Last updated: June 2025

1. Data Controller

The data controller for the processing of personal data on this website is:

If you have any questions regarding this policy or the way we handle your personal data, you may contact us at the above email address.

2. What Personal Data We Collect

We collect and process personal data only where necessary, and in accordance with applicable laws. The types of data we may process include:

• Identification data (e.g., name, company name, email address, phone number)

• Communication data (e.g., messages submitted via email or contact forms)

• Interaction data (e.g., link clicks in emails sent via GetResponse)

• Technical usage data (e.g., aggregated visit logs or error diagnostics from web hosting infrastructure)

We do not knowingly collect sensitive data or data of a personal nature unrelated to business or contractual matters.

3. Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract performance (Art. 6(1)(b) GDPR): to respond to communications related to signed contracts, claim positions, or settlement offers.

• Legitimate interest (Art. 6(1)(f) GDPR): to manage email campaigns, monitor website access for security purposes, or evaluate dossiers for due diligence.

• Legal obligation (Art. 6(1)(c) GDPR): where disclosure is required by EU or national law.

• Consent (Art. 6(1)(a) GDPR): where applicable, such as for optional tracking features or extended communication preferences.

4. Purpose of the Processing

We use personal data for the following purposes:

• Responding to inquiries submitted via email or contact forms

• Evaluating credit or contract positions for potential settlement

• Preparing and sharing dossiers in the context of litigation funding or claim assignment

• Managing and tracking email interactions via GetResponse (click-based only)

• Ensuring the technical security and operability of our website and services

• Fulfilling legal and regulatory obligations

5. Data Retention

We retain personal data only for as long as is strictly necessary to fulfill the purposes outlined above, or as required by law. For example:

• Inquiries and correspondence: typically retained for 12 months

• Contractual or legal documentation: retained for 5–10 years, depending on jurisdiction

6. Data Sharing and Transfers

We do not sell personal data for marketing or profiling purposes. However, in the course of our business activities, we may share limited personal data under controlled conditions with:

• Litigation funds or qualified investors: in connection with the due diligence or assignment of contract rights. Dossiers may include business contact details, contractual correspondence, and financial solvency information.

• Service providers, including:

  • GetResponse (for managing email campaigns and tracking interaction metrics such as link clicks)

  • ProtonMail (for secure email communication, using end-to-end encryption and zero-access infrastructure)

  • Hosting and IT providers involved in website and infrastructure support

• Legal advisors, accountants, or third-party consultants working under confidentiality obligations

• Judicial or regulatory authorities, when legally required

Where data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards (e.g., standard contractual clauses) are in place as required under Articles 44–49 GDPR.

7. Your Rights under the GDPR

Under applicable data protection laws, you have the right to:

• Access your personal data (Art. 15 GDPR)

• Correct inaccurate or incomplete data (Art. 16 GDPR)

• Request deletion of your data, where lawful (Art. 17 GDPR)

• Restrict processing under certain circumstances (Art. 18 GDPR)

• Receive your data in portable format (Art. 20 GDPR)

• Object to processing based on legitimate interests (Art. 21 GDPR)

• Lodge a complaint with your local Data Protection Authority (Art. 77 GDPR)

To exercise your rights, please contact info@110liquido.com.

8. Cookies and Email Tracking

Our website uses only strictly necessary cookies. We do not use advertising, profiling, or behavioral tracking cookies.

However, emails sent through our campaigns (via GetResponse) may include click-based tracking. This allows us to detect whether a recipient has interacted with a link in the email, and helps us prioritize further contact with interested users.

You may disable such tracking by choosing plain-text email viewing in your client or disabling remote content loading.

We do not track email opens, read times, or user behavior beyond basic link interactions.

9. Updates to This Policy

We may occasionally update this privacy policy to reflect legal requirements or changes in our processing activities. Any significant changes will be posted here. Please review this page periodically to stay informed.