PRIVACY NOTICE
Pareja Ltd is the controller responsible for personal information used through this investment-memo website at pareja.co.uk and its alternative domains. For privacy questions or requests, contact dan@alldis.associates. This notice covers the memo website and related enquiries; it does not describe a future online shop or mailing list.
INFORMATION WE USE
When you visit, our hosting provider Vercel processes connection and security information, including your IP address, request time, requested address, browser and device details, and access or error records, to deliver and protect the site. This information comes from your browser and its requests.
If you email or call us, we receive the contact details and information you choose to provide, together with the resulting correspondence. Providing enquiry information is voluntary, but without sufficient contact details we may be unable to respond. Please avoid sending sensitive personal information unless we have agreed a suitable way to receive it.
ANALYTICS
This site does not use visitor analytics, advertising trackers or marketing cookies. Vercel still processes the hosting and security information described in this notice to deliver and protect the site.
COOKIES AND PASSWORD ACCESS
The essential first-party cookie pareja_memo_session authorises access to encrypted memo files for up to 24 hours. It is Secure, HttpOnly and SameSite=Strict. It is necessary to provide the protected memo you request; blocking it prevents access. The password is sent over HTTPS for server verification and used in your browser to decrypt the memo. We do not save the entered password in browser storage. Reloading requires entering it again.
The site uses only the essential access cookie described above. No analytics consent or preference cookie is required. Any preference cookie left from the previous version is removed when you next visit.
WHY WE USE INFORMATION
For site delivery, access control, investigating faults and preventing misuse, we rely on our legitimate interests in keeping the memo available and protecting confidential material. For enquiries, we rely on our legitimate interests in answering questions and managing business communications. Where processing is necessary to comply with a specific legal duty, our basis is legal obligation. We limit use to what is needed for these purposes.
WHO RECEIVES INFORMATION
Vercel and its infrastructure subprocessors provide hosting, security and access controls. Our email and communications providers process messages you send us. Authorised Pareja personnel may access information where needed for their work. Professional advisers, regulators or public authorities may receive relevant information where necessary for legal advice, legal claims or a legal obligation. We do not sell visitor data or share it for targeted advertising.
INTERNATIONAL PROCESSING
Vercel is based in the United States and uses international infrastructure and subprocessors, so information may be processed outside the UK. Vercel’s Data Processing Addendum sets out contractual safeguards, including the European Commission’s Standard Contractual Clauses and the UK transfer addendum for relevant restricted transfers. Its subprocessor list provides information about processing locations and suppliers. Contact us for a copy or explanation of safeguards relevant to your information.
HOW LONG INFORMATION IS KEPT
The access cookie expires after 24 hours. We no longer collect visitor analytics. Any aggregate statistics previously collected remain subject to Vercel’s existing retention arrangements; removing analytics does not itself delete historical reports.
Hosting and security records are retained under Vercel’s applicable service arrangements for operating, protecting and troubleshooting the service. Any incident records we keep are retained while needed to investigate or resolve the incident, meet legal obligations or establish or defend a claim. We keep enquiry correspondence while the enquiry or resulting business relationship is active, and afterwards only where needed for an outstanding issue, applicable record-keeping duty or legal claim. Retention depends on the nature of the record, the unresolved matter and any applicable legal period; records no longer needed are deleted.
YOUR RIGHT TO OBJECT
You can object to processing based on legitimate interests for reasons relating to your particular situation. Contact dan@alldis.associates.
YOUR OTHER RIGHTS AND COMPLAINTS
Depending on the circumstances, you may request access to your personal information, correction, deletion, restriction of its use, or a portable copy where the legal conditions apply. Email dan@alldis.associates to exercise these rights. We may need proportionate information to verify your identity. Requests are normally free and answered within one month; if a lawful extension or exception applies, we will explain it.
Aggregate analytics may not be linked to an identifiable person, so we may be unable to locate a particular visitor’s records. We will not collect additional identifying information solely to identify someone within those statistics.
You can complain to the Information Commissioner’s Office (telephone 0303 123 1113), or your local supervisory authority where applicable. You can contact us first, but do not have to do so. We do not use this site’s data for automated decisions producing legal or similarly significant effects.
CHANGES TO THIS NOTICE
We will update this notice when our practices change. The date above shows the latest revision.