus Datos Personales son las siguientes:
- You have consented to the processing of your Personal Data for one or more specific purposes. This applies when you submit personal information through the Website for transfer to a third-party trading platform.
- The Company or a third party may process data to pursue a legitimate interest — for example, to improve Our Services or to defend legal claims.
- Processing is required to comply with a legal obligation.
Reach out by email for details on the processing used to safeguard legitimate interests.
Below is a list of the purposes and legal bases under which we may use the personal data you provide.
Alcance, Base Legal
1. At your request, we may share your personal data with third-party companies to facilitate access to digital trading.
You have given your consent for your Personal Data to be processed for one or more specified purposes.
2. To respond to your requests, questions, or concerns. Personal data is required to help resolve any questions you may have about the Services.
Processing is required to serve the legitimate interests of the Company or a third party.
3. Personal data is processed to fulfill legal, administrative, judicial, or regulatory obligations.
Processing is required to meet legal obligations.
4. We may use personal data to optimize our Services. This includes crash reports and functional error data collected in connection with the Services.
Processing is required to serve the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our Services
Processing is required to serve the legitimate interests of the Company or a third party.
6. To carry out and manage activities aligned with the requirements of Our Services — including back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing is required to serve the legitimate interests of the Company or a third party.
7. We use analytical techniques, including statistical methods, to support decision-making across a range of matters.
Processing is required when it serves the legitimate interests of the Company or a third party.
8.
Para proteger nuestros activos, derechos e intereses, así como los de terceros, hemos desarrollado HTML0 para establecer y defender reclamaciones legales.
Sus datos personales podrán ser procesados con el fin de proteger nuestros derechos, intereses y activos, o los de terceros, conforme a las leyes, regulaciones o acuerdos aplicables, así como a cualquier condición, término o política vigente.
Processing is required to serve the legitimate interests of the Company or a third party.
6. Sharing Personal Data with Third Parties
The Company may share Personal Data with third-party service providers, including hosting and storage providers that process IP address information, as well as vendors that analyze user experience.
You may also request that we share specific Personal Data with third-party trading platforms. In such cases, we will share the Personal Data you have provided to us with those platforms. Your Personal Data will then be subject to their respective privacy policies and may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to support the development and improvement of the products and services offered to clients.
Where necessary to protect the rights or assets of third parties, the Company is authorized to disclose Personal Data to regulatory, local, or other official authorities.
The Company may also share Personal Data with prospective investors or acquirers, lenders, or any other entity within the group in connection with a transaction — including the transfer or sale of assets belonging to the Company or any group entity — or as part of any merger, restructuring, consolidation, or insolvency proceeding involving the Company or any other business within the group.
7. Cookies and Third-Party Services
We may use third-party services, such as advertising providers and analytics companies, on our website. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and show you relevant products and services. Cookies are also used for statistical and analytics purposes.
Some cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a set period after your browser is closed. Persistent cookies help the website recognize you as a returning user and allow you to pick up where you left off.
Tipos de Cookies:
They may be used by us according to their purpose:
1. Essential cookies only
These cookies are necessary to provide the information, products, and services you've requested and to enable navigation across our website. They allow your device to download and transmit data, so you can browse the site, use its features, and return to pages you've previously visited.
Cookies collect personal data such as your username and the date of your last login to verify site access. They are deleted when you close your web browser (session cookies).
2. Cookies de funcionalidad
Cookies recognize you each time you visit our site and save your preferences and settings.
Cookies collect Personal Data — such as your username and the date of your last login — to confirm you are signed in to the site. They are deleted when you close your web browser (session cookies).
3. Cookies de rendimiento
We use cookies to collect statistical data on site performance and support ongoing improvements, including internal analytics.
Cookies store anonymous data not associated with any identifiable individual. Session cookies are deleted when the browser is closed. Other cookies remain valid indefinitely.
