Data and Privacy Policy 

INVEREADY ASSET MANAGEMENT SGEIC SA (hereinafter referred to as “Inveready”) is a Spanish company with registered office in Zuatzu Kalea 7, first floor, door 1, Urola building, San Sebastián (28018), Guipúzcoa, registered in the Barcelona Mercantile Register under Volume 42929, leaf B-419543, Folio 28 and with CIF number A-65696007. You can contact Inveready at any time by sending an email to info@inveready.com.

Through our website www.inveready.com (hereinafter, the “Website”) the public may access news, information, and events organized by Inveready, as well as certain corporate information for our partners and investors.

The use of this website and its forms requires acceptance of the processing of the user’s data in accordance with this privacy policy, including the collection of access data and the delivery of commercial information by electronic means.

DATA CONTROLLER AND CONTACT INFORMATION
The data controller is: INVEREADY ASSET MANAGEMENT SGEIC S.A.
Address: Zuatzu Kalea 7, first floor, door 1, Urola building, San Sebastián (28018), Guipúzcoa
CIF: A-65696007
CNMV register number: 94
Contact telephone: 93 180 72 60
Email: lopd@inveready.com

By means of this notice, the company informs users of the website that, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27th 2016 concerning the protection of data subjects with regard to the processing of personal data and the free movement of data (hereinafter GDPR) and the Spanish Data Protection and Digital Rights Act, Organic Law 3/2018 dated 5th December 2018. The personal data provided will be included in our files owned by Inveready.

PURPOSE OF THE DATA PROCESSING

Please note that only data necessary for the proper development of the relationship between the parties is collected, and in particular, for any of the following purposes:

  • Managing access to technical documentation on the website.
  • Managing the procurement of services, as well as those administrative procedures pertaining to the existing commercial relationship.
  • Managing the use of any of those features which will be made available to the user on this website, including, by way of an example and therefore not limited to, subscription to newsletters and queries or requests for information.
  • Managing the sending of CVs by means of the following enabled form or in the case of registration for the different job offers.
  • Comply with the applicable sector regulations.

The user guarantees the authenticity of the data reported and will be solely responsible for any false or inaccurate statements. The personal data you provide to us with will be processed at all times in accordance with the GDPR and the applicable sector regulations.

LEGITIMACY

  • Data is processed with the aim of providing access to the online contents of the web as well as fulfill the requests from the users, keep a record of visits for statistical purposes (IP addresses, browser type, country, page accessed, etc.), to apply measures aimed at the security of the web, and, to deliver commercial information by electronic means about our services. When the user fills any of our forms it will be necessary to provide certain personal data, and it will be processed to carry out the user’s request.
  • For their part, the management of the procurement of services, payment, billing and corresponding shipments, is legitimized by the signing of the contract itself.
  • The processing of the data in order to send out electronic newsletters about services, events, and news related to our professional activity is based on the legitimate interest of the group in carrying out such processing in accordance with the regulations in force.
  • With regard to the submission of their CV and registration for professional job offers that we may publish, the legitimization of their processing is based on the consent of the user who sent their data, which they may withdraw at any time, although this would mean that their candidacy could no longer be taken into account in our recruitment processes. However, the withdrawal of consent shall not affect the lawfulness of the processing carried out prior to this.
  • In addition, the user’s information may be used to comply with the different legal obligations of the group.

The data is processed in base of the consent of the user, compliance with legal obligations, where appropriate for the execution of a contract or pre-contract.

DATA RECIPIENTS AND TRANSFERS

Recipients: INVEREADY ASSET MANAGEMENT SGEIC S.A. and group companies.

The company undertakes that all communications of your personal data are considered confidential, however, depending on the services that is contracted; different entities may be assignees of personal data. Among others: (i) where appropriate, the depository entities of the contracted funds, (ii) intermediary companies of investment, (iii) public institutions of the General State Administration, of the Autonomous and Local Administrations or authorities that may be located inside or outside the European Economic Area, to those who are legally obliged to provide them, (iv) group companies, or (v) service providers such as IT services, administration or advice.

International transfers are not planned (outside the European Economic Area), except for storage purposes, and in any case based on a decision of adequacy, on adequate guarantees, or to entities adhering to Privacy Shield program (http://www.privacyshield.gov)

DATA RETENTION TIME

We will only keep your data as long as the relationship with our company is maintained. From that moment, only those minimum necessary data related to the operations and transactions carried out in order to handle any claim will be kept blocked until they have prescribed our obligations (the data will be available to the corresponding authorities and for the formulation, exercise or defense of claims). Normally, the terms applicable to these responsibilities are 10 years, derived from the Money Laundering Prevention regulations and 6 years for commercial legislation. After this, the statute of limitations will proceed to their final deletion.

