LEGAL INFORMATION

Who is responsible for the processing of users’ personal data?

Identity: Sancus Capital SGEIC, S.A.

NIF: A42904276

Postal address: Plaza de la Lealtad, nº 2-1st floor – 28014 Madrid

Telephone: +34 91 781 96 28

Email: info@sancuscapitalpartners.com

Data Protection Delegate: Yes, a DPO has been appointed in the entity

DPO Contact: dpo@sancuscapital.es

For what purpose does Sancus Capital SGEIC, S.A. treat personal data of users?

In Sancus Capital SGEIC, S.A. We treat your personal data with the utmost respect and compliance with the applicable regulations on the protection of personal data.

We treat your data to manage queries, complaints, suggestions and requests made by interested parties and the issues arising from them by the company.

We inform you that we will limit ourselves to processing your personal data for the aforementioned purposes.

We inform you that, in no case, automated decisions will be adopted based on your profile.

How long will we keep your personal data?

When dealing with a query, complaint, suggestion or request, we will process your personal data for as long as necessary to resolve it satisfactorily and completely and, subsequently, for the time necessary to comply with legal requirements.

In other cases, we will process your data for the time necessary to manage your request and/or service.

What is the legitimacy to carry out the treatment of the personal data of the users?

The legitimacy for the processing of your personal data is that it is necessary for the execution of the legal relationship that arises when filling in the contact form, being necessary to attend to your query, suggestion or request.

What obligations does Sancus Capital SGEIC, S.A. fulfill regarding the personal data treatment?

Sancus Capital SGEIC, S.A. complies with each and every one of the principles required by the General Data Protection Regulation and the LOPDGDD. Below, we include a brief summary of all of them to understand exactly what it entails. However, we will be happy to clarify any questions that may arise in this regard by sending an email to dpo@sancuscapital.es.

In this sense, the General Data Protection Regulation and the LOPDGDD establish a series of principles – that is, obligations for Sancus Capital SGEIC, S.A. and all its staff – that Sancus Capital SGEIC, S.A. will take into account during all the phases, treatments and actions to which they submit the personal data for which they are responsible.

These principles are regulated in articles 5 and 6 of the General Data Protection Regulation and are:

  • Principle of legality, loyalty and transparency that implies, as its name indicates, that Sancus Capital SGEIC, S.A. will only have the right to process data in a “lawful, fair and transparent manner in relation to the interested party”.
  • Principle of purpose limitation. This principle requires that Sancus Capital SGEIC, S.A. will only process data collected for “determined, explicit and legitimate purposes”. This principle also implies that Sancus Capital SGEIC, S.A. may not further process such data “in a manner incompatible with those purposes”.

The prohibition of processing them for incompatible purposes, according to the provisions of article 89.1 of the General Data Protection Regulation, is not applicable to the processing of said data for the purposes of “archive in the public interest, scientific and historical research purposes or statistical purposes”.

  • Principle of data minimization. This obligation entails the duty of Sancus Capital SGEIC, S.A., as the data controller and of all the personnel who work for Sancus Capital SGEIC, S.A. to process only data that is “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed”.
  • Principle of accuracy. This principle is specified in the need for Sancus Capital SGEIC, S.A. process personal data that is accurate and, therefore, up to date. In this sense, the General Data Protection Regulation requires that Sancus Capital SGEIC, SA, as data controller, adopt “all reasonable measures to promptly delete or rectify personal data that is inaccurate with respect to the purposes for those who are treated”. Therefore, we ask that, in the event that any personal data has changed with respect to those you provided us with when we started the relationship, please let us know as soon as possible in order to process personal data only if they are updated.

The principle of accuracy requires -and so will Sancus Capital SGEIC, S.A. – that Sancus Capital SGEIC, S.A. periodically adopt measures to verify – to the extent possible and making reasonable efforts – that the personal data it processes are accurate and up-to-date.

  • Principle of limitation of the term of conservation. This principle requires that Sancus Capital SGEIC, S.A. only keep the personal data that it treats – in a way that allows the identification of the interested parties – for no longer than necessary for the purposes of the processing of personal data.

