Privacy statement

Kaminada and ARM Abogados attach great importance to the protection of your personal data and strive for full transparency on how this data is processed, in accordance with Regulation (EU) 2016/679 (AVG/GDPR), the Spanish Organic Law 3/2018 (LOPDGDD), the Dutch AVG and the Portuguese Law No 58/2019.

This privacy statement explains how we collect, use, share and secure personal data when you use our services or visit our website.

 

Controller

Depending on your relationship with us and your location is the controller:

• Kaminada B.V. (Netherlands)
• Kaminada Fiscal y Contable S.L. (Spain)
• Kaminada Gestão e Fiscalidade Unipessoal LDA (Portugal)
• ARM & Asociados Abogados Y Asesores S.L. (Spain)
• ARM Advocaten C.V. (Netherlands)

These entities, collectively referred to as "Kaminada" and "ARM Abogados", determine the purposes and means of processing your personal data.

 

Categories of personal data

Depending on the service we provide, we may process the following categories of data:

• Identification data: name, date of birth, gender, company name, address
• Contact details: e-mail address, phone number
• Financial data: bank account number, payment information
• Tax and legal identification data: BSN, tax identification number, national ID
• Other data you provide voluntarily in the context of the service

Special categories of personal data process only if justified under Article 9(2) AVG, such as:

• Legal obligation (e.g. tax return, personnel administration)
• Necessity for performance of a contract (e.g. incorporation of a company, legal aid)
• Your express consent (if no other legal basis applies)
• Legal proceedings
• Legitimate interests (e.g. fraud prevention, identity verification), provided your fundamental rights are not violated

 

Purposes and legal bases of processing

Your personal data will only be processed where there is a valid legal basis for doing so, and only for specific purposes, including:

• The execution of an agreement or preparatory measures
• Complying with legal obligations (e.g. tax and anti-money laundering legislation)
• Represent legitimate interests (e.g. system security, fraud prevention)
• Your explicit consent, if required

We do not use automated decision-making or profiling with legal or similar consequences without human intervention.

 

Retention periods

Your personal data will not be kept longer than necessary for the purposes for which it was collected, including:

• The duration of the service agreement
• Comply with legal retention periods (e.g. tax records)
• For marketing purposes: as long as consent has not been withdrawn

At the end of the retention period, the data will be securely deleted or anonymised.

 

Data sharing

We do not sell your data. Your personal data may be shared with:

• Qualified employees of Kaminada and ARM Abogados
• Subcontractors or third parties required for our services (e.g. notaries, registries)
• Government agencies if required by law (e.g. tax authorities, court)
• Processors (such as IT service providers) under strict confidentiality obligations

In all cases, we ensure compliance with applicable privacy laws and appropriate protective measures.

 

International data transfers

We do not transfer your data outside the European Economic Area (EEA) unless this is necessary for the performance of our services. If a transfer takes place, it will be in accordance with Chapter V of the AVG, including Standard Contractual Clauses or on the basis of an adequacy decision.

 

Your rights

You have the following rights, subject to legal conditions:

• Right of access - you may know what data we hold about you
• Right to rectification - correct inaccurate or incomplete data
• Right to erasure - having data erased (where permitted)
• Right to restriction - having processing restricted in certain situations
• Right to portability - receive data in transferable format
• Right to object - object to processing on legitimate interest grounds
• Right to withdraw consent - if the processing is based on it

To exercise your rights, please submit a request at info@kaminada.nl, accompanied by a copy of your proof of identity (make sensitive data such as photo, MRZ, document number and BSN illegible). We will respond within one month.

 

Security measures

We take appropriate technical and organisational security measures to protect your personal data from unauthorised access, modification, disclosure or destruction. These include encryption, access control and secure data storage.

 

Complaints

If you believe that your data is being processed incorrectly or that your rights have been violated, you can complain to your national regulator:

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

Netherlands
Personal Data Authority (AP)
www.autoriteitpersoonsgegevens.nl

Portugal
Comissão Nacional de Proteção de Dados (CNPD)
www.cnpd.pt

For questions or comments on this statement, please contact us at info@kaminada.nl