1. Identification of the Data Controller

In accordance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, we inform you that personal data will be processed by the following Data Controller:

AVA SOCIEDAD OPERATIVA INMOBILIARIA V S.L.U.

CIF B-88294269

Address: Calle José Ortega y Gasset, 29, 4th floor, Madrid.

Contact for the exercising of rights: protecciondedatos@arcanopartners.com

Hereafter referred to as the data controller.

2. General privacy principles

When we collect and process your personal information, we are guided by the following principles:

  • Personal data is treated in a fair, lawful and transparent manner.
  • Personal data is collected for specified, explicit and legitimate purposes and is not processed in a way that is incompatible with those purposes.
  • Personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which the processing occurs.
  • Personal data must be accurate and up to date. Inaccurate data will be updated or deleted.
  • Personal data should be kept in an identifiable format and only for what is strictly necessary.
  • Personal data is kept secure through appropriate and effective technical and organizational measures against unauthorized or unlawful processing and against accidental loss, destruction or damage, through the implementation of appropriate technical or organizational measures (“integrity and confidentiality”).
  • We are committed to the principles of data protection by design and data protection by default.

3. Purposes of personal data collection

The user’s personal data will be processed for the following purposes:

3.1 Personal data processed merely by accessing the website:

The entity collects the IP address and other data relating to the connection and its origin by simply accessing the website.

  • Purpose: To enable users to browse the website, thereby allowing access to the information and content provided therein.
  • Legal basis: The legal basis that legitimizes the processing of the IP Address is the technological necessity to enable the provision of the website.
  • Preservation periods: IP addresses will be retained for as long as permitted by applicable law.

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3.2 Contact form:

The data controller will process the data provided through the contact form, in order to respond to the contact request.

  • Purpose: To respond to specific requests or requests that users may make in this area through this contact form and send commercial communications about services, products, news or events of the Responsible related to the investment sector that may be of interest to those users who have consented.
  • Legal basis: The legal basis that legitimizes this treatment is the consent expressed at the time of sending the query through the contact form and the consent given for the receipt of commercial communications.
  • Preservation periods: The data will be processed for the time necessary to resolve the User’s request for contact. Subsequently, they will be blocked and kept for 3 years for the attention of the possible responsibilities derived from the treatment. User data processed for the purpose of sending communications will be retained until the user decides to unsubscribe from the website or by exercising their right of opposition or deletion.

4. Other processing of personal data

4.1 Cookies and similar

The data controller uses cookies and other similar mechanisms for storing and retrieving data on terminal equipment (hereinafter, cookies).

Cookies are files that are downloaded to the User’s browser and can be read later by the entity. In this way, cookies allow various functionalities, such as, for example, recognizing a User who has already accessed the website previously and being able to make analyses on the use of the web service that allow it to be improved.

However, it is not possible to ascertain the identity of the User from the cookies used by the entity, unless the User provides additional information through other means and these could be linked to the cookies that have been downloaded.

For more information, please refer to the Cookie Policy.[EPF1] 

5. Destinatarios y transferencias internacionales de datos. Profiles.

The personal data of the users of the Website may be communicated to third parties in the following cases and circumstances:

  • Public Administrations, Courts and/or Tribunals to comply with legal obligations that affect certain treatments.
  • Companies of the Arcano Partners Group when necessary to comply with the provision of the services requested by the user and/or administrative purposes.

With respect to our suppliers in charge of the treatment, with all of them is signed the mandatory contract, in accordance with the requirements of art. 28 of the GDPR.

No international data transfers will be made, as all data are processed within the European Economic Area.  No profiling will be performed.

6. Rights of the Data Subject

As a data subject, you may exercise your rights in accordance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.

