PRIVACY POLICY

SECOND LAYER

*Additional data protection information

This Privacy Policy describes the processing of your personal data carried out by the company “NORTIA CAPITAL INVESTMENT HOLDING, S.L.” (hereinafter, “NORTIA”) through the web portal:  https://www.nortia.com (hereinafter the “Website”).

WHO IS THE DATA CONTROLLER?

  • Identity: NORTIA CAPITAL INVESTMENT HOLDING, S.L.
  • Spanish Corporate Tax id. CIF: B58654039
  • Address: Calle Sagasta 31, 3ª pl. 28004, Madrid, España
  • Telephone no.:: +34 91 600 37 36
  • Email: protecciondatos@nortia.com

WHAT PERSONAL DATA DO WE PROCESS?

  1. Personal data that we collect. The website uses cookies (and/or similar technologies) so that, depending on your cookie settings, NORTIA may collect and process personal data. Generally, we collect and store limited personal information and anonymous aggregate statistics on all users who visit our websites, either because you actively provide us with such information or because you are simply browsing our websites. The information we collect includes the Internet Protocol (IP) address of your device, your browser software, your operating system, the date and time of access, the Internet address of the website through which you accessed our websites and also information on how you use our websites. For more information on the use and configuration of cookies (and/or similar technologies), please consult our Cookie Policy.
  2. Personal data that we collect from third parties. You may find links on our website that direct you to platforms or websites operated by third parties. Please note that we may receive the personal data you provide on third party platforms, for example, through the NORTIA pages made available to you on the website, for the purposes set forth below, or in the respective Policy of the website you visit, but primarily for informative purposes.

WHY DO WE PROCESS YOUR DATA?

NORTIA shall process your personal data for the following purposes:

  1. To comply with legal obligations, including, but not limited to, Law 10/2010 on the Prevention of Money Laundering;
  2. Where appropriate, to communicate your data to other companies of the business group to which the NORTIA Group belongs, for internal administrative purposes, including the processing of personal customer data;
  3. Depending on your cookie settings, for statistical analysis and profiling based on your browsing habits.

LEGITIMACY

The legal bases for the processing of your personal data for the purposes described above are as follows:

  1. Where applicable, your consent to statistical analysis and profiling based on your browsing habits;
  2. Where applicable, we rely on our legitimate interest to communicate your data to other companies of the group to which the NORTIA Group belongs; and
  3. To comply with the various applicable legal obligations.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

In general, NORTIA shall not communicate your personal data to third parties, except in the following cases:

  1. to competent authorities and bodies, courts, tribunals or any other third parties entitled to do so in accordance with applicable law;
  2. to other companies within the group of companies to which NORTIA belongs for internal administrative purposes, including the processing of customer personal data, as well as to business partners with whom we have business agreements, to be processed in accordance with the above-mentioned purposes.
  3. Finally, to all companies that require the data for the purpose of providing services to NORTIA, in their capacity as data processors (e.g. virtual infrastructure services, cloud computing, etc.).

Please note that some of these providers may process and store personal information on servers located outside your country of residence.

Therefore, depending on the user’s location, data transfers to other countries may occur.

In such a case, your personal data may be transferred internationally to third parties located outside the European Economic Area (“EEA”), provided that NORTIA has the authority to do so and subject to compliance with the appropriate safeguards set forth in Articles 44 to 50 of the GDPR. Such third parties shall only access the data to carry out their services on behalf of and in the name of NORTIA, under the obligation of confidentiality and always following their instructions and without at any time using such data for their own purposes and/or unauthorised purposes.

In any case, according to NORTIA’s order of preference, appropriate safeguards include, but are not limited to, the following:

  • Adequacy decision: a declaration by the European Commission that a non-EU state offers an adequate level of data protection equivalent to that provided by European data protection law, making international data transfer to a third party established in that state outside the EU possible;
  • Binding Corporate Rules: they apply to corporate groups or the union of companies engaged in a joint economic activity, which enables the flow of personal data based on a self-regulation accepted and assumed by each of the signatory entities;
  • Standard Contractual Clauses: this is signed between the exporter of the Personal Data from any of the EEA countries and a third country. It is a contractual agreement whose model has been approved and published by the European Commission and aligned with the precepts of the GDPR.

