Legal
Privacy & Cookie notice
Last reviewed
This notice explains what personal data SOHBEL Management collects through this website, why, on what legal basis, and what rights you have. SOHBEL Management is established in the Republic of Panama, and this notice is written to meet Panama's Law 81 of 2019 on Personal Data Protection and its regulations. Where they apply to you, it also meets the EU and EEA General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (FADP). It covers this site only; data we process in the course of a client engagement is governed by the terms of that engagement.
Summary
- We collect only what you send us through the contact form or by email.
- We use it only to answer you. We never sell it or use it for marketing.
- The site uses no analytics, no advertising and no social media plugins, and sets no cookies of its own. The short cookie notice you may see is for information only: there is nothing to consent to.
- You can ask to see, correct or delete your data at any time by writing to sovereignindividual@sohbel.com.
Who is responsible
The controller responsible for the processing described here is:
- Controller
- SOHBEL Management
- Established in
- Republic of Panama
- Data protection contact
- sovereignindividual@sohbel.com
What we process and why
| Activity | Data | Purpose and legal basis | Kept for |
|---|---|---|---|
| Visiting the site | IP address, date and time, page requested, referring page, browser and operating system | Delivering the site and protecting it against attack and abuse. Legitimate interests (GDPR art. 6(1)(f)) in operating a secure website. | Security logs: up to 7 days, unless needed to investigate an incident. |
| Bot protection on the contact form | IP address and technical characteristics of your browser and device | Telling people from automated spam before a message is accepted. Legitimate interests (art. 6(1)(f)) in keeping the form usable and secure. | Not stored by us; a single-use check at the moment you send. |
| Contact form or email enquiry | Name, email address and message; company name and telephone number if you give them | Replying to you and, if you ask, taking steps towards an engagement. Your consent, given when you send the form or write to us; under the GDPR, steps taken at your request before an engagement (art. 6(1)(b)) or our legitimate interest in answering the enquiries we receive (art. 6(1)(f)). | 12 months after our last exchange if no engagement follows. If one does, the retention periods of that engagement apply. |
| Legal obligations and claims | Any of the above, where relevant | Complying with legal duties and establishing or defending legal claims. Legal obligation (art. 6(1)(c)) and legitimate interests (art. 6(1)(f)). | For as long as the obligation or the limitation period requires. |
Do you have to give us your data?
No. Nothing obliges you to contact us. If you do, we need your name, an email address and a message in order to reply; the other fields are optional. Please do not send us special categories of personal data (for example about health, religion or political opinions) or confidential information through the form or by email.
Automated decisions
We do not make decisions about you by automated means alone, and we do not use your data for profiling.
Who receives your data
We do not sell personal data, and we do not share it for marketing. Within our firm, only the people who need to handle your enquiry see it. Outside it, we use the service providers below. They process data only on our instructions, under data-processing agreements that oblige them to protect it.
| Provider | Role | Established in |
|---|---|---|
| Cloudflare, Inc. | Hosting, content delivery, security, bot protection (Turnstile) and email routing | United States, with a global server network |
| Resend, Inc. | Delivery of contact-form messages to our inbox | United States |
| Google LLC (Google Workspace) | Hosting of our email inbox, where enquiries are received and stored | United States, with data centres worldwide |
We may also disclose data to our professional advisers, who are bound by confidentiality, and to courts or public authorities where the law requires it or where it is needed to establish, exercise or defend legal claims.
International transfers
Some of the providers above are established in, or use servers in, countries other than Panama, in particular the United States. We transfer personal data abroad only where the recipient ensures a level of protection equivalent to that required by Panamanian law and, for visitors from Switzerland or the European Economic Area, only to countries recognised as adequate or under the safeguards below:
- Cloudflare, Inc. - EU–US and Swiss–US Data Privacy Framework certification; standard contractual clauses.
- Resend, Inc. - Standard contractual clauses.
- Google LLC (Google Workspace) - EU–US and Swiss–US Data Privacy Framework certification; standard contractual clauses in Google’s Cloud Data Processing Addendum.
