1. Controller
The data controller is Asuncion Trade and Consulting LLC, registered business address 33 N Gould Street, Sheridan, WY 82801, United States. Privacy enquiries may be addressed to privacy@asunciontradeandconsulting.com.
2. What we collect
We collect personal data in three ways:
- Contact form submissions. Name, email address, country, optional company name, the reason for contact, and the contents of the message you submit.
- Engagement correspondence and records. When you engage us, we collect identification information necessary to comply with applicable anti-money-laundering and know-your-business requirements, contract correspondence, deliverables, and invoicing records.
- Analytics. Aggregated, privacy-friendly traffic measurements collected by our analytics provider (Plausible). These measurements do not use third-party cookies and do not allow us to identify individual visitors.
3. Why we collect it
- To respond to enquiries and provide the services you request from us.
- To perform contracts we enter into with clients.
- To comply with legal obligations, including anti-money-laundering, tax, and records-retention requirements.
- To operate, secure, and improve the Site.
4. Legal basis (GDPR)
For visitors in the European Economic Area and the United Kingdom, our processing relies on the following bases under Article 6 of the GDPR:
- Article 6(1)(b) - performance of a contract or pre-contractual measures (for engagement correspondence and contract delivery).
- Article 6(1)(c) - compliance with a legal obligation (for AML, tax, and records-retention purposes).
- Article 6(1)(f) - legitimate interest (for responding to enquiries, securing the Site, and aggregate analytics). Where we rely on legitimate interest, we have assessed that our interest does not override your fundamental rights.
5. Data sharing
We do not sell personal data. We share data only with the following categories of third parties, under written agreements that bind them to confidentiality and data-protection obligations:
- Hosting and infrastructure providers - Vercel Inc. (Site hosting); Google Workspace (email and document collaboration).
- Analytics - Plausible Analytics (EU-based, cookie-free traffic measurement).
- Professional advisors - our accountants, lawyers, and banking partners, where their work requires limited access to specific records.
- Authorities - where disclosure is required by applicable law, court order, or regulatory request.
6. International transfers
The Firm is established in the United States. Personal data of European visitors may therefore be transferred to and processed in the United States. Where applicable, we rely on the Standard Contractual Clauses approved by the European Commission for international transfers, and we have assessed the legal regime of the receiving country in line with applicable guidance.
7. Retention
- Contact form submissions where no engagement follows: deleted within 24 months.
- Engagement records: retained for the period required by applicable tax and AML law (typically 7 years from the end of the engagement), and then deleted.
- Analytics: aggregated indefinitely; no individual identifiers retained.
8. Your rights under GDPR
If you are located in the European Economic Area or the United Kingdom, you have the right to:
- Access the personal data we hold about you.
- Request rectification of inaccurate or incomplete data.
- Request erasure where applicable.
- Request restriction of processing, or object to processing based on legitimate interest.
- Receive your data in a portable format.
- Lodge a complaint with your national supervisory authority.
To exercise these rights, contact us at privacy@asunciontradeandconsulting.com.
9. Your rights under CCPA
If you are a California resident, you have the right to know the categories and specific pieces of personal information we hold about you, to request deletion subject to applicable exemptions, and to opt out of the sale of personal information. We do not sell personal information.
10. Cookies
The Site uses only strictly necessary first-party cookies. We do not use third-party tracking cookies. See our Cookie Policy for details.
11. Security
We apply reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. No system is perfectly secure; please use discretion when sending sensitive information by email.
12. Changes to this policy
We may update this Privacy Policy from time to time. The current version is always available on the Site and indicates the date of last update. Material changes affecting how we process existing data will be communicated to affected individuals where reasonably practicable.
13. Contact
Privacy enquiries: privacy@asunciontradeandconsulting.com. General contact: hello@asunciontradeandconsulting.com.