Privacy Notice

1. Data Controller

The controller of your personal data is Complitron, reachable at office@complitron.com. Full controller identification details are provided in engagement agreements and invoices, and are available on request.

2. What Data We Collect

• Inquiry & contact data - name, email address, company, role and the content of your message when you contact us by email, via the contact form or via LinkedIn.
• Engagement data - identification and billing details, and the documents and information you provide so we can perform the agreed services (which may include client due-diligence data required by anti-money-laundering law).
• Technical data - basic server logs (IP address, browser type, access times) generated when you visit the website.

3. Purposes and Legal Bases

• Responding to inquiries and preparing quotes - legitimate interest (Art. 6(1)(f) GDPR) or pre-contractual steps (Art. 6(1)(b)).
• Performing engagements - contract performance (Art. 6(1)(b)).
• Invoicing, accounting and record-keeping - legal obligation (Art. 6(1)(c)).
• Client due diligence / AML compliance - legal obligation (Art. 6(1)(c)).
• Website security and operation - legitimate interest (Art. 6(1)(f)).

4. Who We Share Data With

We share personal data only where necessary: with IT/hosting and email providers operating under data-processing agreements; with professional advisers (accountants) under confidentiality duties; and with authorities where the law requires it. We do not sell personal data.

5. International Transfers

Where a service provider processes data outside the EU/EEA, transfers are made only with appropriate safeguards, such as adequacy decisions or Standard Contractual Clauses.

6. Retention

Inquiry data is kept for up to 24 months if no engagement follows. Engagement, invoicing and AML-related records are retained for the periods required by applicable law (typically 5-10 years), after which they are securely deleted.

7. Your Rights

You have the right to request access to, rectification or erasure of your personal data; restriction of or objection to processing; data portability; and to withdraw consent where processing is based on consent. To exercise any right, email office@complitron.com. You also have the right to lodge a complaint with your local data protection authority.

8. Cookies

This website does not use marketing or analytics cookies. Only technically necessary storage may be used to operate the site. If this changes, this notice will be updated and, where required, your consent will be requested.

9. Security

We apply appropriate technical and organisational measures - access controls, encryption in transit and professional secrecy procedures - to protect personal data against unauthorised access, loss or disclosure.

10. Changes to This Notice

We may update this notice from time to time. The current version is always published on this page.

11. Contact

Privacy questions and rights requests: office@complitron.com.