You may ask us for a copy of the relevant safeguards at sovereignindividual@sohbel.com.
Cookies and similar technologies
Cookies are small files a website stores in your browser. Similar technologies, such as local storage, work in the same way.
What this site does
Our own code sets no cookies. It stores one thing in your browser's local storage: a single entry, sohbel-cookie-notice, recording that you have dismissed the cookie notice so it is not shown again. It contains nothing that identifies you, is never sent to us, and stays until you clear your browser's site data. We use no analytics, no advertising networks, no social media plugins and no embedded third-party content. Fonts, images and scripts are served from our own domain, so loading a page does not disclose your IP address to a font or content-delivery provider other than our host.
Strictly necessary security cookies
Our hosting and security provider, Cloudflare, may set the following cookies to protect the site from automated attacks. Most visitors will never receive them. They are not used to identify you or to follow you across other sites, and are used for nothing else.
| Name | Provider | Purpose | Duration | When it is set |
|---|---|---|---|---|
__cf_bm | Cloudflare | Distinguishes people from automated traffic to protect the site from bots. | 30 minutes | Only if Cloudflare bot protection is active for the domain |
cf_clearance | Cloudflare | Records that a browser has passed a security check, so it is not asked again. | Up to the challenge-passage period set for the domain (30 minutes by default) | Only after the visitor has been shown a Cloudflare security challenge |
The contact form may also show Cloudflare Turnstile, a check that tells people from bots. It issues a single-use token that is sent with your message and then discarded; it does not set a cookie.
Because these technologies are strictly necessary to provide the site securely, they do not require your consent. For visitors in Europe, this follows from article 5(3) of the EU ePrivacy Directive and its national implementations, and from article 45c of the Swiss Telecommunications Act.
Managing cookies
Every major browser lets you see, block and delete cookies in its settings. You can block the cookies above without affecting how the site looks, but you may then be shown a security check more often, and the contact form may not work. If you would rather not use the form, you can always write to us at sovereignindividual@sohbel.com.
If this changes
If we ever introduce analytics or any other technology that requires consent, we will ask for it before anything is set, let you withdraw it as easily as you gave it, and update this notice.
Your rights
Subject to the conditions set by applicable law, you have the right to the following. Panamanian law refers to them as your ARCO rights: access, rectification, cancellation, objection and portability.
- access the personal data we hold about you and receive a copy of it;
- rectification of data that is inaccurate or incomplete;
- erasure of your data;
- restriction of how we use it;
- data portability - to receive data you gave us in a structured, commonly used, machine-readable format, or have it sent to another controller;
- withdraw your consent at any time, without affecting what we did before you withdrew it.
Right to object. You may object at any time to our processing of your data, including processing based on legitimate interests, on grounds relating to your particular situation. We will then stop, unless we have compelling legitimate grounds that override your interests, or need the data to establish, exercise or defend legal claims.
To exercise any of these rights, write to sovereignindividual@sohbel.com. It costs nothing. We will reply within 10 business days, as Panamanian law requires. We may ask you to confirm your identity so that we do not disclose data to the wrong person.
Complaints
We would appreciate the chance to resolve any concern first. You also have the right to complain to a data protection supervisory authority:
- In Panama: National Authority for Transparency and Access to Information (ANTAI)
- In Switzerland: Federal Data Protection and Information Commissioner (FDPIC)
- In the EU or EEA: the authority in the country where you live or work, or where you believe an infringement took place, listed by the European Data Protection Board
Security
The site is served only over HTTPS, and enquiries are transmitted encrypted. We apply appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. No transmission over the internet is entirely secure, so please do not send confidential or sensitive information through the contact form; tell us instead that you would like a secure channel.
This site is intended for business contacts and is not directed at children. We do not knowingly collect data from anyone under 16.
Changes to this notice
We will update this notice when the way we process data changes. The date at the top of the page shows when it was last reviewed. Where a change is significant, we will say so here.