Stellum Gestora de Activos, S.G.E.I.C., S.A.U. (hereinafter, “Stellum Capital”) is a Spanish company with registered office at Calle Zuatzu 7, Edificio Urola, Local 1, planta baja, 20018, San Sebastián, registered in the Commercial Register of Guipúzcoa under Volume 3086, page SS-45494, Folio 33, Registration 1 and holder of Tax Identification Number A44598795. You can contact Stellum Capital at any time by sending an email to info@stellumcapital.com.

The general public can access news, information and events organised by Stellum Capital and certain corporate information for our partners and investors through our website, www.stellumcapital.com (hereinafter the “Website”).

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

Data controller and contact information

The data controller is: Inveready Asset Management, S.G.E.I.C., S.A.

Address: Calle Zuatzu 7, Edificio Urola, Local 1, planta baja. 20018 SAN SEBASTIÁN.

Contact details of the data controller: dpo@stellumcapital.com

Purpose of data processing

The data is processed to provide access to the online content of the Website as well as to deal with requests from users of the Website, keep a record of visits (IP addresses, browser data, country, page accessed, etc.) for statistical purposes, apply measures aimed at the security of the Website, as well as, where appropriate, send you commercial information about our products and services by electronic means.

If you fill in any of the forms, it will be necessary to provide certain personal data, which will be processed for the purpose for which they are requested.

Legitimation

The data is processed on the basis of the user’s consent in compliance with legal obligations.

Recipients and transfers

Recipients: Stellum Gestora de Activos, S.G.E.I.C., S.A.U. and INVEREADY ASSET MANAGEMENT SGEIC S.A. and group companies.

International transfer (outside the European Economic Area) is not foreseen, except for storage purposes, and in any case, based on the existence of an adequacy decision, based on the existence of adequate guarantees, as well as entities adhering to the privacy shield agreement (http://www.privacyshield.gov).

Data retention period

At least for the periods established by the applicable legislation and, in any case, for as long as the consent remains valid.

Rights of individuals

Data subjects have the right to:

  • access, rectify and erase their data
  • request portability of their data,
  • oppose the processing or request its limitation,
  • withdraw the consent given, where appropriate

To do so, they can send their request

    • By e-mail, specifying in the subject line the reference “Data protection”.
    • In writing to Calle Zuatzu 7, Edificio Urola, Local 1, planta baja. 20018 SAN SEBASTIÁN.
    • The data owner must attach a photocopy of their ID card to the request.

They may also file a complaint with the Data Protection Control Authority.

Accuracy and updating of data

The user must fill the forms with accurate, complete, and current data. The user shall not enter data corresponding to another person; it shall be presumed that the owner of the same has provided the data. The user shall be solely responsible for any direct or indirect damage or harm that may be caused to any person as a result of filling in the form with false, inaccurate, incomplete or out-of-date data or data relating to another person.

The user must communicate any modification in the data provided to keep their data duly updated.

Information security

Stellum Capital has taken all legally required measures to protect personal data; likewise, it has adopted all the technical devices within its reach to avoid the loss, misuse, alteration, access or theft of the personal data provided by the Website’s users. However, the user shall bear in mind that security measures on the Internet are not absolutely inviolable.

Web Analytics

This Website employs various analytics to understand how the public searches, accesses, and uses it. These analytics may involve collecting personal data such as IP address, connection location, browsing software or hardware information, etc. This information is not associated with users and is used to obtain statistical information on the company’s Website.

Use of third-party features and plug-ins

This Website may incorporate functions and complements provided by third parties for various purposes, such as, for example:

      • Third-party web analytics
      • Third-party maps
      • Third-party videos
      • Social media sharing
      • Favourite” “like” and “+1” buttons and the like

A third-party feature or plug-in establishes a direct connection between the user’s browser and internet domains controlled by the third party, allowing the feature to be downloaded and executed.

In addition, most third-party plug-ins collect which pages users visit to learn about their interests and to be able to provide them with tailored advertising.

Use of the Google Analytics function provided by Google, Inc.

This Website integrates the analytical functions of Google Inc. (1600 AMPHITHEATRE PARKWAY, MOUNTAIN VIEW, CALIFORNIA, USA) to learn how users search, access, and use it. To this end, when using this Website, the user’s browser establishes a direct connection to the servers of the internet domain google.com and other Google domains. This allows Google to record the user’s activity and information regarding the user’s IP address. Google Analytics uses persistent cookies to compile anonymous statistics on the use of this Website per the following privacy policy: https://www.google.com/analytics/learn/privacy.html?hl=en.

By using this Website, you consent to process data about your Google in the manner and for the purposes set out above.

Use of functions provided by Google, Inc.

This Website integrates functions of Google Inc. (1600 AMPHITHEATRE PARKWAY, MOUNTAIN VIEW, CALIFORNIA, USA), such as YouTube videos, maps and “+1” buttons. For this purpose, when using the Website, the user’s browser establishes a direct connection to the servers of the internet domain google.com and other Google domains. This allows Google to know that the user has visited the Website from your IP address. Google makes use of persistent cookies, local storage and local Flash storage on the user’s device, for various purposes, including the collection of user activity on the Internet to offer advertising tailored to your interests, per its privacy policies: http://www.google.es/intl/en/policies/privacy/.

By using this Website, you consent to process data about your Google in the manner and for the purposes set out above.
Applicable law and competent jurisdiction

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