WEBSITE PRIVACY POLICY: CASER VALORES E INVERSIONES
Version: 02 of 02 February 2023
Below is the privacy policy (hereinafter, the “website privacy policy” or the policy) that governs the website www.caserasesoresfinancieros.es (hereinafter, the “Platform”), whose owner is CASER VALORES E INVERSIONES AV, S.A.U. (hereinafter, “CASER VALORES E INVERSIONES” or “we”), an entity with registered address at Plaza de la Lealtad, 4– 28014 – Madrid, and filed on the Companies Registry of Madrid in volume 37.143, on Folio 135, Section 8, Sheet number M-662977.
PLEASE READ OUR PRIVACY POLICY. IT WILL ONLY TAKE A FEW MINUTES OF YOUR TIME. IN IT, WE TRY TO EXPLAIN HOW WE PROCESS AND PROTECT YOUR PERSONAL DETAILS AND RIGHTS IN A STRAIGHTFORWARD, CLEAR AND TRANSPARENT WAY. YOUR SECURITY AND THAT OF YOUR PERSONAL DATA IS ESSENTIAL FOR CASER VALORES E INVERSIONES AND WE TAKE PROTECTING YOU PROPERLY VERY SERIOUSLY.
WHO IS THIS POLICY INTENDED FOR AND WHO IS SUBJECT TO IT?
All users of this platform, whether or not they are clients of CASER VALORES E INVERSIONES (hereinafter, either the “user” or the “users”) whose legal status is that of a natural person shall be subject to this policy. Personal data herein shall refer to all information about an identified or identifiable natural person. If you are already a client of CASER VALORES E INVERSIONES because you have entered into an agreement with us, you must also consult the information in it about the specific terms and conditions on privacy.
WHO IS THE DATA CONTROLLER IF YOU BROWSE OR USE OUR ONLINE PLATFORM?
We are the data controller of your personal data, namely:
- Full name of the entity: CASER VALORES E INVERSIONES AV, S.A.U.
- Registered address: Plaza de la Lealtad, 4– 28014 – MADRID
- Contact telephone no.: 91 762 34 42
- Contact email (general): info@caserasesoresfinancieros.es
WHO IS CASER VALORES E INVERSIONES’ DATA PROTECTION OFFICER (DPO)?
CASER VALORES E INVERSIONES has appointed a DATA PROTECTION OFFICER (DPO) who the users, if they so wish, may contact for all matters related to their personal data and to exercise their rights as provided for in the GDPR. The contact details of our DPO are as follows:
- Postal address: Avda. de Burgos, 109 – 28050 – Madrid (España)
- Email: dpogrupocaser@caser.es
PROCESSING OF PERSONAL DATA SUBMITTED ON THE PLATFORM
| Purpose of processing | Additional information | Categories of personal data | Legal basis | Storage period |
|---|---|---|---|---|
| Browsing the website | You are allowed to access the information and contents posted on it. We suggest that you consult the documents made available by the Spanish Data Protection Agency (AEPD) about recommendations for the Users to minimise the risks to their privacy as a result of browsing the Internet and the information about IT security. Furthermore, if you browse our Website, you are hereby informed that we shall process your personal data for analytical, advertising and statistical purposes, provided you have accepted the relevant cookies as explained in the Cookies Policy made available for this purpose, pursuant to which you may change your preference settings in relation to the processing of your personal data. | Information about your browsing habits (website browsing information collected by cookies, websites that you visit, connection time, etc.). | Your consent, specifically, should you have accepted or consented to the use of cookies, as required by our Cookies Policy (as per art. 6.1 a of the GDPR). Either CASER VALORES E INVERSIONES or third parties, as the case may be, shall be entitled to exercise their legitimate interest to ensure the technical usability, management, maintenance, development and evolution of the Website, its tools, network and associated information systems (as per art. 6.1 a of the GDPR). | Your personal data shall be stored for the time absolutely necessary to enable you to browse and use our Website and its contents. In respect of the data associated with your browsing profile, in line with the analytical cookies that you have accepted, you must review the section on their lifetime (see the Cookies Policy). |
| Handling your enquiries and requests | To do so, there is a contact form on the “Contact us” section of the platform. |
| Your consent. | For the time strictly required to resolve or respond to them. |
| Handling your claims. | To do so, there is a customer service form on the platform’s “Customer Service” section. |
| Your consent and, as the case may be, the execution of precontractual terms and conditions at the request of the user/data subject. | For the minimum time required to properly handle your claims or, if they entailed the performance of pre-contractual terms and conditions at your request or the execution of an agreement with CASER VALORES E INVERSIONES, your personal data shall be stored for the time required to duly perform such pre-contractual terms and conditions or a service agreement between the parties. |