The following describes your rights and how you can exercise them:

Your rightsWhat does it mean?
Right of informationYou have the right to be presented with clear, concise, transparent and easy-to-understand information about how we use your personal data and your rights.
Right of accessYou have the right to access the personal data we hold about you (subject to certain limits). .
Right of rectificationYou have the right to have your personal data rectified when it is inaccurate or no longer valid or to have it completed when it is incomplete.
Right of deletion / right to be forgottenIn certain cases, you have the right to request that your personal data be erased or deleted. It should be noted that this is not an absolute right, as we may have legal or legitimate reasons to keep them.
Right to object to receiving advertisingYou may unsubscribe from our marketing communications at any time. The easiest way to unsubscribe is to click on the “unsubscribe” link in any email or communication we send you. You can also email us at protecciondedatos@arcanopartners.com.
The right to withdraw consent at any time when data processing is based on consent.In the event that consent has been granted for any of the purposes informed and determined in the processing to which we refer, we inform you that you have the right to withdraw consent at any time, without affecting the legality of the processing based on the consent prior to its withdrawal.
Right to object to processing based on the satisfaction of legitimate interestsYou can object at any time to the processing of your data when the processing is based on the satisfaction of legitimate interests.
Right to lodge a complaint with a supervisory authorityLikewise, we inform you that when you have not obtained satisfaction in the exercise of your rights or the way to exercise them, you may file a complaint with the Control Authority. If you want to know more information about this right and how to exercise it, please contact the Spanish Data Protection Agency www.aepd.es Tel. 901 100 099 and 91.266.35.17. C/Jorge Juan,6 28001-Madrid.
Right to data portabilityYou have the right to receive the personal data concerning you and which you have provided to us in a structured format, in common use and machine readable, in order to be able to transmit this to other data controllers, when the processing is based on the execution of a contract or on your consent and the processing is done automatically.
Right to limitation of processingYou have the right to obtain the limitation of the processing of your data, although its application has two facets: You can request the suspension of the processing of your data: -When you contest the accuracy of your personal data, for a period of time that allows the data controller to verify it. -When you have objected to the processing of your personal data by the controller on the basis of legitimate interest or public interest mission, while the controller verifies whether these reasons prevail over yours. Request that the data controller retain your data: -When the processing is unlawful and you have objected to the deletion of your data and instead request the limitation of its use. -When the controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the formulation, exercise or defense of claims.
Right not to be subject to automated decisions, including profilingThis right entitles you not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly affects you. Unless such a decision is necessary for the conclusion or performance of a contract, is authorized by law or is based on consent.

How can you exercise your data protection rights?

To exercise your rights, you may contact us at protecciondedatos@arcanopartners.com or at the postal address mentioned above, specifying which of the rights you are requesting to be satisfied and proving your identity.

You can use an official form from the Spanish Data Protection Agency: https://www.aepd.es/reglamento/derechos/index.html

7. Security

The security measures adopted are those required, in accordance with the provisions of Article 32 of the GDPR. In this regard, taking into account the current state of technology, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons, the Controller has in place appropriate technical and organizational measures to ensure the level of security appropriate to the existing risk.

The Data Controller has implemented sufficient mechanisms to:

  • Ensure the ongoing confidentiality, integrity, availability and resilience of treatment systems and services.
  • Restore availability and access to personal data quickly in the event of a physical or technical incident.
  • Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to ensure the security of the processing.
  • Pseudonymize and encrypt personal data, if applicable.

8. Validity and modification of the privacy policy

The Data Controller reserves the right to modify this policy, to adapt it to future legislative, doctrinal or jurisdictional developments that may be applicable, or for technical, operational, commercial, corporate and business reasons, previously and reasonably informing users of the changes that may occur when possible.

In any case, it is recommended that you read this policy carefully each time you access the site, as any changes will be posted on the site. The Data Controller may also inform users personally and in advance of planned changes to this policy before they become effective, provided that this is technically and reasonably possible, especially when they are considered registered users or customers of the Data Controller.

9. More information

If the user has any questions about the information contained in this Privacy Policy, please send an e-mail to: protecciondedatos@arcanopartners.com.