Data Privacy Policy

This Privacy Policy explains how Azal Advisors collects, uses, stores, and protects personal data when you visit azaladvisors.com or contact us. It is issued pursuant to EU Regulation 2016/679 (GDPR) and Greek Law 4624/2019. If you have questions, contact us at it@azaladvisors.com.
  1. Who We Are

Azal Capital IKE is a private capital company (Ιδιωτική Κεφαλαιουχική Εταιρεία) incorporated in Greece, with its registered office at Kefallinias Street, Kifissia 14563. We provide advisory services to government and institutional clients. We are the data controller for personal data collected through this website.

  1. What Data We Collect and Why

We collect personal data in the following circumstances:

 

Purpose Data Collected Legal Basis (GDPR Art. 6)
Contact form submissions Name, email address, message content Art. 6(1)(f) – legitimate interests (responding to enquiries)
Website security and delivery IP address, browser type, pages visited, timestamps Art. 6(1)(f) – legitimate interests (website security and performance via Cloudflare CDN)
Email correspondence Name, email address, message content Art. 6(1)(f) – legitimate interests (business communications)
Daily Brief subscription Name, email address, organization, reports and format chosen, terms consent form Art. 6(1)(a) for consent; Art. 6(1)(c)/(f) for keeping proof of consent and opt-out.
Media monitoring Public posts from monitored social media accounts, Telegram channels and news
feeds (account name, post text, date, link), and names of people mentioned in them		 Art. 6(1)(f) – legitimate interests; Art. 9(2)(e) – data manifestly made public

 

Apart from the Daily Brief you have subscribed to, we do not send you marketing communications.
We do not use your personal data for profiling or automated decision-making, and we do not sell it.

     3. Media Monitoring

Azal Advisors produces the Daily Brief, a daily summary of political, security, economic and
foreign-policy developments in Syria and Iraq. To produce it, we collect posts published publicly
on selected X accounts, public Telegram channels and news feeds of media outlets, institutions,
officials and journalists. These posts may contain personal data of their authors and of people
they mention, including information about political opinions. We process this information on the
basis of our legitimate interest in media monitoring and analysis (Art. 6(1)(f) GDPR) and, where it
reveals political opinions, because it has been manifestly made public by the person concerned
(Art. 9(2)(e) GDPR). Posts are analysed with the help of an AI service (Anthropic) and stored on our
hosting provider’s servers (Render). Collected posts are deleted after 12 months. The Daily Brief
refers to public figures only in their public roles. Because we do not hold contact details for the
authors of these posts, we provide this information here rather than individually (Art. 14(5)(b)
GDPR). You may object to this processing or exercise your other rights by writing to
it@azaladvisors.com.

4. Cookies

Our website uses only strictly necessary cookies required for security and functionality. These cookies do not require your consent under the ePrivacy Directive. For full details, please see our Cookie Policy.

5. Who We Share Your Data With

We share your personal data only where necessary with the following categories of recipients:

  • Infomaniak Network SA (Switzerland) — our web hosting provider. Data hosted in Switzerland, which has an EU adequacy decision. Data Processing Agreement in place.
  • Proton AG (Switzerland) — our email provider. Data hosted in Switzerland. Zero-knowledge encryption means Proton cannot access email content.
  • Render Services, Inc. (USA) — hosting of the Daily Brief service and its database. Certified under the EU-US Data Privacy Framework; Data Processing Agreement with Standard Contractual Clauses.
  • Twilio Inc. / SendGrid (USA) — delivery of the Daily Brief and related emails. Certified under the EU-US Data Privacy Framework; Data Protection Addendum with Standard Contractual Clauses.

We do not share your data with any other third parties without your explicit consent, except where required by law.

6. International Transfers

Your data may be transferred outside the European Economic Area to the following countries:

  • Switzerland — adequate country per European Commission decision. No additional safeguards required.
  • United States (Render Services, Twilio / SendGrid) — transfers covered by Standard Contractual Clauses and the EU-US Data Privacy Framework.

Where we provide advisory services involving clients in non-EEA countries, any personal data transfers are made on the basis of contractual necessity (Article 49(1)(b) GDPR) or with appropriate safeguards in place.

7. How Long We Keep Your Data

We retain personal data only for as long as necessary:

  • Contact form enquiries: 2 years from submission, or until the matter is resolved.
  • Business correspondence that becomes part of a client engagement: 7 years from the end of the engagement.
  • Daily Brief: for as long as you are subscribed. Invitations not accepted within 30 days are deleted. After you unsubscribe, a record of your subscription and unsubscription is kept for
    5 years, then your details are deleted; only a one-way coded form of your email address is kept, so that we do not contact you again. Media monitoring: collected posts are deleted after 12 months

8. Your Rights

Under GDPR, you have the following rights:

  • Access — request a copy of your personal data.
  • Rectification — ask us to correct inaccurate data.
  • Erasure — ask us to delete your data where there is no longer a lawful basis for processing.
  • Restriction — ask us to restrict processing in certain circumstances.
  • Portability — receive your data in a structured, machine-readable format.
  • Objection — object to processing based on legitimate interests.

To exercise any of these rights, contact us at it@azaladvisors.com. We will respond within one calendar month. You also have the right to lodge a complaint with the Hellenic Data Protection Authority (HDPA): www.dpa.gr | Tel: +30 210 6475 600.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data on our end, including encrypted email (ProtonMail), HTTPS encryption on all web traffic, and restricted access to personal data on a need-to-know basis.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The current version is always available at azaladvisors.com/privacy-policy. Material changes will be notified prominently on the website.

11. Contact

Data controller: Azal Capital IKE, Athens, Greece

Data protection contact: it@azaladvisors.com

Supervisory authority: Hellenic Data Protection Authority (HDPA), www.dpa.gr