PRIVACY POLICY

Latest update date:  February 20, 2024

PURPOSE

This privacy policy governs personal data processing carried out by means of the STELLUM CAPITAL investor portal accessed via the website https://stellumcapital.com (hereinafter referred to as the “Website“).

DATA CONTROLLER

The data controller responsible for personal data processing carried out through the website is: STELLUM GESTORA DE ACTIVOS, S.G.E.I.C., S.A.U. (hereinafter referred to as “STELLUM CAPITAL”).

Registered Office: Calle Zuatzu, Edificio Urola, Local 1, planta baja (20018) Donostia-San Sebastián.

TAX ID NO.: A-44598795

E-mail: info@stellumcapital.com

DATA PROTECTION OFFICER

Inveready Asset Management, S.G.E.I.C., S.A.

Address: Calle Zuatzu 7, Edificio Urola, bajo 1, 20018 SAN SEBASTIÁN.

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

PERSONAL DATA

STELLUM CAPITAL will only collect personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed, as appropriate in each case.

The user guarantees the authenticity of the data communicated and shall be solely responsible for any false or inaccurate information.

PURPOSES OF PROCESSING

Personal data will be processed by the data controller for the following purposes, as applicable in each case:

  • Management of registration, maintenance and deregistration of the STELLUM CAPITAL investor portal user of this website.
  • Commercial and administrative management of the existing business relationship, including the issuance and management of the corresponding business documentation.
  • Business relationship maintenance with the interested party or with the company or organisation he/she works for or contributes to.
  • Prevention, detection and control of abuse and fraud committed on or through the website.
  • Management of compliance with the legally stipulated obligations.

 

PROCESSING LEGITIMACY

The legal basis for personal data processing will be the consent of the user, in the event that it has been granted for the following purpose:

  • Management of registration, maintenance and deregistration of the STELLUM CAPITAL investor portal user of this website.

The user has the right to withdraw consent at any time, without affecting the legitimacy of the processing prior to its withdrawal.

The legal basis for personal data processing shall be the fulfilment of a legal obligation, in the event it has been provided for the following purposes:

  • Commercial and administrative management of the existing business relationship, including the issuance and management of the corresponding business documentation.
  • Management of compliance with the legally stipulated obligations.

Personal data processing according to the aforementioned purposes is necessary for STELLUM CAPITAL to comply with its obligations under the applicable law.

On the other hand, the legal basis for personal data processing shall be the performance of the contract, in the event that it has been provided for the following purpose:

  • Commercial and administrative management of the existing business relationship, including the issuance and management of the corresponding business documentation.

Personal data processing according to the aforementioned purpose is necessary in order to be able to enter into and execute the contract between STELLUM CAPITAL and the investors.

In conclusion, the legal basis for personal data processing shall be the legitimate interest of the data controller, in the event that it has been provided for the following purposes:

  • Business relationship maintenance with the interested party or with the company or organisation he/she works for or contributes to. The legitimate interest of the data controller is acknowledged by the applicable regulations.
  • Prevention, detection and control of abuse and fraud committed on or through the website. The legitimate interest is based on the data controller’s desire to maintain the website as a secure site.

RECIPIENTS

STELLUM CAPITAL will not communicate personal data to third parties, except in case of legal obligation and to subcontracted third parties.

STELLUM CAPITAL may be required to communicate personal data to the relevant public bodies, by virtue of a regulatory provision or a request.

International transfer (outside the European Economic Area) is not foreseen, except for storage purposes, and in any case on the basis of the existence of an adequacy decision, based on the existence of adequate guarantees stipulated by the regulations, as well as entities adhering to the EU-US Data Privacy Framework agreement: https://www.dataprivacyframework.gov/

For further information and to obtain a copy of these guarantees, please contact the Data Protection Officer at dpo@stellumcapital.com.

RETENTION PERIODS

If the legal basis for data processing is the user’s consent, such data will be retained for as long as the consent is not withdrawn.

For all other legal purposes, personal data will be retained for as long as necessary to fulfil the stipulated processing purposes.

In any case, personal data will be kept for as long as the data controller can be held liable according to the applicable law and, if necessary, the data will be blocked until the corresponding limitation period has elapsed.

USERS’ RIGHTS

Please note that at any time you can exercise your rights of access, rectification, deletion, limitation, opposition and portability in relation to your personal data provided for in the regulations on data protection, by sending a letter to the Data Protection Officer at the following email address: dpo@stellumcapital.com.

In particular, you may exercise the rights set out below:

  • Access to your personal data.
  • Rectify your inaccurate or incomplete data.
  • Request the deletion of your data when, among other reasons, the data are not necessary for the purposes for which they were collected.
  • Exercise the limitation of data processing when any of the conditions provided for in the data protection regulations are met.
  • In certain circumstances and for reasons related to their particular situation in relation to data processing, data subjects may refuse the processing of their data. In these cases, STELLUM CAPITAL will cease to process the data, except for compelling legitimate reasons or for the exercise or defence of possible claims.
  • The right to contact the Data Controller, to express one’s point of view and to challenge automated decisions adopted by STELLUM CAPITAL, if applicable.
  • Request portability of one’s data.

If you disagree with the way your data is processed, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

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=es

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/es/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 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 (Donosti).