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PRIVACY POLICY

PRIVACY POLICY

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In this policy you will find all the information relating to the treatment of your personal data and the rights that you can exercise to maintain control over them. Therefore, you should read it carefully before using this website.

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MAIN ASPECTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

 

NINA CAPITAL SGEIC, S.A. (hereinafter “NINA CAPITAL”) need to process the personal data that you provide us during the use of our website (hereinafter "the Website"), with the purpose of:

  • Answering the requests, concerns, and demands that you send us through the different means at your disposal.

  • Offering, where appropriate, products and services that may be of interest to you and that are related to our activity.

 

We may also use your data to help improve the development, maintenance and usability of the Website. In these cases, your data will be aggregated, so it will never be possible to link the information to you individually.

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In any case, we guarantee to guard all your information with the maximum security guarantees and in accordance with current legislation on the protection of personal data.

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At any time you can exercise your rights under data protection regulations or ask us any questions you have about the processing of your data by contacting us at the email info@nina.capital.

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FULL TEXT OF THE PRIVACY POLICY

 

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

 

Your personal data will be processed by the company NINA CAPITAL SGEIC, S.A. (NINA CAPITAL), with NIF A67448910 and whose business data and contact are:

 

2. WHAT ARE THE REQUIREMENTS TO PROVIDE US WITH YOUR PERSONAL DATA?

 

2.1. Minimum age. The provision of personal data through the website requires more than fourteen years of age, except in those services in which the age of majority or the assistance of the holders of parental authority or guardianship is required.

 

2.2. Truthfulness. When you provide us with your data in order to use our services, you guarantee that the data and information provided is real, truthful, up to date and belongs to you and not to third parties. In addition, you must notify us of any change in the data provided, responding in any case of the veracity and accuracy of the data provided at all times.

 

3. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?

 

Below, we explain how we process your personal information and provide you, in detail, with all relevant information regarding your privacy:

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3.1. Submission of requests through the contact form or via email:

 

a. What data do we collect?

Identifying and contact information. We collect the information you provide to us through the means we make available to you, such as, via a form linked to our Website or via email. In this sense, we will process your identification data (name and surname) and e-mail address, as well as any other information that you include in the communications you send us.

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b. What are the purposes of processing your personal data?

Answer your requests. The main purpose of the processing of these data will be to provide the information or services that you require from us. In case we wished to send you commercial communications or use your personal data for other purposes, you will be notified and, where appropriate, asked for your permission to do so.

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c. What is the legitimacy basis that allows us to process your data? Is it mandatory to provide these data?

Consent. The data provided for this purpose will be processed on the basis of your consent, which is given when, voluntarily, you contact us through the means made available to you to request information or send us other communications.

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d. How long do we keep your information?

All your personal information will be processed during the time in which your applications are being processed and for 6 months to follow up on them. At the end of this period, NINA CAPITAL will keep, blocked, this information for the periods established in the legislation to attend eventual responsibilities and to demonstrate the fulfillment of our obligations. All, unless you start a new processing.

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e. To whom do we disclose your personal information?

We do not make any additional transfers to carry out this treatment other than those indicated, in general, in point 4. To whom do we transfer your personal information?

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3.2. Navigation through our website:

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a. What data do we collect?

When you access any website, information may be collected through cookies or other tracking tools. These tools are small files that are downloaded to your device and collect data about your use of a website. Through these tools, the following information can be collected:

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  • Device Information: information about the mobile device from which you access a website, such as, the model of the device, the operating system and version, the unique identifier of the device, and the mobile network.

  • Location information: IP address, time zone, and mobile service provider, indicative of your general location.

  • User Navigation Information: information about your use of a website, such as, the frequency of use, the sections you visit, use of specific functions, etc.

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b. What are the purposes of processing personal data?

Improve and adjust the contents of a website: All the information indicated in the previous section allows to create an anonymous profile that, in relation to the navigation of the other users, at the same time allows to elaborate statistics of use that help detect errors of the website, aspects to improve in the design or the necessity to add new functions and services.

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This type of analysis also allows to understand possible needs of a website's audience which are then translated into promotional activities of services to the general public.

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​By default, our Website only uses essential cookies for technical purposes. These strictly necessary cookies enable core functionality such as security, verification of identity and network management. NINA CAPITAL may process the data to control and prevent any form of abuse of our services, such as fraudulent activities, denial of service attacks, sending spam, unauthorized access, as well as any other practice that is contrary to the Conditions of Use of the Website or endangers the security of the information or the integrity of the Website.

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This Website does contain links to third-party websites with privacy policies other than ours, which you can decide whether or not to accept when you visit them. 

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If you would like to learn more about Cookie Usage, please visit our Cookie Policy.