The General Data Protection Regulation allows personal data to be kept for longer periods “provided that they are treated exclusively for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes”, in accordance with article 89, section 1, without prejudice to the application of the appropriate technical and organizational measures imposed by the General Data Protection Regulation in order to protect the rights and freedoms of the interested party.

  • Principle of integrity and confidentiality. This obligation implies the adoption by Sancus Capital SGEIC, S.A. of all measures -technical, organizational or of any other nature- that are necessary to guarantee “adequate security of personal data, including protection against unauthorized or unlawful processing and against loss, destruction or accidental damage.
  • Principle of Accountability. This principle is one of the new obligations incorporated in the General Data Protection Regulations and which implies a change in attitude and mentality, as far as personal data protection and security are concerned, on the part of Sancus Capital SGEIC, S.A. and, therefore, of all its staff.

Compliance, in practice, with this duty of Accountability (also known as active responsibility or accountability) means that Sancus Capital SGEIC, S.A. and all its personnel, have an active and preventive attitude -and not reactive- in the face of possible risks, threats and/or inappropriate treatment of personal data from the beginning in all phases of treatment.

For this reason, all the personnel of Sancus Capital SGEIC, S.A. is aware of the importance of this principle of Accountability, which implies the adoption of preventive measures, attitudes and proactive actions and for the benefit, at all times, of the maximum with respect to the fundamental right to the protection of personal data of the owner.

This principle of Accountability supposes an extensive documentary work that allows a traceability of all the actions that have been adopted to comply with this active responsibility on the part of all the personnel of Sancus Capital SGEIC, S.A.

  • Principle of legality of the treatment. The General Data Protection Regulation requires, how could it be otherwise, that all processing of personal data that is carried out be lawful and, in this sense, includes six legal bases that make the processing of personal data carry out is lawful.

These six bases are regulated in article 6 of the General Data Protection Regulation and are made up of the following factual assumptions:

  • a) the interested party gave their consent to the processing of their personal data for one or more specific purposes;
  • b) the treatment is necessary for the execution of a contract in which the interested party is a party or for the application at the request of the latter of pre-contractual measures;
  • c) the processing is necessary for compliance with a legal obligation applicable to the data controller;
  • d) the processing is necessary to protect the vital interests of the data subject or of another natural person;
  • e) the processing is necessary for the fulfillment of a mission carried out in the public interest or in the exercise of public powers vested in the data controller;
  • f) the processing is necessary to satisfy the legitimate interests pursued by the data controller or by a third party, provided that the interests or fundamental rights and freedoms of the data subject that require the protection of personal data do not prevail over said interests, in particularly when the interested party is a child.

Likewise, you can consult the full text of the General Data Protection Regulation as well as the LOPDGDD.

And, in case of any doubt or question that arises related to the protection of personal data, you can contact our data protection delegate at dpo@sancuscapital.es.

To which recipients will the personal data of the users be communicated?

Sancus Capital SGEIC, S.A. will not transfer or make international transfer of your personal data.

They will only transfer your personal data in the event that a Law requires you to do so.

We also inform you that Sancus Capital SGEIC, S.A. works with several entities that provide a service that requires access to personal data, therefore, these entities are in charge of processing Sancus Capital SGEIC, S.A.

What security measures has Sancus Capital SGEIC, S.A. adopted? to protect your data?

From Sancus Capital SGEIC, S.A. We take all measures in our power to ensure the security and confidentiality of all personal data we process. These measures are both physical and logical, of a technical and organizational nature and necessary depending on the data we process. Of course, the measures are adopted with the aim of guaranteeing the security, confidentiality and integrity of all the personal data that we process to avoid its alteration, loss, treatment and/or unauthorized access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed, whether they come from human action or from the physical or natural environment.

Likewise, Sancus Capital SGEIC, S.A. has an updated Security Document (following the recommendations of the Spanish Agency for Data Protection) on its conservation and adaptation to the requirements of the RGPD and the LOPDGDD.

Among the security measures (as a summary) that we adopt are: constant training of all our workers, use of secure passwords and frequent change of the same, backup copies, encrypted sending of personal data, control of access to personal data in function of needs, security audit, hiring of treatment managers that offer the necessary security and strict compliance with data protection regulations, physical security measures for access control (keys, padlocks, etc.), paper shredder, use of official programs that guarantee the security in the processing of personal data and, of course, all those that are offered by technique and technology and that are consistent with the risks identified for the processing of personal data carried out by Sancus Capital SGEIC, S.A.