| Managing your access to the digital client channel. | Through the channel enabled on the platform under the “Clients” section. | Identification details (ID number). | The execution of an agreement entered into with CASER VALORES E INVERSIONES. | For the terms required for the performance of an agreement between the parties (term of the agreement between the parties). Furthermore, whenever enforceable pursuant to Act 10/2010, of 28 April, on the prevention of money laundering and the financing of terrorism, your personal data may be kept on record for 10 years from the termination of a business relationship or the execution of a transaction. |
OTHER DATA PROCESSING OPERATIONS
| Purpose of processing | Additional information | Categories of personal data | Legal basis | Storage period |
|---|---|---|---|---|
| The execution and performance of an advisory agreement on investments and/or the custody, handling, receipt and discharge of orders. | Managing the advisory relationship and/or the custody, handling, receipt and discharge of orders, of which the following can be highlighted:
Under no circumstances shall automated decisions be taken in the processing of your personal data. | Identification details (ID number, address, full name, etc.). Personal details and/or social status (date of birth, place of birth, age, nationality, etc.). Academic and employment details (education, work experience, etc.). Employment details (profession, non-financial payroll details, employment history etc.). Financial and/or insurance details. Details related to transactions of goods and services (goods and services received by the data subject, compensation payments, indemnities, etc.). | The legal basis for processing these details is for executing agreements and meeting legal obligations. The processing of the personal data of Clients is essential for assessing the suitability and appropriateness of the products and services offered, as well as for entering into and performing a contractual relationship with the Broker. Furthermore, the processing of personal data is essential for the Broker to fulfil its legal obligations, amongst which the following can be highlighted:
| Your personal data shall be stored for as long as the contractual relationship is in force and shall be erased pursuant to the terms provided for by current legislation: up to a maximum of ten years in accordance with the provisions in the regulation on the prevention of money laundering. |
| Drawing up marketing profiles and sending marketing information. | In order to carry out marketing campaigns and rendering the services that best suit your profile, we shall use your personal data gathered in managing the advisory relationship and/or the custody, handling, receipt and discharge of orders as instructed by you. For these purposes, you are hereby informed that automated decisions shall not be taken based on your profile. Furthermore, we shall process your personal data in order to provide you, via any means of communication, including email, text message, MMS or similar, with marketing information about our products and services. | The categories of personal data processed are those required for managing your access to the digital client channel. In addition, the data associated with your user profile shall be processed (products and services taken out, level of satisfaction with products and services taken out, etc.). | The consent given to us by you when, for example, you accept to receive marketing messages from CASER VALORES E INVERSIONES via any medium, or when you accept the terms and conditions for taking part in a marketing campaign (art. 6.1 a of the GDPR). According to each case, fulfilling the legitimate interest shall also apply to that associated with user interest targeting (as per (art. 6.1 a of the GDPR). | Your personal data shall be processed for this purpose for as long as you do not object to this for up to two years following the termination of your relationship with the Broker. |
Whenever the legitimate basis for processing your personal data is your consent, you are reminded that you are entitled to withdraw it at any time free of charge by simply writing to us at derechosrgpdgrupocaser@caser.es.
In respect of the storage period, as a general rule, when your personal data are no longer required to the purposes for which they were collected, they shall be locked, whereby they shall only be disclosed to the competent authorities for the potential release of legal liabilities while the data are being processed, pursuant to the regulations in force at any given time, whereby they may not be used for any other purposes. Once the legal deadlines have elapsed, in the case of locked data your personal data shall be erased as provided for by current regulations, whereby they may likewise be securely anonymised if applicable by CASER VALORES E INVERSIONES (anonymised/non-personal data).
WHAT ARE THE CONSEQUENCES OF NOT PROVIDING YOUR PERSONAL DATA?
We endeavour to ask for and use the minimum amount of personal data for the personal data processing we carry out in the full discharge of our corporate purpose. The foregoing is in line with the principles contained in the regulations in force.
However, the failure to provide your personal data could give rise to preventing you from: 1) properly browsing our website (disabling technical cookies); or 2) processing your request or claim (because, for instance, you did not fill in the corresponding form properly).
