1. Who is the controller of your personal data?
The controller is:
NRT: L-722584-Z
Registered office: Av. Tarragona, 113-135, AD500 Andorra la Vella, Principality of Andorra.
Telephone: +376 666 626.
Data Protection Officer
For any enquiry relating to this Privacy Policy, the processing of your personal data or the exercise of your rights, you may contact Abansa’s Data Protection Officer at dpo@setupinandorra.com.
2. What personal data may we process?
Depending on the relationship with the user and the channel used, Abansa may process the following categories of data:
- Identification and contact details, such as first name, surname, email address, telephone number or WhatsApp number;
- Information included in an enquiry or request, such as objectives, personal or professional circumstances, country of residence, business project or intended timetable;
- Professional, corporate, financial, tax, employment, asset-related or immigration and international mobility information that is necessary to assess or provide the requested service;
- Browsing and technical data, such as IP address, device identifiers, browser used, access logs and cookie preferences, where applicable;
- Data arising from a pre-contractual, contractual, professional or commercial relationship with clients, prospective clients, suppliers and collaborators.
Users should not provide particularly sensitive information or documentation through the contact form unless it is necessary for the initial enquiry. If Abansa requires additional information or documentation to assess or provide a service, it will specify the appropriate channel through which it should be sent.
3. For what purposes do we process your personal data?
Abansa may process personal data for the following purposes:
- To respond to, deal with and manage enquiries, requests for information and contact requests;
- To carry out an initial assessment of projects relating to a move of residence to Andorra, immigration and international mobility, the incorporation or management of companies and Abansa’s other professional services;
- To prepare proposals and quotations and take the pre-contractual steps requested by the data subject;
- To enter into, manage and provide the professional services engaged;
- To manage administrative, accounting, tax, commercial and professional relationships with clients, prospective clients, suppliers and collaborators;
- To comply with legal, regulatory, professional, tax and accounting obligations and, where applicable, anti-money laundering and counter-terrorist financing obligations;
- To ensure the security, availability, maintenance and proper operation of the Website, prevent fraudulent use and deal with possible incidents;
- To send information or marketing communications relating to Abansa’s services where there is a valid legal basis, allowing the recipient to object to receiving them or withdraw consent at any time;
- To handle requests to exercise rights, enquiries, complaints and potential legal liabilities.
4. What is the legal basis for processing your data?
Depending on the circumstances, the legal bases for processing personal data may be:
- Taking steps at the request of the data subject before entering into a contract;
- Performance of a contractual or professional relationship;
- Compliance with legal and regulatory obligations applicable to Abansa;
- The data subject’s consent, where required, for example for certain marketing communications or the installation of non-essential cookies;
- Abansa’s legitimate interests in managing its professional relationships, dealing with enquiries, protecting its systems, preventing fraudulent use and keeping clients informed about services connected with an existing professional relationship, provided that the data subject’s rights and interests do not take precedence.
Where processing is based on consent, the data subject may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.
5. Is it compulsory to provide the data?
Fields marked as mandatory are required in order to process the relevant enquiry or request. If the user does not provide this information, Abansa may be unable to deal with it properly.
The user confirms that the data provided is true, accurate and up to date and undertakes to notify Abansa of any relevant change.
6. How long do we retain the data?
Personal data will be retained for as long as necessary to deal with the enquiry, manage the pre-contractual, contractual or professional relationship and fulfil the purposes for which it was collected.
Once the relationship has ended, the data may be retained in a duly restricted form for the limitation periods applicable to potential liabilities and for the periods required by tax, accounting, commercial, professional, anti-money laundering or any other applicable legislation.
Where processing is based solely on consent, the data will be retained until consent is withdrawn, unless another legal basis justifies its continued retention.
Data processed for marketing purposes will be retained until the data subject objects to the processing or requests erasure, without prejudice to any legally required retention periods.
7. To whom may the data be disclosed?
Personal data may be processed by Abansa’s authorised staff and professionals.
It may also be disclosed or made available to the following recipients where necessary and where there is a valid legal basis:
- Public administrations, authorities, regulatory bodies, judicial bodies, notaries, public registers and other legally competent bodies;
- Financial institutions, insurers or other parties where their involvement is necessary to handle the requested matter;
- Lawyers, advisers, auditors, accountants, administrators or other professional collaborators whose involvement is necessary for the proper provision of the service;
- Suppliers acting as data processors, including providers of web hosting, maintenance, email, communications, storage, IT support, security, document management or customer relationship management services.
Suppliers that access personal data on Abansa’s behalf will be subject to the corresponding contractual data protection, security and confidentiality obligations.
Abansa will not sell personal data or disclose it to third parties for their own marketing purposes without a legal basis that permits this.
8. International data transfers
As a general rule, Abansa will seek to use providers located in Andorra or in countries that provide an adequate level of protection for personal data.
However, certain technology or communications providers may process data from other countries. Where an international data transfer takes place, Abansa will adopt the safeguards required by applicable Andorran legislation to ensure an adequate level of protection, including adequacy decisions, contractual clauses, binding corporate rules or other legally recognised mechanisms.
Where necessary, Abansa will also apply supplementary measures intended to protect the security and confidentiality of the data.
9. What are your rights?
Subject to the conditions set out in applicable legislation, the data subject may exercise the following rights:
- The right of access to their personal data;
- The right to rectification of inaccurate or incomplete data;
- The right to erasure of their personal data;
- The right to object to processing;
- The right to request restriction of processing;
- The right to data portability;
- The right not to be subject to decisions based solely on automated processing that produce legal effects or similarly significantly affect them;
- The right to withdraw consent at any time.
To exercise these rights, the data subject may send a request to dpo@setupinandorra.com or write to:
Av. Tarragona, 113-135
AD500 Andorra la Vella
Principality of Andorra
The request must identify the data subject, specify the right they wish to exercise and provide the information needed to process it. Abansa will request additional documentation only where necessary to verify the applicant’s identity.
The data subject also has the right to lodge a complaint with the Andorran Data Protection Agency (APDA) through the channels available at https://www.apda.ad/.
10. Security and confidentiality
Abansa will apply appropriate technical and organisational measures to protect personal data against loss, alteration, unauthorised access, disclosure or processing, taking into account the nature of the data, the risks involved and the state of the art.
Users should nevertheless be aware that no system connected to the internet can guarantee absolute security.
Staff and professionals involved in dealing with enquiries or providing services will be subject to the corresponding confidentiality obligations and, where applicable, professional secrecy.
11. Personal data relating to third parties
If a user provides personal data relating to third parties, the user confirms that they are entitled to do so and that those individuals have been properly informed about the disclosure and processing of their data.
Users should not provide third-party data that is not necessary to deal with the enquiry or provide the requested service.
13. Changes to this Privacy Policy
Abansa may update this Privacy Policy to reflect changes in legislation, guidance from the competent authorities, new processing activities or changes to its services.
The current version will be the version published on the Website and will state the date on which it was last updated.