In this same sense, we ask you to do everything in your power to prevent being a victim of any of the attacks that, unfortunately, take place on the Internet. To do this, we remind you not to click on any link whose origin you are not sure of, do not provide bank details or passwords electronically or by telephone, use a secure password (combining letters, numbers and special characters) and change it frequently (at least once a year). Likewise, in case you have any doubt that Sancus Capital SGEIC, S.A. request data and/or any other type of action, please consult Sancus Capital SGEIC, S.A. before taking any action in the email dpo@sancuscapital.es.

What rights do users have as holders of their data?

You, as the owner of personal data, both on your own behalf and through a representative – legal or voluntary – may exercise the rights of access, rectification, limitation of treatment, deletion, opposition as well as the right to portability of your data.

We briefly explain what each of the rights consist of:

– Right of access: you have the right to know which of your personal data is being processed by Sancus Capital SGEIC, S.A.

– Right of rectification: you have the right for Sancus Capital SGEIC, S.A. to rectify your personal data that is erroneous or that has become outdated (For example: change in the email, errata in the contact telephone number, change in the mailing address or account number).

– Right of deletion: you have the right to request that Sancus Capital SGEIC, S.A. delete the personal data referring to your person. However, in the event that there is a cause that prevents it (contractual relationship, legal requirements, etc.), upon receipt of your request, Sancus Capital SGEIC, S.A. will inform you if you can positively address your right of deletion or cannot do so.

– Right to limit treatment: you have the right to request that Sancus Capital SGEIC, S.A. cessation of a certain processing of personal data that is being carried out. However, and as in the right of deletion, in the event that there is just cause for not positively addressing your right, Sancus Capital SGEIC, S.A. will let you know in a clear, simple and transparent way.

– Right to the portability of your data: you have the right to request a copy of the personal data that Sancus Capital SGEIC, S.A. is dealing with your person as long as these have been provided by you and, furthermore, they are in a structured, commonly used and machine-readable format. Likewise, you can choose if you want such data to be provided to you or to another data controller.

– Right of opposition: you may exercise this right to oppose a certain processing of personal data that is being carried out by Sancus Capital SGEIC, S.A. However, and as occurs with the right of suppression and limitation, in the event that there are legitimate reasons that require treatment and/or legal obligations, such circumstance will be communicated to you in a simple and transparent way by Sancus Capital SGEIC., S.A.

– Right not to be the subject of automated decisions: you have the right not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects on you or significantly affects you in a similar way.

To exercise them, you must contact us via email malonso@sancuscapital.es, indicating in the Subject “Data Protection Rights” or, if you prefer, by mail to Sancus Capital SGEIC, S.A. at Plaza de la Lealtad, nº 2-1st floor – 28014 Madrid, specifying which right you want to exercise and sending a photocopy of your DNI.

Within a maximum period of 30 days – putting all our efforts and the means at our disposal to reduce that period to the maximum possible – from the time we receive your request, you will receive a response from us. If you are not satisfied, you can go to the Spanish Agency for Data Protection to request the protection of rights.

However, prior to submitting such a claim, you may (and we ask that you do so) refer such claim to our DPO, who will be pleased to resolve your issue as soon as possible. You can contact our DPO at the following email address dpo@sancuscapital.es.

How have we obtained your personal data?

The personal data that we process at Sancus Capital SGEIC, S.A. have been collected through the form enabled to establish contact with us. All the personal data that we request marked as “required” are necessary to manage your query or request, so they are mandatory in such a way that, if you do not provide them, we will not be able to attend to it.

The categorie of data that are processed is:

  • Identification data

We inform you that data that the General Data Protection Regulation qualifies as “special categories of data” (data on health, religion, ideology, union affiliation, etc.) are not processed.

What is the organism to which you can file a claim regarding data protection?

We inform you that you can file a data protection claim with the Spanish Data Protection Agency. They have all the information on their website: www.aepd.es.

