Privacy Policy
1. 1. Data Controller
Stella Maris Capital, Corp., incorporated and existing under the laws of República de Panamá, is the entity responsible for the processing of personal data collected through this website (https://www.stella-maris.xyz).
For any inquiry, request, or complaint related to the processing of your personal data, you may contact us through the following channels:
- Email: contact@stella-maris.xyz
- Postal address: Tower Financial Center, Piso 27, Calle 50, Ciudad de Panamá
We are committed to responding to all requests within a maximum period of thirty (30) business days from receipt.
2. 2. Information We Collect
When you use this website, we may collect the following categories of information, either automatically or as voluntarily provided by you:
Technical and device information:
- IP address (anonymized where possible)
- Web browser type and version
- Operating system and device type
- Screen resolution and language settings
- Unique session identifiers
Usage and browsing data:
- Pages visited, time spent, and navigation patterns
- Referring URL (originating website)
- Interactions with site elements (clicks, scrolls, form submissions)
- Data collected by Google Analytics 4 (GA4) and Cloudflare Web Analytics, including performance metrics and user flows
Voluntarily provided information:
- Data submitted through contact forms (name, email, phone, message)
- User preferences (language, visual theme, cookie consent)
- Any other information you choose to voluntarily provide to us
Cookies and tracking technologies:
We use essential, analytics, and preference cookies. For more information, please refer to our Cookie Policy.
3. 3. How We Use Information
The information collected is used for the following purposes:
- Service improvement: Analyzing usage patterns to optimize website performance, content, and user experience.
- Analytics and statistics: Generating aggregated and anonymized reports on traffic, user behavior, and usage trends through tools such as Google Analytics 4 and Cloudflare Web Analytics.
- Security and fraud prevention: Monitoring suspicious activity, preventing unauthorized access, DDoS attacks, and other security threats.
- Legal compliance: Fulfilling legal, regulatory, and contractual obligations applicable in República de Panamá and other relevant jurisdictions.
- Marketing communications: With your prior and express consent, sending commercial communications, newsletters, or promotional materials. You may withdraw your consent at any time.
- Artificial intelligence training: Anonymized and aggregated data may be used to train, improve, and validate artificial intelligence and machine learning models. Under no circumstances will identifiable personal data be used for this purpose without your express consent.
We will not use your personal data for purposes incompatible with those described above without first obtaining your consent or without a legal basis to justify such use.
4. 4. Legal Basis for Processing
The processing of your personal data is based on the following legal grounds, in accordance with the applicable legislation of República de Panamá and, where applicable, the Ley 81 de 2019:
Legitimate interest:
We process web analytics and security data based on our legitimate interest in maintaining a secure, functional, and optimized website. This interest has been assessed and balanced against the rights and freedoms of users, concluding that it does not override them. Analytics data is anonymized or aggregated to minimize the impact on privacy.
Consent:
For the sending of marketing communications, the installation of non-essential cookies, and any other processing that requires it, we request your prior, free, informed, and unambiguous consent. You have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent prior to its withdrawal.
Contractual necessity:
When you request a service through our website, we process the data necessary for the performance of a contract or the taking of pre-contractual measures at your request.
Legal obligation:
In certain cases, we are legally required to process and retain certain information to comply with fiscal, regulatory, judicial, or other applicable legal mandates.
5. 5. Data Sharing
Stella Maris Capital, Corp. does not sell, rent, or trade your personal data to third parties under any circumstances.
However, we may share information with the following categories of recipients, solely to the extent necessary for the purposes described in this policy:
- Cloudflare, Inc.: Hosting provider, content delivery network (CDN), web security, and performance analytics. Cloudflare processes technical data (IP address, HTTP headers) for the delivery and protection of the website. See Cloudflare's Privacy Policy.
- Google LLC: Web analytics services provider (Google Analytics 4). Collects anonymized usage and browsing data. See Google's Privacy Policy.
- Microsoft Corporation: Behavioral analytics provider (Microsoft Clarity): heatmaps and anonymized session recordings, with sensitive content masked by default. See Microsoft Privacy Statement.
- Payment processors: When payment services are offered, transaction data will be shared with the corresponding payment processor, who will act as an independent data controller.
- Legal authorities: When required by law, court order, governmental request, or applicable legal proceedings, we may disclose necessary information to competent authorities.
All service providers with access to personal data are subject to contractual confidentiality and security obligations that ensure an adequate level of protection.
7. 7. User Rights
In accordance with the Ley 81 de 2019 and applicable legislation in República de Panamá, you have the following rights with respect to your personal data:
- Right of access: Request confirmation as to whether your personal data is being processed and, if so, obtain a copy thereof together with information about the purposes of processing, categories of data, recipients, and retention periods.
- Right to rectification: Request the correction of inaccurate or incomplete personal data without undue delay.