In any event, the information and personal data you submit to us must, as the case may be, 1) be sufficient, even if limited, and have been provided on the platform’s forms; and 2) accurate, up-to-date and true, in order to properly check your identity and for you to access the services on the Website.
The users shall be wholly liable for the personal data and information that they submit to CASER VALORES E INVERSIONES on the platform and, if applicable, in the framework of the services they require or take out.
DO WE DISCLOSE YOUR PERSONAL DATA TO THIRD PARTIES?
As a general rule, we do not disclose your personal data to third parties, nor do we sell or provide them to third parties. However as a client of CASER VALORES E INVERSIONES, your personal data may be disclosed to the entities that make up the CASER Group to which CASER VALORES E INVERSIONES belongs, in the manner and for the purposes described in the agreements entered into with our clients, as well as to comply with the regulation on Supervision, Classification and Solvency. In accordance with the foregoing purposes, your personal data may be disclosed, if applicable, to the following recipients:
- Public authorities, particularly the Spanish Securities Commission (CNMV), as provided for by Law.
- Sub-custodian banks.
Furthermore, it is possible that certain third parties may access your personal details in rendering their services to CASER VALORES E INVERSIONES. This, for example, is the case of third-party cookies used on the platform (see the Cookies Policy).
CASER VALORES E INVERSIONES uses a number of data processors for processing the personal data under its control that are permitted to access them, such as trusted service providers, to the extent that this is strictly necessary for them to render the services subcontracted to them. These data processors operate under service agreements subject to the terms and conditions and safeguards contained in article 28 of the GDPR, over which CASER VALORES E INVERSIONES conducts the controls, inspections and audits required in respect of this matter in order to check that such data processors strictly comply with the agreements signed for this purpose and with the regulations in force.
ARE YOUR PERSONAL DATA SUBJECT TO INTERNATIONAL TRANSFERS?
You are hereby informed that, as a general rule, no international transfers of your personal data have been anticipated, with regard to which CASER VALORES E INVERSIONES has put the measures and safeguards in place pursuant to current regulations on personal data protection. Notwithstanding the foregoing, you can find information about the use of cookies by third parties that could make international transfers of personal data in our Cookies Policy. You may consult the information of the privacy policies of third parties that post cookies on this Website in our Cookies Policy.
WHAT ARE YOUR RIGHTS, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?
You may exercise your rights of data access, rectification, erasure, portability, restriction of processing and objection by writing a letter to the company’s registered address at Plaza de la Lealtad, 4 – 28014 - Madrid (put the wording “Asesoría Jurídica – Protección de Datos” on the envelope) or an email to derechosrgpdgrupocaser@caser.es, accompanied by, should you have to prove your identity, a copy of your national identity document or similar document (passport, NIE, etc.).
You are likewise informed that should you consider that matters related to your personal data have not been duly dealt with, you may lodge a claim with the competent supervisory authority, in this case, the Spanish Data Protection Agency (AEPD). For further information, you may visit its website at www.aepd.es.
However, we recommend that before submitting any reports or claims to the AEPD that you contact us, specifically, CASER VALORES E INVERSIONES’ Data Protection Officer (dpogrupocaser@caser.es), in order to review any given situation and attempt, if possible, to seek an effective, amicable outcome.
ARE THERE SECURITY MEASURES IN PLACE TO PROTECT YOUR PERSONAL DATA?
Given the nature, scope, context and purposes of processing your personal data, in addition to the risks of varying probability and seriousness for your rights and freedoms, CASER VALORES E INVERSIONES uses (and shall use) the appropriate technical and organisational measures to properly safeguard and protect your personal data in line with privacy standards by design and by default, in addition to using a system that takes a risk-centred approach that shall be reviewed and updated by CASER VALORES E INVERSIONES whenever necessary. The use of Hypertext Transfer Protocol Secure (HTTPS) on our platform delivers additional safeguards for the security of your personal data.
TERM AND AMENDMENTS TO THE PRIVACY POLICY
This policy entered into force on 15 February 2023.
CASER VALORES E INVERSIONES reserves the right to amend this policy to adapt it to future legislative, procedural and judicial changes that may be introduced, or on technical, operational, commercial, corporate and business grounds, in which case you shall be notified a reasonable time in advance of such changes whenever possible. In any event, it is recommended that you read this policy carefully every time you access this platform, as any amendments to it shall be published in it.