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c. What is the legitimacy basis that allows us to process your data? Is it mandatory to provide these data?

The information we collect through cookies and other tracking devices is based on consent, which we request when you access the Website. All this information may be used, based on our legitimate interest, to analyze and evaluate the use made of our website and to implement improvements. Note that essential cookies can’t be disabled.

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d. How long do we keep your information?

The retention periods of the information collected through cookies depend on the specific cookie. All information retention periods are specified, for each cookie, in our Cookie Policy.

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e. To whom do we disclose your personal information?

We may carry out statistical analyses either directly or through third parties who analyze such data at our request (such processing will be subject to the relevant data processing agreements which will guarantee the confidentiality and integrity of the data).

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3.3. Subscription to our newsletter and other commercial information

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a. What data do we collect?

Sending of publications of interest and commercial communications. In order to send commercial information by electronic means, we use the contact data available to us through our contractual relationship or, where applicable, in the corresponding form for subscribing subscribe to our newsletter and other commercial communications.

No profiles are created: For the sending of commercial information no automated decisions will be taken based on a profile of interests, tastes or habits of the user.

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b. What are the purposes of processing your personal data?

Sending of publications of interest and commercial communications: Your data will be used to send you commercial and promotional information and news about our activities.

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c. What is the legitimacy basis that allows us to process your data? Is it mandatory to provide these data?

When there is a prior contractual relationship between the User and NINA CAPITAL that enable the sending of promotional communications in accordance with the law. However, at the initial moment and at any time you can oppose the use of your data for promotional purposes by communicating it to info@nina.capital.

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In case there is not a contractual relationship between us, when you expressly consent to your data being used by NINA CAPITAL for promotional communications on products and/or services related to the website as well as newsletters or newsletters, by means of the express request or ticking of the corresponding boxes.

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d. How long do we keep your information?

When the sending of commercial communications is legitimized in the existing contractual relation between the parties, the information will be maintained during the time in which the same one lasts and, later, during the period established by the legislation to be able to guarantee the exercise of our legal obligations and to solve eventual disputes.

 

e. To whom do we disclose your personal information?

There are no specific transfers of your personal data to meet the purpose indicated in this section. However, we may use the services of mail marketing service providers or other advertising and marketing service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our service providers act, see point 4. To whom do we disclose your personal information? > Service Providers).

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3.3. Use of Plug-ins and actions linked to social networks.

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a. What data do we process?

When you use our services, you can share information from the Services on social networks, such as LinkedIn and Twitter, through an implemented social plug-in. If you choose to share information through a social plug-in, the following data will be transferred to the social network:

  1. Date and time of visit;

  2. The Internet address or URL for the address you are temporarily visiting;

  3. Your IP address;

  4. The browser you're using;

  5. The operating system you're using;

  6. If you are a registered user of the social network; and

  7. The information for which you have used this specific plug-in.

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b. For what purposes do we process your personal data?

The use of these options allows you to share publications, articles and other resources that you will find on the Website with other people through the social networks to which you are registered. With regard to the processing of such information, the terms and conditions of the relevant social network shall apply. We encourage you to stay informed of the purpose and scope of information collection that is done through social plug-ins.

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c. What is the legitimacy basis that allows us to process your data? Is it mandatory to provide these data?

As it is a voluntary option, this processing and the transfer of data that occurs as a consequence will be based on your consent. Please note that we have no influence on the information that the social network collects through the use of plug-ins.

 

d. How long do we keep your information?

We do not have any control over the deletion of data by the providers of the plugins, so we recommend that you read the privacy policies of the social network before using any plugin.

 

e. To whom do we disclose your personal information?

If you choose to share information through a social plug-in, the data will be transferred to the social network of your choice, in order to carry out the chosen action (for example, share the content through the social network with third parties or interact with them).

 

To this end, we inform you that the data will be transferred regardless of whether or not you are registered in the social network owned by the provider of the plugin, or even if you are not logged into it at the moment.

 

4. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

 

In general, NINA CAPITAL will not communicate your data to third parties. However, in addition to the transfers that we specifically indicate in the section in which we explain the characteristics of the different operations (point 3), we inform you of the data transfers that we can carry out, generally, that affect all the previous processing of data and their legitimate grounds.

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i. Providers of essential services to execute the service we offer you, (for example, computer hosting companies or platforms for sending commercial communications). Notwithstanding the foregoing, these entities have signed the corresponding confidentiality agreements and will only process your data according to our instructions, not being able to use them for their own purposes or apart from the service they provide us.

