Privacy policy

Who is responsible for your data

The data controller is Lladó & Franquesa Global Services LLC, of Urb. Alturas de San Patricio, Calle 1 #5, Guaynabo, PR 00968, Puerto Rico, USA.

For anything relating to your personal data, including the exercise of the rights described below, write to bjorn@lladofranquesa.com or pere@lladofranquesa.com. Both addresses reach a founding partner directly; we have not appointed a data protection officer, as the scale of our processing does not require one.

What we collect

The contact form is the only place on this website where we collect personal data. It asks for your name, your email address, your message and, optionally, your telephone number. We also record which language version of the site you were using and, if you opened the form from a particular property, a reference to that property. Where you reached us from an advertisement or a campaign link, we also record the campaign parameters that link carried.

We ask for nothing else and we want nothing else. Please do not include bank details, identification documents, health information or any other sensitive category in your message: a first enquiry never needs them.

Browsing the rest of the site collects nothing. We do not use tracking cookies, advertising pixels or profiling of any kind, and your browser makes no request to any third party while you read these pages. The Cookie policy sets this out in detail.

Why we use it, and on what legal basis

To read and answer your enquiry. The legal basis is Article 6(1)(b) of the GDPR: steps taken at your request before entering into a contract. Without your email address we cannot reply, which is why it is the one field, besides your name and your message, that we require.

To follow up on opportunities that match the interest you expressed, where an enquiry does not conclude on first contact. The legal basis is our legitimate interest in developing the relationship you began, under Article 6(1)(f). You can object to this at any time, and we will stop.

To keep the site working and free of abuse. The contact form counts recent submissions in order to detect automated traffic, which is part of the same legitimate interest.

We do not send newsletters or mass commercial mailings, and we will not add you to any list on the strength of an enquiry.

Who else handles it

Three providers process personal data on our behalf, each under a data processing agreement that forbids them from using it for their own purposes: Vercel Inc. (hosting of the website, USA), Supabase Inc. (the database in which enquiries are stored, USA) and Resend (delivery of the email that alerts us to a new enquiry, USA).

We do not sell personal data, we do not trade it and we do not disclose it to anyone else, except where a law or a competent authority obliges us to.

International transfers

Our company is established in Puerto Rico and our three providers are established in the United States, so any data you send us is stored and processed there.

Where you write to us from the European Economic Area or the United Kingdom, these transfers are covered by the standard contractual clauses adopted by the European Commission, which our providers incorporate into their data processing agreements, together with the technical measures described below.

How long we keep it

Enquiries are kept for three years from our last contact with you, and are deleted after that. Three years is the working life of an investment conversation: someone who wrote to us two years ago is still a live contact, and someone who wrote five years ago is not.

If an enquiry leads to an actual transaction, the documentation associated with it is kept for as long as the commercial and tax rules applicable to that transaction require. You can ask us to delete your data sooner at any time.

Your rights

You have the right to obtain a copy of the data we hold about you, to have it corrected if it is wrong, to have it deleted, to have its processing restricted, to receive it in a portable format and to object to processing based on our legitimate interest.

To exercise any of them, write to bjorn@lladofranquesa.com or pere@lladofranquesa.com. We reply within one month and we do not charge for it. We may ask you to confirm your identity, but only where we genuinely cannot otherwise tell that the request is yours.

If you believe we have handled your data badly, you can complain to your national supervisory authority. In Spain that is the Agencia Española de Protección de Datos (www.aepd.es); elsewhere in the European Economic Area, the equivalent authority in your place of residence.

How your data is protected

Everything you submit travels over an encrypted connection. Enquiries are stored in a table that is not publicly readable and has no public write access: the only route in is the server code of this website, and the only route out is the partners’ password-protected panel.

No security is absolute, and we would rather say so than pretend otherwise. If a breach ever affected your data and put your rights at risk, we would tell you and the relevant authority within the period the law allows.

Automated decisions, and children

We take no automated decisions about you and we do not build profiles. Your enquiry is read by a person.

This website is directed at professional and private investors and is not intended for children under 18. We do not knowingly collect their data; if you believe a child has sent us something, tell us and we will delete it.

Changes to this policy

If this policy changes, the new version is published on this page with a new date at the top. Substantial changes affecting data we already hold will be notified by email to the people concerned.