Privacy Policy

https://carlac-capital.com/

I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, CARLAC CAPITAL PARTNERS SL (hereinafter Carlac Capital) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws that this privacy policy incorporates

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it respects the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD) .

• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

• Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected at CARLAC CAPITAL PARTNERS SL is: Carlac Capital, with NIF: B88093810 (hereinafter, Data Controller). Their contact information is as follows:

Address: Calle Velázquez, 150 Madrid CP: 28002

Telephone contact:

Contact email: administracion@carlac-capital.com

Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by CARLAC CAPITAL PARTNERS SL, through the forms extended on its pages, will be incorporated and will be processed in our file in order to facilitate, expedite and comply with the commitments established between CARLAC CAPITAL PARTNERS SL and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query from the User. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities. carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles included in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights:

• Principle of legality, loyalty and transparency: the User's consent will be required at all times following completely transparent information about the purposes for which personal data is collected.

• Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.

• Data minimization principle: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.

• Accuracy principle: personal data must be accurate and always up to date.

• Principle of limitation of the conservation period: personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of its processing.

• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.

• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the previous principles are met.

Categories of personal data

The categories of data processed by CARLAC CAPITAL PARTNERS SL are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. CARLAC CAPITAL PARTNERS SL undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent will not condition the use of the Website.

On occasions when the User must or can provide their data through forms to make queries, request information or for reasons related to the contentnest of the Website, you will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing for which personal data are intended

Personal data is collected and managed by CARLAC CAPITAL PARTNERS SL with the purpose of being able to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or query.

Likewise, the data may be used for commercial personalization, operational and statistical purposes, and activities specific to the corporate purpose of CARLAC CAPITAL PARTNERS SL, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User. , as well as improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 12 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will be shared with the following recipients or categories of recipients:

Google

In the event that the Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the data is transferred. intention to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of your personal data lawfully by CARLAC CAPITAL PARTNERS SL. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

CARLAC CAPITAL PARTNERS SL undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so that the security of personal data is guaranteed and destruction, loss or alteration is avoided. accidental or unlawful personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted. .

However, because CARLAC CAPITAL PARTNERS SL cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when this occurs. a breach of the security of personal data that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of personal data security is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, preserved or otherwise processed, or unauthorized communication or access to said data.

The personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the data is made accessible. information.

Rights derived from the processing of personal data

The User has over CARLAC CAPITAL PARTNERS SL and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Law.and Organic 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the User's right to obtain confirmation of whether or not CARLAC CAPITAL PARTNERS SL is processing their personal data and, if so, to obtain information about their specific personal data and the processing that CARLAC CAPITAL PARTNERS SL has carried out. made or carried out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned thereof.

• Right to rectification: This is the User's right to have their personal data modified that turns out to be inaccurate or, taking into account the purposes of the processing, incomplete.

• Right to deletion ("the right to be forgotten"): It is the User's right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or treated; The User has withdrawn his or her consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible who are processing the personal data of the interested party's request to delete any link to those personal data.

• Right to limit processing: It is the User's right to limit the processing of their personal data. The User has the right to obtain the limitation of processing when he challenges the accuracy of his personal data; the treatment is illicit; The Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.

• Right to data portability: If the processing is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit it to another. responsible for the treatment. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.

• Right to object: It is the User's right not to have their personal data processed or to have their processing ceased by CARLAC CAPITAL PARTNERS SL.

• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including the preparation of profiles. profiles, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "RGPD-https://carlac-capital.com/", specifying:

• Name, surname of the User and copy of the DNI. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other legally valid means that proves identity.

• Request with the specific reasons for the request or information you want to access.

• Address for notification purposes.

• Date and signature of the applicant.

• Any document that proves the request you make.

This application and any other attached document may be sent to the following address and/or email:

CARLAC CAPITAL PARTNERS SL (hereinafter Carlac Capital) with address at Calle Velázquez 150, 28002, Madrid with CIF B88093810

Links to third party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than CARLAC CAPITAL PARTNERS SL, and which are therefore not operated by CARLAC CAPITAL PARTNERS SL. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the supervisory authority

In the event that the User considers that there is a problem or violation of current regulations in the way in which their personal data is being processed,You will have the right to effective judicial protection and to file a claim with a supervisory authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he accepts the processing of his personal data so that the Data Controller can proceed with it in the form, during the deadlines and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

CARLAC CAPITAL PARTNERS SL reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the freedom circulation of these data (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.