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Transfers to third countries outside de EU. Some of these service providers are located in the United States, so your data may be hosted on servers located outside the European Economic Area. However, all these suppliers are adhered to the framework of the Privacy Shield (https://www.privacyshield.gov/welcome), an agreement signed between the United States and the European Union whereby the American entities adhering to the program guarantee that they apply the same data protection standards as European companies.

 

ii. Public Bodies. We may disclose to the competent public authorities data and any other information in our possession or accessible through our systems when there is a legal obligation to do so, as well as when required, for example, when the purpose is to prevent or prosecute abuse of services or fraudulent activities through our Website or web page. In such cases, the personal data you provide would be kept and made available to administrative or judicial authorities.

 

We also inform you that this Privacy Policy only refers to the collection, processing and use of information (relating to personal data) by us through your interaction with our Website. Access to third party websites that you may access through links from the Website have their own privacy policies over which we have no control. Therefore, before providing them with any personal information, we recommend that you read their Privacy Policies.

 

5. WHAT ARE THE RIGHTS YOU CAN EXERCISE AS AN INTERESTED PARTY?

 

You can exercise the rights that the law guarantees you in relation to the processing of your personal data by contacting us via email info@nina.capital.

 

Any claim we receive will be resolved as soon as possible and, in any event, within 1 month of receipt. In some cases, it may be necessary to ask for a copy of your identity document or other identifying document if it is necessary to verify your identity.

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The rights that correspond to you as an interested party are the following:

 

i. Right to withdraw consent given

You can revoke your consent in connection with all processing based on it. However, we remind you that the withdrawal of consent will not affect the lawfulness of processing based on consent prior to withdrawal.

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ii. Right of access

You have the right to know which data are being processed, if any, and, if so, to obtain a copy of them, as well as to obtain information concerning: the origin and recipients of the data; the purposes for which they are processed; whether there is an automated decision-making process, including profiling; the period of data retention; and the rights provided by law.

 

iii. Right of rectification

You have the right to obtain the rectification of your personal data or to complete them when they are incomplete.

 

iv. Right of Withdrawal

You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or if we are no longer authorized to process it.

 

v. Right to data portability

You have the right to request data portability in the case of the processing of your data based on your consent or the execution of a contract, as well as when the processing is carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you can also request, where possible, that your data be transmitted directly to another company.

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vi. Right to the limitation of the treatment of your personal data

You have the right to limit the processing of your data in the following cases:

  1. When you have requested the rectification of your personal data during the period in which we verify the accuracy of them.

  2. When you consider that it is no longer necessary for us to continue processing your data and you want us to keep them for the purposes of exercising or defending claims.

  3. When you consider that we are not authorized to process your data. In that case, you can ask us to limit its use instead of requesting its deletion.

  4. In cases where there is processing based on our legitimate interest and you have exercised your right to object, you may ask us to limit the use of your data during verification of the prevalence of such interests over yours.

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vii. Right to object

You have the right to object at any time to the processing of your personal data based on our legitimate interest, including profiling.

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Termination of commercial communications: Remember that you can oppose the receipt of such communications at any time by sending an email to info@nina.capital. You can also unsubscribe from our commercial communications by following the instructions on the body foot of each electronic communication we send you.

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viii. Right to lodge a complaint with the Supervisory Authority

Remember that, at any time, and in case you consider that we have violated your right to the protection of your data, you will be able to a complaint with the corresponding Authority in Data Protection, in the case of Spain, the Spanish Data Protection Agency (www.agpd.es).

 

6. HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?

 

The security of your personal data is a priority for us. Therefore, NINA CAPITAL has implemented all necessary security measures to ensure the effective use and processing of personal data provided by the user, safeguarding the privacy, confidentiality and integrity of them.

 

Consequently, we comply with the recommended safety standards to protect your data. However, it is impossible to fully guarantee your security due to the nature of the Internet and because there may be fraudulent actions by third parties beyond our control.

 

We are committed to acting quickly and diligently if data security is compromised or compromised, and to inform you of this where relevant.

 

7. WHAT REGULATIONS AFFECT THIS PRIVACY POLICY?

 

If you would like more information on the regulations that assist you, protect and establish your rights, we make available to you the laws that have inspired this policy and are relevant to you:

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  • General Data Protection Regulation EU 216/679

 

https://www.boe.es/buscar/doc.php?id=DOUE-L-2016-80807

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  • Law 34/2002, of 11 July, on information society services and electronic commerce

 

http://www.boe.es/buscar/act.php?id=BOE-A-2002-13758

 

We can modify the content of the privacy policy at any time according to the legislative, jurisprudential or interpretation modifications of the Authorities in Data Protection that may occur.

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Therefore, we recommend that you periodically review this Privacy Policy to be informed of how your personal data is processed and protected, as well as your rights.

 

This Privacy Policy was amended on November 11th 2020.

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