In the absence of the above, your personal data may exceptionally be transferred to a third country or international organisation, pursuant to the mechanisms that may be recognised in this respect by data protection legislation.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

NORTIA shall store your personal data for as long as necessary to fulfil the purposes set forth above (provided that you do not request their deletion or opposition through the means indicated in the section “YOUR RIGHTS”), and as indicated in NORTIA’s Cookie Policy, and shall keep them for the necessary limitation periods in accordance with the legislation that, in each case, is applicable to address any future criminal, civil, commercial and/or administrative liabilities of any kind.

YOUR RIGHTS

You may exercise a number of rights regarding the processing of your personal data at any time. These rights are inherent to each interested party and therefore cannot be waived, and are as follows:

  • Right of access: access to personal data that are processed by NORTIA, as Data Controller in accordance with Article 15 of the GDPR.
  • Right of rectification: request that NORTIA, as Data Controller, rectify certain personal data regarding the data subject in accordance with Article 16 of the GDPR.
  • Right of objection: object to any processing which is based on consent or on the existence of a legitimate interest (including, but not limited to, the sending of commercial communications) in accordance with Article 21.2 of the GDPR.In cases where the processing is based on the existence of a legitimate interest, the data subject shall have the right to request the weighting report carried out by the Data Controller. In addition, in cases in which processing is carried out for the purpose of sending own or third-party commercial information, the data subject may, free of charge and on an opt-out basis, choose to use an advertising opt-out mechanism (further information can be found here: https://www.listarobinson.es/).
  • Right of deletion: right to request to NORTIA, as Data Controller, that all or part of your personal data be deleted in accordance with Article 17 of the GDPR. Remember that while the commercial and/or contractual relationship with you remains in force, there is a series of personal data that we need to process in order to comply with the contract, so while the contract is in force we cannot delete, block or cancel them, because otherwise it would prevent us from complying with the contract.
  • Right to limitation of processing: request that the controller restrict the processing of your personal data, provided that one of the conditions set forth in Article 18 of the GDPR is met.
  • Right to portability of personal data: receive the data you have provided to NORTIA, as Data Controller, in a structured, commonly used and machine-readable format, and to transmit it to another Data Controller (or to have it transmitted directly to the new Data Controller, where technically possible), in accordance with Article 20 of the GDPR.
  • The right to withdraw the consent given to carry out the processing identified in the section “Why do we process your data?”, without such revocation having retroactive effect, in accordance with Article 7.3 of the GDPR.

These rights may be exercised by sending a request to the Data Controller’s address or by emailing protecciondatos@nortia.com, where you can obtain further information on the processing of your personal data.

We will respond to your request as soon as possible and, in any case, within the legal deadline. Likewise, you may withdraw your consent at any time by emailing protecciondatos@nortia.com, without, in any case, the withdrawal of your consent being a condition for guaranteeing the correct management of the commercial relationship.

If you believe that we have processed your Personal Data inappropriately and not in accordance with the personal data protection regulations, or if you are not satisfied with the way in which we have dealt with the exercise of your rights, you may file a complaint with the corresponding Supervisory Authority (in the case of Spain, the Spanish Data Protection Agency) at any time.

In any case, before filing a complaint, please contact by email at protecciondatos@nortia.com or by post to NORTIA’s address, as indicated in this Policy, in order to try to resolve any disagreement amicably.

Lastly, please note that you are responsible for all personal data you provide us with, as well as for their accuracy, inaccuracy, updating, validity and authenticity, including your consent to their use and/or processing. You are also responsible for the data of third parties that you provide us with and for which you are obliged to obtain their consent once you have disclosed the contents of this Policy to them, given that we have no direct contact with such third parties. You are also responsible for regularly reviewing this Policy and any updates to it.

LINKS

This website may include, feature or display links to other websites for your convenience and information. Such websites may operate independently of us. These linked sites may have their own privacy policies, which we strongly advise you to read when you visit them. Insofar as any linked websites you visit are not owned or controlled by us, we are not responsible for the content of such websites, their use or their privacy practices.

UPDATE

This Policy may be updated periodically to reflect changes in our processing of personal data. A prominent notice shall be posted on the Site to notify you of any significant changes to our Policy and the date on which the Policy was last updated shall be indicated at the bottom of the Policy.

Last update: june 2023.

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