PEOPLE RIGHTS

Lastly, please also note that you may exercise your rights of access, rectification, deletion, limitation, portability, and objection with respect to personal data at any time as provided for in the regulations regarding the protection of data, by sending a written message with a photocopy of your identity document to the company e-mail address: lopd@inveready.com

In particular, you can exercise the rights that are set out below:

  • Revoke the consents granted.
  • Obtain confirmation as to whether the company is processing personal data that concern them or not.
  • Access your personal data.
  • Rectify imprecise or incomplete details.
  • Request the deletion of your data when the details are no longer necessary for the purposes for which they were collected, among other reasons.
  • Exercise limitation of the data processing when any of the conditions set out in the data protection regulations are met.
  • In certain circumstances and for reasons related to their particular situation with regard to the processing of personal data, data subjects may object to the processing of their data. The company will no longer process the data, except for imperative legitimate reasons, or in order to exercise or defend against any possible complaints.
  • Obtain human intervention, in order to express your point of view and to challenge the automated decisions taken by the group, if necessary.
  • Request the portability of your data.

Data subjects have the right to issue a complaint with the Data Protection Control Authorities, the Spanish Data Protection Agency, an organization that has the controlling authority in the matter, located at C/Jorge Juan, 6, Madrid (PC 28001).

VERACITY OF DATA, UPDATING DATA

The user must fill the forms with real, exact, complete and up-to-date data. The user will not enter data about other people; will presume that the data has been entered by the data subject him or herself. The user will be the only responsible for any harm or damage, direct or indirectly caused to another individual, derived from providing false, inexact, incomplete, or outdated data or data referring to another person.

Users must communicate any changes in the provided data in order to keep it up-to-date.

INFORMATION SECURITY

Inveready has taken all the measures required by law to protect personal data; likewise, it has adopted the technical measures available to prevent data loss, unfair use, alteration, unauthorized access or data theft. Nevertheless, the user will take into account that security measures on Internet are not completely unbreachable.

WEB ANALYTICS

This website deploys web analytics in order to gain some understanding of how user search for, access and navigate it. These analytics can entail the collection of personal data like the user IP address, connection location, browsing software, and hardware features, etc. This information is not associated with the user and is exclusively used for statistical analysis.

USE OF THIRD-PARTY FUNCTIONS AND PLUG-INS

This website may deploy functions and plug-ins provided by third parties. These functions serve several purposes like:

  • Third-party web analytics
  • Third-party maps
  • Third-party video streaming
  • Sharing contents in social networks
  • “Fav”, “Like”, “+1” and similar buttons

A function or plugin provided by a third party establishes a direct connection between the user browser and internet domains owned by the third party, allowing to download and execution of the function. Most third-party plugins collect information about the websites visited by the user in order to know his or her interests and to provide targeted advertisements.

USE OF THE GOOGLE ANALYTICS FUNCTION PROVIDED BY GOOGLE, INC.

This website deploys analytical functions provided by Google Inc (1600 AMPHITHEATRE PARKWAY, MOUNTAIN VIEW, CALIFORNIA, USA) in order to understand how user search for, access and navigate it. These analytics can entail the collection of user activity tied to his or her IP address. When the user loads this website, the user browser makes a connection to Google domains like google.com in order to record the user access to the website. Google Analytics makes use of permanent cookies to create anonymous analytics about this website, according to Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en

The user consent for the processing performed by Google is implied from the use of this website. Use of functions provided by Google, Inc.

This website may deploy functions provided by Google Inc (1600 AMPHITHEATRE PARKWAY, MOUNTAIN VIEW, CALIFORNIA, USA) like YouTube videos, maps and social buttons “+1”. These functions can entail the collection of user activity tied to his or her IP address. When the user loads this website, the user browser makes a connection to Google domains like google.com enabling Google to know that the user is accessing the website. Google collects usage data for several purposes including targeted advertisements according to Google’s privacy policies http://www.google.es/intl/en/policies/privacy/.

The user consent for the processing performed by Google is implied from the use of this website.

APPLICABLE LEGISLATION AND COMPETENT JURISDICTION

Any dispute arising from matters relating to the Website shall be subject to the exclusive jurisdiction and jurisdiction of the Courts of the city of Barcelona.