However, prior to submitting such a claim, you may (and we ask that you do so) refer such claim to our DPO, who will be pleased to resolve your issue as soon as possible. You can contact our DPO at the following email address dpo@sancuscapital.es.

1. IDENTIFICATION DATA

In compliance with the duty of information of article 10 of Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce, which establishes the obligation of all service providers of the society of the information to have means that allow, both the recipients of the service and the competent organism, access by electronic media, permanently, easily, directly and free of charge to certain information that we provide in this section.

Data of the owner of the website:

Sancus Capital SGEIC, S.A.

NIF: A42904276

Address: Plaza de la Lealtad, nº 2-1st floor – 28014 Madrid

Telephone: +34 91 781 96 28

E-mail: info@sancuscapital.es

Registration data: Sancus Capital SGEIC, S.A. (hereinafter, “Sancus Capital”), a company registered in the Mercantile Registry of Madrid, Volume 41,408, Book 0, Folio 154, Page M-734799, with registered office in Madrid, Plaza de la Lealtad, nº 2-1st Floor – 28014 Madrid, and NIF A-42904276.

2. TERMS OF SERVICE

These conditions are the terms and conditions that regulate the access and use of the website that Sancus Capital makes available to its users and customers on the Internet.

The Sancus Capital website includes www.sancuscapital.es and all Sancus Capital online sites (“our Website”) such as blog, web, support materials, control panels, product pages, manuals, microsites, etc., both under www.sancuscapital.es as under other domains controlled and/or operated by Sancus Capital. Visiting and browsing our website attributes the condition of user (“User”) to the user and implies that they have read, understood, and fully accepted these conditions and our Privacy Policy. If you do not agree with any of these conditions, please do not continue using our website.

Access to our website is free, except in those cases in which prior contracting is required to access certain content or services, a situation of which you will be clearly informed, and your explicit acceptance of the provision contract of services and appropriate payment will be requested.

3. CONTENT AND INTELLECTUAL PROPERTY

All the contents of our website, including, without limitation, the texts, diagrams, photos, graphics, logos, names, icons or computer applications, as well as the domain names are the property of Sancus Capital (except in the cases in which it is indicated otherwise) or the corresponding rights or transfers have been acquired and are protected by national and international laws and regulations related to intellectual property, domain registration regulations and trademark registration regulations. Sancus Capital registered trademark in the Spanish Patent and Trademark Office.

The use of our website or any content present on them without the written permission of Sancus Capital is prohibited. The User undertakes not to violate the intellectual and industrial property rights belonging to both Sancus Capital and third parties.

In no case shall it be understood that access to our website or the contracting of any of the Sancus Capital products by the User implies a transmission, license or even partial assignment of any of the aforementioned rights by Sancus Capital to the User.

All trade names, brands, logos, icons, slogans and distinctive signs on our website belong to Sancus Capital or it has received authorization of the right to use them by the owner.

The unauthorized use or for purposes other than those provided in these Conditions of the contents and information of our Website, or its use for commercial purposes by the User, as well as the infringement of the Intellectual Property rights or trademarks of Sancus Capital, will give rise to the legally established responsibilities and actions.

4. COOKIES

You have all the information about cookies, and the time of permanence in the following link: https://sancuscapital.es/informacion-legal/#tab_uso-de-cookies

5. PERSONAL DATA PROTECTION

You can access our privacy policy at the following link: https://sancuscapital.es/informacion-legal/#tab_politica-de-privacidad

6. LIMITATION OF LIABILITY

Sancus Capital does not control or guarantee continuous access, nor the correct display, download or use of the elements and information contained in its website, which may be impeded, hindered or interrupted by factors or circumstances that are beyond its control and are not is responsible for service interruptions, delays or malfunctions when they are due to causes beyond its control, due to force majeure, or due to malicious or negligent action by the user.

Sancus Capital reserves the right to limit or interrupt access to our website, as well as the offer or provision of how many services and products are advertised on it at any time and without prior notice, for reasons of maintenance, security, power failure, reasons technicians or others, without this being able to derive any responsibility or having the right to request any financial compensation. Sancus Capital will not assume any responsibility, direct or indirect, for direct or indirect damages or loss of profits that may derive from the non-availability of our website or the services of Sancus Capital.

