Legal

Privacy Policy

Last updated: 28 July 2026

1. Who we are (data controller)

Stellar Way Trade LLC, a limited liability company registered in Wyoming, United States, doing business as "Solvient", operates the website solvient.org and provides residence-permit application support services for France and Spain.

For the purposes of the EU General Data Protection Regulation ("GDPR") and the UK GDPR, Stellar Way Trade LLC is the data controller of the personal data described in this policy.

• Contact: [email protected]
• Registered address: 208 West Hampton Avenue, 1st Floor, Sumter, South Carolina, 29150, United States of America
• EU/UK representative details will be published here once the appointment is completed.

2. Who this policy covers

This policy applies to: (a) visitors of solvient.org; (b) prospective clients who submit a form, take the eligibility quiz, or book a call; (c) clients and their family members included in an application; (d) people who correspond with us. It applies wherever you are located, with region-specific sections for the EU/EEA, UK, Canada and the US.

3. What data we collect

Tier 1 — Website visitors:

• Technical data: IP address, device/browser type, pages viewed, referral source — via cookies and similar technologies, including Google Analytics 4 and Google Ads, only as permitted by your cookie choices (see our Cookie Policy, section 2, for how choices work in your region).
• Data processed by our infrastructure providers (Cloudflare) for security and content delivery.

Tier 2 — Leads (forms, quiz, bookings):

• Name, email, phone or messenger handle (if provided); your message ("briefly about your situation"); your quiz answers and the resulting route indication and score; page language (EN/RU); technical submission data (submission ID, consent-text version and timestamp); advertising attribution from your first visit (click IDs such as gclid or fbclid, UTM parameters, and the landing URL).
• Eligibility quiz answers: nationality/citizenship, country of residence, income range, family composition, relocation timeline.
• Correspondence (email, messaging).

Tier 3 — Clients (service delivery):

• Identity documents: passport copies, civil-status documents (birth/marriage certificates).
• Financial documents: bank statements, proof of income/resources, tax documents.
• Application-related documents and information about accompanying family members (including minors).
• Depending on the destination country's requirements, application files may include special categories of data (e.g., health data from medical certificates) and criminal-record certificates required by French or Spanish authorities. See section 6.

We collect data from you, and — for family members included in your application — from the applicant acting on their behalf. If you provide us with another person's data, you confirm you are authorized to do so and have informed them of this policy. Where a family member's data includes special categories (section 6), each adult signs their own explicit consent as part of the engagement paperwork; for minors, consent is given by the parent/guardian.

4. Why we process your data and on what legal basis

The legal bases above apply where the GDPR or UK GDPR applies to you. For visitors in other regions, analytics and advertising cookies operate as described in the Cookie Policy (section 2), including your right to opt out at any time.

Where we rely on legitimate interests, you may object (section 9). Where we rely on consent, you may withdraw it at any time without affecting prior processing.

5. Automated decision-making

The eligibility quiz produces a preliminary, informational indication of which route may fit your situation. No decision producing legal or similarly significant effects is made solely by automated means: any assessment that matters for your engagement is reviewed by a human before we accept or decline an engagement.

6. Special categories and criminal-record data

Immigration application files can include health data (e.g., medical certificates where required) and criminal-record certificates (required by French and Spanish authorities for long-stay applications).

• We process special-category data (health, etc.) only where necessary for the application and with the explicit consent of the data subject — each adult applicant gives their own consent (minors: parent/guardian) — which can be withdrawn at any time (this may make it impossible to continue the service).
• Criminal-record certificates: by default, you obtain and submit these directly to the authority — we do not store them. Where handling a copy by us is unavoidable, it occurs only where and as authorised by applicable law, with strict minimization and prompt deletion after submission.

7. Who receives your data

• Service providers (processors): Google (Workspace: email, document storage and our lead-management spreadsheet via Google Apps Script; Google Analytics 4), Cloudflare (hosting/security/CDN), Calendly (scheduling of the introductory calls you book through the link on the Site), and a secure document-exchange platform. These providers process data under their applicable terms and privacy documentation.
• We also receive an internal new-lead alert via Telegram; the alert contains only a technical reference (submission ID and product), not your personal details.
• Independent controllers providing services to us: Google in respect of Google Ads (advertising measurement and — with your consent — remarketing audiences, under Google's controller-to-controller terms; see the Cookie Policy) and payment processors, which process payment data under their own privacy policies.
• Independent professionals involved in your file at your request or with your knowledge: certified/sworn translators, and — where needed — qualified lawyers (avocats/abogados) or gestores administrativos.
• Government authorities of France or Spain (consulates, prefectures, extranjería offices): your application data is disclosed to them as the very purpose of the service — by you directly or as part of the file prepared for submission.
• Successors in the event of a corporate reorganization (with continuity of this policy's protections).
• We do not sell your personal data and do not share it with third parties for their own marketing. Advertising measurement and audience (remarketing) data is shared with Google only as described in the Cookie Policy and subject to your consent.

