1. Who we are
In this privacy policy we explain what we do with your personal data when you use Pasivoo via the website pasivoo.com (hereinafter, "the Site").
The data controller is:
- Legal name: EXOLUTIONS CONSULTING LLC
- Registered address: 1309 Coffeen Avenue, STE 1200, Sheridan, Wyoming 82801, EE.UU.
- Tax ID: EIN 36-5112012
- Contact email for data protection: info@pasivoo.com
2. What data we collect
Only what you give us voluntarily, usually through the contact or sign-up form:
- Identification data: name, email and phone.
- Basic financial data: the indicative amount you would consider investing (it's not a charge, just a reference to calculate an estimate).
- Browsing data: IP address, device type, browser, pages visited and time spent, via cookies and analytics tools. See Cookies Policy.
3. What we use your data for
- To show you a personalised estimate on the Site.
- To contact you by email, WhatsApp or phone about the service you've requested.
- To send you commercial information related to Pasivoo (only if you consent).
- To comply with our legal obligations (tax, accounting, commercial).
- To improve the Site and our services through aggregated analytics.
4. Legal basis for processing
- Your consent when filling in the form or accepting cookies (Article 6(1)(a) GDPR).
- Performance of a contract or pre-contractual measures at your request (Article 6(1)(b) GDPR).
- Legitimate interest in improving our service and preventing fraud (Article 6(1)(f) GDPR).
- Compliance with applicable legal obligations (Article 6(1)(c) GDPR).
5. Who we share your data with
Only with service providers we need in order to operate, all under data processor agreements compliant with GDPR:
- Hosting: Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Alemania).
- Email marketing and CRM: providers such as HighLevel and Resend to manage communications.
- Analytics: Google Analytics and Meta Pixel (aggregated/anonymised data, see Cookies).
- Messaging: Telegram for support and community (optional).
We don't sell your data to third parties. Some providers may be located outside the European Economic Area (US and similar); in that case they use Standard Contractual Clauses approved by the European Commission.
6. How long we keep your data
- Contact form data: up to 2 years from your last contact, unless you ask for deletion sooner.
- Contractual data (invoicing, contracts): the legally required period (at least 6 years per tax and commercial rules).
- Browsing data: maximum 14 months.
7. Your rights
You can exercise at any time your rights of access, rectification, deletion, objection, restriction, portability and not to be subject to automated decisions by writing to info@pasivoo.com.
If you consider we haven't handled your request properly, you have the right to lodge a complaint with your country's data protection authority. For Spain it's the AEPD (www.aepd.es). For other EU/EEA countries see edpb.europa.eu.
8. Security
We apply reasonable technical and organisational measures to protect your data (HTTPS encryption, access controls, backups, staff training). No system is 100% invulnerable, but we do everything possible to keep your data safe.
9. Minors
Pasivoo is not aimed at minors under 18. We don't knowingly collect data from minors. If you believe a minor has shared data with us, please write and we'll delete it.
10. Changes to this policy
We may update this policy when the law or our services change. The current version is always published here, with the last updated date at the top of the document.