Sancus Capital may include links to third parties and/or external websites, outside the control of Sancus Capital. Although we will periodically verify the legality, veracity and relevance of these sites, we cannot guarantee their quality. In these cases, Sancus Capital cannot guarantee, nor can it assume any type of responsibility regarding these external contents or the damages that may be caused by access to said sites. Sancus Capital will only be responsible, in accordance with article 17 of Law 34/2002 on Services of the Information Society and Electronic Commerce, of July 11, 2002, for those contents that, having had effective and reliable knowledge of the illegality would not have deleted or deactivated the link to them.

In the same way, Sancus Capital does not assume any responsibility for the information that may exist about it on third-party websites or that can be accessed through search engines or third-party links to our website.

Sancus Capital reserves the right to modify these general conditions whenever and wherever necessary. In the event that the change in the content is substantial, it will be done in any case prior to the inclusion on the website of a notice informing of the change in question in a visible and easily accessible place for all users.

7. USE OF THE WEBSITE BY MINORS

Although this website is not directed to minors, their access is permitted. However, in the event that a minor wishes to request information from us, they can only do so by themselves if they are over 14 years of age. In the case of minors under 14 years of age, it must be done by whoever has parental authority, guardian or legal representative, authorizing the processing of their personal data by the company on their behalf, so that those who are in charge of minors of age assume sole responsibility for determining the services and contents of this website that are appropriate for the age of the minors in their charge.

Sancus Capital assumes no responsibility in the event that minors under the aforementioned age provide us with their personal data in breach of these obligations.

8. PROHIBITION OF DISSEMINATION OF THE CONTENTS AND INFORMATION PROVIDED

Users undertake to use the content diligently, correctly and lawfully and, in particular, undertake to refrain from reproducing or copying, distributing, allowing public access through any form of public communication, transforming or modifying the content, unless you have the authorization of the owner of the corresponding rights or it is legally permitted.

9. OTHER ISSUES OF INTEREST

Sancus Capital does not guarantee the absence of viruses or other elements that may cause alterations in the users’ computer system or in the electronic documents or files stored in it. For this reason, Sancus Capital is not responsible for possible damages of any nature that may arise for users.

The user agrees to use the website in accordance with the provisions of the law, morality, and public order and, in any case, in accordance with the conditions stipulated in this website. Likewise, it should be emphasized that the user undertakes to make appropriate use of the services and contents of the website, avoiding the commission of illegal acts or constituting crimes that violate the rights of third parties or infringe current regulations on intellectual and industrial property.

Similarly, it is forbidden for the user to introduce content or information on the website that is xenophobic, pornographic or that violates human rights.

Finally, the inclusion or dissemination through the website of both viruses or malicious software and illicit advertising is expressly prohibited.

10. APPLICABLE LAW AND JURISDICTION

The activity carried out through the website www.sancuscapital.es is subject to applicable Spanish legislation in force.

These Conditions will be governed and interpreted in accordance with Spanish law, being subject for any dispute, claim or controversy over them to the exclusive jurisdiction of the Courts of Madrid.

11. ONLINE DISPUTES

In compliance with the duty of information regarding online dispute resolution in accordance with Art. 14.1 of Regulation (EU) 524/2013, we inform you that the European Commission provides an online dispute resolution platform, which is at your disposal. available at the following link: http://ec.europa.eu/consumers/odr/

Definitions

Cookies: they are small text files that are stored on the hard drive or in the memory of the computer that accesses or visits the pages of certain websites, so that the user’s preferences can be known when reconnecting. Cookies stored on the user’s hard drive cannot read the data contained on it, access personal information or read cookies created by other providers.

Data: is the information obtained through the user’s terminal equipment through the data storage and retrieval device (cookies or others).

Terminal equipment: is the device from which the user accesses the service, such as a personal computer, a mobile phone, a tablet, etc., and from which the information is obtained.

Publisher: any entity providing information of the society services that owns a web page that a user can access and for whose provision cookies are used. Each of the companies indicated in the “Legal Notice” will be the editor of this website.

User: is the recipient, a natural person, who accesses the service provided by an editor, being able to differentiate between registered and unregistered user.

What kind of cookies exist?