Booking an introductory call (Calendly). When you book a call, you do so through Calendly, our external scheduling provider: you go to Calendly's own page (we do not embed it on the Site) and enter the scheduling details there — typically your name, email, time zone, chosen time and any answers to the booking questions. We attach a technical reference to the booking link so we can match the booking back to your original enquiry for follow-up; that reference contains no name, email or phone. Calendly processes the booking on its own infrastructure under its own terms; we use the booking data only to schedule and follow up on the call you requested. Booking records are treated as lead data under section 10.

8. International data transfers

We are a US company: your data is processed in the United States and, where relevant, in the countries of the professionals involved in your file (EU).

• Data you give us directly: when you submit data to us from the EU/EEA or UK, the GDPR applies to us directly (Art 3(2)); this collection is not an onward "transfer" requiring a separate transfer tool.
• Onward disclosures to our vendors in third countries: our major vendors (Google LLC, Cloudflare) are certified under the EU–US Data Privacy Framework (and its UK Extension).
• Where a disclosure is not covered by an adequacy mechanism, we apply appropriate safeguards.

9. Your rights

If you are in the EU/EEA or UK, you have the right to: access your data; rectify it; erase it; restrict processing; data portability; object to processing based on legitimate interests; object absolutely to direct marketing; and withdraw consent at any time. EU/EEA: you also have the right not to be subject to solely automated decisions with legal or similarly significant effects (Art 22 GDPR). UK: in relation to significant automated decisions, you have the rights to be informed, to obtain human review, and to contest the decision (Arts 22A–22D UK GDPR, as amended by the Data (Use and Access) Act 2025). Some rights are limited where we must keep data to comply with legal obligations or to establish/defend legal claims.

To exercise your rights, email [email protected]. We respond within one month (extendable as permitted by law). You also have the right to lodge a complaint with a supervisory authority — in particular in your country of residence: e.g., CNIL (France, cnil.fr), AEPD (Spain, aepd.es), or the ICO (UK, ico.org.uk) — and to seek a judicial remedy.

If you are in Canada: we handle personal information in line with PIPEDA principles (consent, limited collection/use, safeguards, openness). You may request access to and correction of your information, and complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca). Quebec residents additionally have the rights provided by the Act respecting the protection of personal information in the private sector (as amended by Law 25), including data portability and cessation of dissemination, and may complain to the Commission d'accès à l'information (CAI); our person in charge of the protection of personal information can be reached at the contact below. Our privacy contact is [email protected].

If you are in the US: to the extent US state privacy laws apply to us, we honor the rights they provide — including the right to opt out of targeted advertising, which you can exercise via "Cookie Settings" on the Site or the Global Privacy Control (GPC) browser signal; in any case, we honor reasonable access and deletion requests at the contact above.

10. How long we keep data

11. Security

We apply appropriate technical and organizational measures: encrypted transmission (TLS), access controls and need-to-know access, a secure document-exchange platform for client files, vendor due diligence, and staff confidentiality commitments. No internet transmission is 100% secure; please use the secure channels we provide for sensitive documents rather than plain email attachments.

Data breaches: where a breach is likely to result in a risk to your rights, we will notify the competent supervisory authority within 72 hours of becoming aware of it, and affected individuals without undue delay where the risk is high.

12. Children

Our services are contracted by adults. We process children's data only as part of a family application file, provided by the applicant parent/guardian, with the protections in this policy. The Site is not directed at children and we do not knowingly collect children's data outside application files.

13. Cookies

See our Cookie Policy for the cookies and similar technologies used on the Site (including Google Analytics 4, Google Ads and Google Consent Mode v2), and how to manage your consent. You can change your choices at any time via "Cookie Settings" on the Site.

14. Changes to this policy

We may update this policy; the current version is always available on the Site with its "Last updated" date. Material changes affecting active clients will be notified by email.

15. Contact

Stellar Way Trade LLC d/b/a Solvient · 208 West Hampton Avenue, 1st Floor, Sumter, South Carolina, 29150, United States of America · [email protected]
EU/UK representative details will be published here once the appointment is completed.

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