We may update this Privacy Policy at any time. The current version will always be available on https://chvmpionmind.com.

12. Professional contacts, investor relations and partnerships

CHVMPION MIND Technology S.L. may process limited professional contact information concerning investors, advisers, potential partners and other business representatives when evaluating a possible professional relationship or communicating about a relevant corporate, financing or partnership matter.

Categories of data. We may process your name, professional role, employer or affiliated organisation, professional email address, professional profile or company-page URL, geographic and investment-focus information, the public or referral source from which the information was obtained, our communication history, and your response or communication preferences. We do not intentionally collect special-category data for this purpose.

Sources. Data may be obtained from publicly accessible professional profiles, company or fund websites, professional directories, business publications, referrals made by professional contacts, and information you provide during correspondence.

Purposes. We use this information to assess whether a professional investment, advisory, referral or partnership conversation may be relevant; conduct proportionate one-to-one business outreach; manage correspondence and follow-up; maintain accurate CRM records; and record objections, unsubscribe requests and do-not-contact instructions.

Legal basis. Where applicable, the legal basis for processing is our legitimate interest in developing and financing our business and communicating with professional contacts whose role appears relevant, under Article 6(1)(f) GDPR. We apply data minimisation, relevance, role and source checks, limited outreach frequency, human review, and immediate suppression after an objection. We document a legitimate-interest assessment and do not rely on this basis where the individual’s interests, rights or reasonable expectations override our interest.

The legality of sending each electronic communication is assessed separately under the rules applicable to electronic marketing and the recipient’s jurisdiction. A legitimate interest under the GDPR does not automatically permit an unsolicited commercial email.

Internal prioritisation. We may use professional role, organisation, geography and publicly stated investment focus to prioritise contacts for human review. We do not make solely automated decisions that produce legal or similarly significant effects concerning you.

13. Recipients, transfers and retention of professional-contact data

Recipients and processors. Access is limited to authorised CHVMPION MIND personnel and service providers supporting email, hosting, CRM, security and professional advice, acting under appropriate contractual and confidentiality obligations. Data may also be disclosed where required by law.

International transfers. Where a service provider processes data outside the European Economic Area, CHVMPION MIND uses an applicable adequacy decision, Standard Contractual Clauses or another legally recognised safeguard, as appropriate. Information about relevant safeguards may be requested using the contact details in this policy.

Retention. Prospect and correspondence records are retained only for the relevant financing or business-development cycle and are reviewed no later than 12 months after the last meaningful interaction. Records may be retained longer where an active relationship, legal obligation or legal claim requires it. A minimal suppression record, normally the email address, date and reason for suppression, may be retained for as long as necessary to ensure that an objection or unsubscribe request is respected.

14. Information and rights of professional contacts

Where personal data was not obtained directly from you, we will provide the information required by Article 14 GDPR within the applicable legal period and, at the latest, in our first communication. You may request access, rectification, erasure or restriction, and you may object at any time to processing for direct-marketing purposes. When you object to direct marketing, we will stop using your personal data for that purpose.

You may exercise your rights by contacting [email protected] or by replying “Unsubscribe” to an outreach message. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) or another competent supervisory authority.