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Privacy Policy

https://baleario.com/

Last Updated: 1 January 2026

1. Data Controller

In accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD), the data controller is:

Chad Harwood-Jones
Trading as Baleario
NIE: Y4531092Z
Margalida Caimari 24
07005 Palma
Balearic Islands
Spain
Email: hola@baleario.com
Telephone: +34 871 510 055

2. Categories of Personal Data Collected

We may collect and process the following categories of personal data:

  • Identification data (name, NIE, passport, tax ID)
  • Contact details (email, telephone, address)
  • Financial and banking information
  • Tax and accounting information
  • Employment and payroll data
  • Property ownership details
  • Mortgage-related financial documentation
  • Communications and correspondence

We do not intentionally collect special category data unless required for tax compliance purposes.

3. Purposes of Processing

Personal data is processed for:

  • Provision of accounting and tax services
  • Preparation and submission of tax filings
  • Payroll processing and compliance
  • Mortgage introduction and coordination
  • Compliance with legal and regulatory obligations
  • Client communication and administration
  • Prevention of fraud and financial crime

4. Legal Basis for Processing

Processing is carried out under one or more of the following legal bases:

  • Performance of a contract (Article 6(1)(b) GDPR)
  • Compliance with legal obligations (Article 6(1)(c) GDPR)
  • Legitimate interests (Article 6(1)(f) GDPR)
  • Consent where required (Article 6(1)(a) GDPR)

5. Data Sharing

Personal data may be shared with:

  • Spanish Tax Authorities (Agencia Tributaria)
  • Social Security authorities
  • Accredited mortgage brokers (including Russell Clements, Bank of Spain registration D675)
  • Accounting software providers (e.g. bookkeeping platforms)
  • Payment processors
  • Professional advisors where required
  • IT service providers

Data is only shared where necessary for service delivery or legal compliance.

6. International Transfers

Where personal data is transferred outside the European Economic Area (EEA), appropriate safeguards are implemented, including:

  • Standard Contractual Clauses approved by the European Commission
  • Transfers to jurisdictions recognised as providing adequate protection

7. Data Retention

Personal data is retained:

  • For the duration of the client relationship
  • For statutory limitation periods under Spanish tax law (typically 4–10 years depending on the obligation)
  • For longer periods where required for legal defence

8. Data Subject Rights

Individuals have the right to:

  • Access their personal data
  • Request rectification
  • Request erasure
  • Restrict processing
  • Object to processing
  • Request data portability

Requests may be made to hola@baleario.com.

Individuals also have the right to lodge a complaint with:

Agencia Española de Protección de Datos (AEPD)
www.aepd.es

9. Security Measures

We implement appropriate technical and organisational measures to protect personal data, including secure systems, restricted access, and data minimisation practices.

10. Mandatory Data

Where personal data is required to fulfil contractual or legal obligations, failure to provide such data may prevent us from delivering services.

11. Automated Decision-Making

We do not carry out automated decision-making or profiling that produces legal or similarly significant effects.

12. Changes to This Policy

This Privacy Policy may be updated periodically. The most recent version will always be available on our website.