Privacy Policy

Introduction

The purpose of this Privacy Policy is to inform, on behalf of ELONA CAPITAL PARTNERS SGEIC, S.A. (hereinafter, the “Entity”), in accordance with the applicable regulations, about the processing of personal data collected through the website https://www.elonacapital.com (hereinafter, the “Website”).

Accessing and using the Website and/or its subdomains grants user status to anyone who does so (hereinafter, the “User”) and implies knowledge of and acceptance of all the conditions included in this Privacy Policy.

The Entity is transparent about what it does with the User’s personal data, so that they understand the implications of the uses we carry out or the rights they have in relation to their data. ELONA CAPITAL PARTNERS SGEIC, S.A. provides the User with all the information in this Privacy Policy permanently, which the User can consult whenever they deem it appropriate.

I. Who processes personal data?

The data controller responsible for your personal data processing (hereinafter the “Controller”) is:

ELONA CAPITAL PARTNERS SGEIC, S.A. (the Entity)

VAT Number: A67697110

CNMV Registration Number: 201

Address: C/ Diego de León, 9, 1°C 28006, Madrid

Data Protection Officer: dpo@elonacapital.com

The Controller has established this Privacy Policy, which covers all aspects related to the processing of your personal data through our Website.

As a User and data subject, we inform you that your personal data will be incorporated into the processing called “WEBSITE” in the Controller’s Register of Activities.

The personal data requested by the Entity from the User through the Website are generally mandatory (unless otherwise specified in the required field) to fulfill the established purposes. Therefore, if the User does not provide or does not do so correctly, the Entity will not be able to fulfill the User’s request, without prejudice to freely accessing the content of the Website.

For more information or clarification of any doubts regarding the processing of the User’s personal data, the User can write to the Entity at the postal address or email address indicated in this section. Additionally, the User can consult the website of the Spanish Data Protection Agency (Agencia Española de Protección de Datos) at https://www.agpd.es/portalwebAGPD/index-ides-idphp.php

II. What is the purpose of processing the User’s personal data?

The personal data provided by the User through the Website are processed by the Controller for the following purposes

  • To address inquiries, requests, and doubts made by the User through the contact form on the Website.
  • To manage the sending and receiving of resumes from potential candidates to be part of internal selection processes of the Entity.

III. What personal data of the User are processed by the Entity?

Through the Website, the Entity collects the following categories of personal data:

  • Contact information: address, email address, and phone number.
  • Technical data: Internet Protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as other technologies you use on your devices to access the Website.
  • Usage data: relevant information about your use of our website.
  • Tracking data: information that we or third parties collect about you through the use of cookies and similar tracking technologies. We do not collect any personal data belonging to special categories of data.

IV. What is the Entity’s legal basis for processing the User’s data?

The processing of the User’s personal data is based on the following legal grounds:

  • Execution of the investment agreement with the Entity and the proper provision of service.
  • Management of the development and execution of the investment agreement and any services you have acquired, to address your inquiries, suggestions, or requests and to communicate your personal data to the Entity’s providers, whenever necessary for the provision of the service.
  • Compliance with legal obligations by the Controller. For fraud prevention, communication of your data to Public Administrations, and addressing possible third parties.
  • Express consent of the User by checking the corresponding box, for the submission of the contact form, as well as the submission of curriculum vitae.

V. To whom will the Entity communicate the User’s personal data?

The User’s personal data may eventually be communicated to the Entity’s providers when such communication is necessary for the proper provision of the service, specifically:

  • Providers of hosting, storage, and data processing services.
  • Providers of legal, consulting, or auditing services, external lawyers, consultants, or auditors.

In addition, the User’s personal data may be communicated to Public Administrations, whenever necessary for compliance with the Entity’s legal obligations, or to address possible claims from third parties, by the Controller.

Since some of the Entity’s service providers have a global nature, the processing of the User’s personal data by them may involve international transfers of the User’s data outside the European Economic Area. In the case of international transfers, the Entity ensures that they are carried out with the security required by the applicable data protection legislation and following the instructions of the Spanish Data Protection Agency (AEPD). For more information, the User can visit the following link: https://www.aepd.es/es/derechos-y-deberes/cumple-tus-deberes/medidas-de-cumplimiento/transferencias-internacionales.

VI. How long does the Entity retain the User’s personal data?

The Entity will retain the user’s data as a client for the time necessary for the provision of the service. Subsequently, this personal data will be kept blocked and only available to the competent authorities until the responsibilities arising from the processing prescribe, after which they will be securely deleted, or anonymized so that they can continue to be used for analytical purposes.

The Entity will retain the User’s data as a user of the Website until the User requests deregistration.

The Entity will retain the User’s curriculum vitae, which has been sent to them, for the time necessary to conduct potential selection processes. In order to keep it updated, the Entity may request the User, whenever interested, to submit an updated version, in which case the Entity will proceed to delete the previous version and retain only the updated version.

VII. What rights does the User have?

The User may exercise the following rights, at any time and free of charge:

  • Request the deletion of their data.
  • Revoke consent for the processing of their data, in case it has been granted to the Entity, for example, for sending commercial communications.
  • Request the limitation of the processing of their data when one of the conditions provided for in the regulations is met.
  • Request data portability.
  • Object to the processing of their data, in case the Entity is using their personal data to send them commercial communications based on the legitimate interest of the Entity.
  • File a complaint regarding the protection of personal data with the Spanish Data Protection Agency (http://www.aepd.es).

To exercise these rights, the User will have the option to contact the Entity through a written or email request, addressed to the physical or email address indicated in Section 1 of this Privacy Policy, attaching a copy of their identity document, with the reference “Data Protection”.

The User should be aware that the security of computer systems is never absolute. When personal data is provided over the internet, such information may be collected and processed by unauthorized third parties without your consent.

VIII. User Responsibility

By providing their personal data through the Entity’s forms, the User declares that they are of legal age and that the personal data provided are accurate, true, complete, and up-to-date. For these purposes, the User is responsible for the accuracy of all personal data provided to the Entity and must keep the provided information properly updated to reflect their current situation.

Furthermore, the User guarantees that they have informed third parties whose personal data they may provide to the Entity, and if they do so, about the aspects related to the processing of their personal data contained in this Privacy Policy. Likewise, the User guarantees that they have obtained their explicit authorization to provide their personal data to the Entity for the indicated purposes.

IX. Links to Third-Party Websites

The Website may include links to other websites, plugins, and third-party applications. Clicking on those links or enabling those connections may allow third parties to collect or share data related to the User. The processing of personal data carried out by the owners of these websites is not included within the scope of this Privacy Policy. Therefore, the Entity has no responsibility or control over the information collected by third parties or over the protection and privacy of the information that the User provides through such websites. The Entity recommends that the User carefully review the privacy policies of all third-party websites to understand how they collect and share User information.

X. Security Measures

The Entity treats the User’s personal data confidentially and is committed to maintaining the duty of secrecy regarding them, adopting at all times the necessary technical and organizational measures to guarantee the security of their data and thus prevent possible alterations, losses, destruction, unauthorized processing, or access, according to the state of the art, the nature of the data stored and their processing, and the risks to which they are exposed.

Likewise, all the Entity’s service providers responsible for processing data enter into the corresponding contract with the Entity to ensure, to the extent possible, that they comply with the current data protection regulations.

XI. Updating the Privacy Policy

The Entity may update this Privacy Policy due to regulatory changes, recommendations from competent authorities, or changes in the processing of your personal data. Whenever such updates are made, the User will find the latest version of the privacy policy here.