Cookies are blocked or disabled
To block or delete cookies, you'll need to adjust your browser settings. Below you'll find links to help you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some or all website features may not work as expected if this occurs.
ONLINE TRACKING NOTICE
This service does not currently support Do Not Track signals.
8. Retention of Your Personal Data
The Company will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, policies, or orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent to this, we will continue sharing your data for an additional 12 months.
We periodically review the Personal Data we hold to confirm it is no longer needed.
9. Transfers of Personal Data to a Third Country or International Organization
Su información personal puede ser transferida a otros países, incluyendo a terceros países distintos al de su residencia, o a organizaciones internacionales. La Compañía adopta todas las medidas necesarias para proteger los Datos Personales que usted proporciona y garantizar que los usuarios puedan ejercer sus derechos y acceder a recursos legales efectivos.
Estas protecciones están disponibles para todas las personas residentes en el EEE (Espacio Económico Europeo).
- Transferencia a un país tercero u organización internacional que la Comisión Europea ha determinado que ofrece un nivel de protección adecuado para los Datos Personales transferidos, de conformidad con el artículo 45(3) del Reglamento 2016/679 del Parlamento Europeo y del Consejo de 27 de abril de 2016 (el "GDPR").
- La transferencia se realiza en virtud de un acuerdo jurídicamente vinculante y ejecutable entre entidades o autoridades públicas, conforme al Artículo 46(2)(a).
- This transfer was carried out in accordance with the standard contractual clauses for data protection adopted by the EU Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
For details on the security measures used to protect your Personal Data when transferred to third countries or international organizations, contact us at: info@palmo-sulteva.com
10. Seguridad de Datos Personales
We have implemented appropriate technical and organizational measures to protect personal data, including safeguards against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that personal data will remain error-free at all times, nor can we be held liable for intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes personal data disclosed due to transmission errors, unauthorized third-party access, or other causes beyond our control.
Where required by legal or other obligations outside our control, we may be required to disclose personal data to third parties, such as public authorities. We have no control over the security measures applied by those third parties in such circumstances.
Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the security of personal data you transmit to us online.
11. Third-Party Hyperlinks
This website contains links to third-party sites and applications. These are not under our supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to actions taken through those sites or applications.
Before accessing or using any third-party site or application, review its privacy policy carefully. Exercise caution when deciding what personal data you share with them.
12. Changes to This Policy We may update this Policy from time to time. Any changes will be posted on this page, and where appropriate, we will notify you directly. We encourage you to review this Policy periodically to stay informed of any updates.
Before accessing any third-party websites or applications, review their privacy policies carefully. Do not share personal data with them until you have done so.
13. Your rights regarding your personal information
You have the right to request verification of the accuracy of your Personal Data being processed, to have inaccuracies corrected, and to have Personal Data deleted where it is no longer necessary. You may also restrict the scope of how your Personal Data is processed.
If you are an EEA resident, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, contact us at the email address listed below.
Access Rights
The Company may verify the accuracy of Personal Data being processed about you. Where confirmed, you may access your Personal Data.
The Company will provide one electronic copy of your Personal Data currently being processed. A reasonable fee may apply for additional copies. Data will be made available electronically upon request.
The right of access to Personal Data must not conflict with the rights and freedoms of third parties. Where a request would be prejudicial to the rights or freedoms of another person, the Company may refuse or limit its response accordingly.
Right to Rectification
The Company may rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be completed, taking into account the purposes of the processing.
Right to Erasure
This right applies where: (a) the Personal Data is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object, on grounds specific to your situation, to processing based on legitimate interests pursued by the Company or a third party; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation of the Company.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law; or (b) for the establishment, exercise, or defense of legal claims.
Restriction of Processing
If you question the accuracy of your Personal Data, you may request that the Company restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or where there is a significant public interest ground within the European Union or a Member State.
Right to Data Portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company.
You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. The right to data portability does not interfere with the rights or freedoms