According to the entity that manages them:

Own cookies: are those that are sent to the user’s terminal equipment from a computer or domain managed by the editor itself and from which the service requested by the user is provided.

Third-party cookies: are those that are sent to the user’s terminal equipment from a computer or domain that is not managed by the publisher, but by another entity that processes the data obtained through cookies.

According to its purpose:

Technical cookies: are those that allow the user to navigate through a web page, platform or application and the use of the different options or services that exist in it, including those that the editor uses to allow the management and operation of the website and enable its features and services.

Preference or personalization cookies: these are those that allow the user to remember information so that the user accesses the service with certain characteristics that can differentiate their experience from that of other users, such as, for example, the language or the number of results to be displayed when the user performs a search etc.

Analysis or measurement cookies: are those that allow the person responsible for them to monitor and analyze the behavior of the users of the websites to which they are linked, including the quantification of the impacts of the advertisements. The information collected through this type of cookie is used to measure the activity of the websites, application or platform, in order to introduce improvements based on the analysis of the usage data of the users of the service.

Behavioral advertising cookies: they are those that store information on the behavior of users obtained through the continuous observation of their browsing habits, which allows the development of a specific profile to display advertising based on it.

According to the period of time they remain active:

Session cookies: are those designed to collect and store data while the user accesses a page. They are usually used to store information that is only of interest to keep for the provision of the service requested by the user on a single occasion (for example, a list of products purchased) and they disappear at the end of the session.

Persistent cookies: they are a type of cookie in which the data is still stored in the terminal and can be accessed and processed for a period defined by the person responsible for the cookie, and which can range from a few minutes to several years.

What type of cookies do we use at www.sancuscapital.es?

Cookie name
Purpose
Duration
cookielawinfo-checkbox-necessary
This cookie is used to save the user’s consent for cookies in the “Necessary” category.

1 year
cookielawinfo-checkbox-functional
This cookie is used to record user consent for cookies in the “Functional” category.

 

1 year
cookielawinfo-checkbox-performance
This cookie is used to store the user’s consent for cookies in the “Performance” category.

 

1 year
cookielawinfo-checkbox-analytics
Cookie used to store the user’s consent for cookies in the “Analytics” category.

 

1 year
cookielawinfo-checkbox-advertisement
Cookie used to record user consent for cookies in the “Advertising” category.

 

1 year
cookielawinfo-checkbox-others
Cookie used to store the user’s consent for cookies in the “Other” category.

1 year
pll_language
Cookie used to know the user’s navigation language.

1 year
_ga
Google Analytics cookie that is used to calculate the data of visitors, sessions and campaigns and also tracks the use of the site for its analysis report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.

2 years
_gid
This cookie is installed by Google Analytics. The cookie is used to store information about how visitors use a website and helps create an analytics report of how the website performs. The data collected, including the number of visitors, the source from which they come and the pages, appeared anonymously.

1 day
_gat
These cookies are installed by Google Universal Analytics to limit request speed and limit data collection on high traffic sites.

1 minute
viewed_cookie_policy
It is used to update your cookie policy, filter services that set specific cookies.

1 year
wordpress_test_cookie
This describes whether this specific cookie, localStorage, or other resource is responsible for sharing, collecting, or storing direct or indirect personal data.

48 hours

 

 

In relation to analytical cookies and the purposes described, we use Google Analytics, a service provided by Google, Llc., a company that acts as data processor and, despite being outside the European Economic Area, the international transfer of data involved its use has the appropriate guarantees contemplated in article 46.2 c) of the General Data Protection Regulation (standard contractual clauses approved by the European Commission).

Cookies policy

Privacy Policy

For more information about Google Analytics cookies: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

How to disable cookies?

The way in which the user can disable cookies will depend on the browser or browsers used. You can also change your consent in the “Cookies” tab that you can find at the bottom right of the website.

In any case, all browsers allow you to change the settings related to cookies. Next, we indicate the links to each browser:

Firefox

Chrome

Safari

Microsoft Edge

Internet Explorer

Android

IOS

If you do not want to be tracked by cookies, Google has developed a plug-in to install in your browser that you can access at the following link.

 

What are the consequences of disabling cookies?