- Right to erasure: Request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you withdraw your consent, or when the processing is unlawful. This right is subject to the legitimate retention of data that we are required to preserve by legal or contractual obligation, or for the defense of claims.
- Right to restriction: Request the limitation of processing of your data under certain circumstances, such as when you contest the accuracy of the data or object to processing.
- Right to portability: Receive your personal data in a structured, commonly used, and machine-readable format, and transmit it to another data controller where technically feasible.
- Right to object: Object to the processing of your personal data based on legitimate interest or for direct marketing purposes.
To exercise any of these rights, send a request to contact@stella-maris.xyz clearly indicating the right you wish to exercise and providing the necessary documentation to verify your identity. We are committed to responding within a period of thirty (30) business days.
If you believe that the processing of your data violates your rights, you have the right to lodge a complaint with the competent data protection authority in República de Panamá.
8. 8. Security
Stella Maris Capital, Corp. implements appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, accidental or unlawful destruction, and any other form of unauthorized processing.
Security measures include, but are not limited to:
- Encryption in transit: All communications between your browser and our website are protected using TLS 1.3 (Transport Layer Security), the most advanced encryption protocol available.
- Encryption at rest: Stored data is encrypted using industry-standard encryption algorithms.
- Access controls: Access to personal data is strictly limited to authorized personnel who require such information for the performance of their duties, through multi-factor authentication and the principle of least privilege.
- Regular audits: We conduct regular security assessments, vulnerability testing, and reviews of our data protection practices.
- Breach notification: In the event of a security breach affecting your personal data, we will notify the competent authorities and affected users within seventy-two (72) hours of discovery, in accordance with applicable legislation.
Despite our efforts, no method of electronic transmission or storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security.
9. 9. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless the law requires or permits a longer retention period. Specific retention periods are as follows:
- Web analytics data: Twenty-six (26) months from the date of collection. After this period, data is automatically deleted or irreversibly anonymized.
- Contact form data: Twelve (12) months from the date of submission, unless the communication results in a contractual relationship that justifies a longer period.
- User account data: For the entire duration of the account plus five (5) additional years from its cancellation, to comply with legal, fiscal, and claims defense obligations.
- Aggregated and anonymized data: Indefinitely, as such data does not allow the identification of natural persons and is used exclusively for statistical and service improvement purposes.
Once the indicated retention periods have elapsed, personal data will be securely deleted or irreversibly anonymized.
10. 10. Children
This website is not directed at children under thirteen (13) years of age. Stella Maris Capital, Corp. does not knowingly or intentionally collect personal data from children under thirteen (13) years of age.
If we become aware that we have collected personal data from a child under thirteen (13) years of age without verifiable parental or legal guardian consent, we will take reasonable steps to delete such information from our systems as soon as reasonably possible.
If you are a parent or legal guardian and become aware that a child under your care has provided personal data through this website, please contact us at contact@stella-maris.xyz so that we may take the necessary actions.
11. 11. International Transfers
Given that Stella Maris Capital, Corp. uses services from global providers, your personal data may be transferred to and processed in countries other than República de Panamá, including countries where data protection laws may differ from those applicable in your jurisdiction of residence.
In particular, data may be processed by Cloudflare's global infrastructure, which operates data centers in multiple countries to ensure website performance and availability. Similarly, Google Analytics processes data on its servers located in various jurisdictions.
When international transfers of personal data are carried out, we implement appropriate safeguards to ensure a level of protection equivalent to that required by the legislation of República de Panamá, including:
- Standard contractual clauses approved by competent data protection authorities
- Adequacy decisions, where they exist and are applicable
- Certifications and codes of conduct recognized by competent authorities
For more information about the specific safeguards applicable to international transfers of your data, you may contact us at contact@stella-maris.xyz.
12. 12. Changes to This Policy
Stella Maris Capital, Corp. reserves the right to modify, update, or revise this Privacy Policy at any time and without prior notice, at its sole discretion. Any modification will be effective immediately upon posting on this website.
The date of the last update is indicated at the top of this page. We recommend that you review this policy periodically to stay informed about how we protect your information.
Continued use of this website after the posting of any modification constitutes your acceptance of the changes made. If you do not agree with the modified terms, you must stop using the website immediately.
13. 13. Contact
For any questions, concerns, rights exercise requests, or complaints related to this Privacy Policy or the processing of your personal data, you may contact Stella Maris Capital, Corp. through the following channels:
- Email: contact@stella-maris.xyz
- Postal address: Tower Financial Center, Piso 27, Calle 50, Ciudad de Panamá
We are committed to acknowledging receipt of your request within five (5) business days of receipt and to providing a substantive response within a maximum period of thirty (30) business days.
If you are not satisfied with our response, you have the right to lodge a complaint with the competent data protection authority in República de Panamá.