Stelliumestates.com – Privacy Notice
Note: Stellium is currently operating in its pre-incorporation stage. This document reflects the company’s intended data protection and service principles. Legal entity details will be updated upon registration.
1. Overview
Stellium Estates (hereinafter, “Stellium” or “the Company”) values privacy and transparency. This Privacy Notice explains how we collect, use, and protect personal data of clients, partners, and website visitors in compliance with the General Data Protection Regulation (EU 2016/679) and Spanish LOPDGDD.
2. Controller Details
Data Controller: Stellium Estates (pre-incorporation stage).
Contact: privacy@stelliumestates.com
3. Purpose of Processing
Stellium may collect and process personal information provided through secure channels during private communications related to our advisory services
To manage client relationships, contracts, and property search engagements.
To comply with legal obligations (AML/KYC, tax).
To maintain communication and provide personalized service.
To manage referral and partnership programs.
4. Legal Basis
Processing relies on:
Contractual necessity
Legal obligation
Consent
Legitimate interest (communication, security)
5. Categories of Data
Identification data, contact details, property preferences, payment and compliance documentation, and communication records.
6. Recipients
Data may be shared only with:
Lawyers, notaries, and banks involved in transactions – only after explicit consent of the client.
Service providers who vetted under Stellium’s standards verification program as required for execution of agreements between the Stellium and its clients – only after explicit consent of the client.
Public authorities when legally required
7. International Transfers
If data is transferred outside the EEA, Stellium applies Standard Contractual Clauses ensuring equivalent protection.
8. Data Retention
Stellium retains personal data only for the time strictly necessary to fulfill the purposes for which it was collected and to comply with legal obligations.
We retain contact information for the time necessary to manage your inquiry and any subsequent relationship. If no further communication occurs, your data will be deleted within two years.
The main retention periods are as follows:
Client contractual data: retained for up to six (6) years after the end of the relationship, in accordance with commercial and tax law.
Identification and AML/KYC documentation: retained for up to five (5) to ten (10) years, as required by Ley 10/2010 de Prevención del Blanqueo de Capitales.
Accounting and tax records: retained for five (5) years under Spanish tax regulations.
Marketing or contact form data: for the time necessary to manage the inquiry and any subsequent relationship. If no further communication occurs, data will be deleted within two years. or until the data subject withdraws consent..
Lifestyle or preference data: retained until end of execution of a contract with Stellium or end of the advisory engagement.
Referral and partnership records: retained for three (3) years, limited to consented business communications.
After these periods expire, the data will be securely deleted or anonymized in accordance with Stellium’s internal GDPR & Data Protection Policy (available upon request).
9. Rights of Data Subjects
Individuals have the right to access, rectify, delete, restrict, or object to data use, and to data portability. Requests should be sent to privacy@stelliumestates.com
If unsatisfied, individuals may file a complaint with the Agencia Española de Protección de Datos (AEPD).
10. Security Measures
Stellium applies strict technical and organizational measures, including:
Encrypted storage and communication.
Two-factor authentication.
Controlled access.
Secure deletion and anonymization.
11. Updates
This Privacy Notice is reviewed annually and published on Stellium’s official channels.
Last updated: November 2025
Approved by: Isaac Shahar, Founder
To manage client relationships, contracts, and property search engagements.
To comply with legal obligations (AML/KYC, tax).
To maintain communication and provide personalized service.
To manage referral and partnership programs.
Contractual necessity
Legal obligation
Consent
Legitimate interest (communication, security)
Lawyers, notaries, and banks involved in transactions – only after explicit consent of the client.
Service providers who vetted under Stellium’s standards verification program as required for execution of agreements between the Stellium and its clients – only after explicit consent of the client.
Public authorities when legally required
Client contractual data: retained for up to six (6) years after the end of the relationship, in accordance with commercial and tax law.
Identification and AML/KYC documentation: retained for up to five (5) to ten (10) years, as required by Ley 10/2010 de Prevención del Blanqueo de Capitales.
Accounting and tax records: retained for five (5) years under Spanish tax regulations.
Marketing or contact form data: for the time necessary to manage the inquiry and any subsequent relationship. If no further communication occurs, data will be deleted within two years. or until the data subject withdraws consent..
Lifestyle or preference data: retained until end of execution of a contract with Stellium or end of the advisory engagement.
Referral and partnership records: retained for three (3) years, limited to consented business communications.
Encrypted storage and communication.
Two-factor authentication.
Controlled access.
Secure deletion and anonymization.