In the event that the user prevents the activation of cookies or deactivates them if they have previously authorized them, it may affect the operation of some functionalities of the website, such as, among others, that information is not saved about the acceptance of the initial notice of cookies so it will be shown again on the next visit.

In the same way, we will not be able to obtain information about users’ browsing through our website, which will prevent or hinder the improvement of the information and content that we publish, as well as its presentation.

Changes or updates to our cookie policies

It is possible that the structure and functionalities of this website may be modified to add new sections, services or content, which may mean that the use and, therefore, our cookie policy is modified. For this reason, we recommend that users review the published cookie policies each time they access our website in case there has been any change since their last visit.

We recommend that you visit this website to obtain more information about cookies.

Data controller and contact details

For questions and/or comments about our cookie policy and this statement, please contact us, as data controllers, using the following contact details:

Sancus Capital SGEIC, S.A.

NIF: A42904276

Plaza de la Lealtad, nº 2-1st Floor – 28014 Madrid

dpo@sancuscapital.es

Telephone: .:+34 91 781 96 28

You can consult the information on the processing of personal data in our

Privacy Policy.

Who is responsible for the processing of your personal data?

Identity: Sancus Capital SGEIC, S.A.

NIF: A42904276

Postal address: Plaza de la Lealtad, nº 2-1st Floor – 28014 Madrid

Telephone: +34 91 781 96 28

Email: info@sancuscapitalpartners.com

Data Protection Delegate: Yes, a DPO has been appointed in the entity

DPO Contact: dpo@sancuscapital.es

For what purpose does Sancus Capital SGEIC, S.A. your personal information?

In Sancus Capital SGEIC, S.A. we treat your personal data with the utmost respect and compliance with the applicable regulations on the protection of personal data.

We treat your data to manage the query, complaint, suggestion or request that you make to us and the issues that arise from it by Sancus Capital SGEIC, S.A. We inform you that we will limit ourselves to processing your personal data for the aforementioned purpose.

We inform you that, under no circumstances, will automated decisions be made based on your profile.

How long do we keep your personal data?

When dealing with a query, complaint, suggestion or request, we will process your personal data for as long as necessary to resolve it satisfactorily and completely and, subsequently, for as long as necessary to comply with legal requirements.

What is the legitimacy to carry out the processing of your personal data?

We inform you that the legitimacy for the processing of your personal data is that it is necessary for the execution of the legal relationship that arises when filling out this form, being necessary to attend to the query, suggestion or request.

To which recipients will your data be communicated?

Sancus Capital SGEIC, S.A. will not transfer or make international transfer of your personal data.

You will only transfer your personal data in the event that a Law requires you to do so.

We also inform you that Sancus Capital SGEIC, S.A. works with several entities that provide a service that requires access to personal data, therefore, these entities are in charge of processing Sancus Capital SGEIC, S.A.

What rights do you have as the owner of the data?

You, as the owner of personal data, both on your own behalf and through a representative -legal or voluntary- may exercise the rights of access, rectification, limitation of treatment, deletion, opposition as well as the right to portability of your data.

To exercise them, you must contact us via email dpo@sancuscapital.es indicating in the Subject “Data Protection Rights” or, if you prefer, by mail to Sancus Capital SGEIC, S.A. at Plaza de la Lealtad, nº 2-1st Floor – 28014 Madrid, specifying which right you want to exercise and sending a photocopy of your DNI.

Within a maximum period of 30 days – putting all our efforts and the means at our disposal to reduce that period to the maximum possible – from the time we receive your request, you will receive a response from us. If you are not satisfied, you can go to the Spanish Agency for Data Protection to request the protection of rights.

How have we obtained your personal data?

The personal data that we process at Sancus Capital SGEIC, S.A. have been collected through this form. All the personal data that we request marked as “required” are necessary to manage your query or request, so they are mandatory in such a way that, if you do not provide them, we will not be able to attend to it.

The categorie of data that are processed is:

• Identification data

We inform you that data that the General Data Protection Regulation qualifies as “special categories of data” (data on health, religion, ideology, union affiliation, etc.) are not processed.

What is the organism to which I can file a claim regarding data protection?

We inform you that you can file a data protection claim with the Spanish Data Protection Agency. It has all the information on its website: www.aepd.es.