Privacy Policy

1. Introduction

The purpose of this Policy is to provide information, in accordance with the provisions of applicable legislation, on the processing that will be carried out concerning the personal data collected through the website www.portobellocapital.es (hereinafter “Portobellocapital.es”).

Access to and use of Portobellocapital.es and/or its subdomains confers on you the status of user (hereinafter “User/s”) and implies knowledge and acceptance of all the conditions included in this Privacy Policy.

2. Data Controller

Identity: Portobello Capital, S.L (hereinafter “PORTOBELLO”)

Tax Identification Number: B86057122

Postal address: C/ Almagro 36, 2ª planta – Madrid 28010

Telephone: 914318071

E-mail: info@portobellocapital.es

 

3. How we collect personal data

Users are hereby informed that as a result of the use of certain features of Portobellocapital.es it is necessary to provide certain personal data that will be incorporated into files of which PORTOBELLO is the controller. Specifically, Portobellocapital.es will record the following information:

• E-mails sent: the personal data (including, but not limited to, the e-mail address) that the User provides to us by sending an e-mail to any @Portobellocapital.es addresses.

The use of the different forms and features of Portobellocapital.es is voluntary. However, some fields are necessary in order to deal with your request correctly (e.g. to manage exchanges and returns), while the inclusion of personal data in the remaining fields is voluntary and additional. The User’s failure to provide the information required in the mandatory fields may prevent PORTOBELLO from dealing with your request.

4. The purpose for which we process your data

In general, the information recorded through Portobellocapital.es that PORTOBELLO obtains from Users will be processed:

1. To handle and respond to requests submitted by Users through the forms set up on Portobellocapital.es and/or by e-mail.

5. Recipients to which we will communicate your data

PORTOBELLO does not plan to communicate your personal data to any third party, except to the Portobello Group company Capital Gestión SGECR, S.A., to fulfil the purposes indicated above, unless expressly indicated otherwise.

 

6. Legal basis for processing

We consider that we have a lawful interest to deal with the requests or queries you submit to us through the various means of contact provided. We understand that the processing of these data is also beneficial for you in that it allows us to attend you adequately and deal with the queries submitted. When you contact us, in particular, to manage any problems related to you pre-registration/registration or the service acquired through Portobellocapital.es, the processing is necessary for the performance of the contract/pre-contract. When your query is related to exercising the rights we inform you of below, the legal basis for processing your data is the compliance of legal obligations by us.

As the case may be, if you accept to receive commercial communications, the legal basis for sending them is the User’s consent.

7. How long we will store your data

The personal data collected will be stored by PORTOBELLO only for the time necessary to deal with and manage each specific request submitted by the User.

• In the case of e-mails sent: for the time necessary to deal with your request correctly.

However, at the end of that time, that data may be blocked and kept by PORTOBELLO in order to manage possible liabilities arising from the processing, only until such liabilities become statute-barred. At the end of that time, the personal data will be erased by PORTOBELLO.

8. Your rights when you provide your data to us

The User may at any time revoke the consent given for the processing of his/her data.

The User may, at any time, ask PORTOBELLO for confirmation as to whether his/her personal data are being processed by our Company and, if so, access such data. Furthermore, the User may request the rectification of inaccurate data or, as the case may be, request erasure when, among other reasons, that data are no longer necessary for the purposes for which they were collected.

Furthermore, in certain circumstances, the User may request the restriction of the processing of his/her data, in which case we will only store the data in order to exercise or defend claims. You may also object to the processing of your data in certain circumstances. PORTOBELLO will stop processing the data, except for imperative lawful reasons or to exercise or defend possible claims. Finally, where applicable, the User may exercise the right of portability in order to obtain data in electronic format or have the data transmitted to another entity.

For such purposes, the User may use the following channels, accompanying at all times a photocopy of his/her National Identity Document or any other document providing evidence of his/her identity:

• In writing to: C/ Almagro 36, 2ª planta – Madrid 28010
• By e-mail to info@portobellocapital.es

Finally, you are also informed of the right to submit a claim to the Spanish Data Protection Agency if you are aware or consider that a fact may represent a breach of applicable data protection legislation.

 

 

 

9. Updates and changes in the Privacy Policy

PORTOBELLO reserves the right to make modifications to this Privacy Policy and Users are therefore advised to check it regularly. When significant changes are made to this Privacy Policy, Users will be notified and asked to confirm their acceptance through notices on Portobellocapital.es, or through any other suitable procedure according to the circumstances.