Privacy policy Bestinver SV
Privacy and data protection policy
This policy applies to the company BESTINVER SOCIEDAD DE VALORES S.A. (hereinafter, BESTINVER SV).
BESTINVER SV undertakes to process personal data pursuant to data protection regulations, in particular with the provisions of Regulation (EU) 2016/679, 27 April 2016, regarding the protection of natural persons in terms of personal data processing and the free circulation of this data and other current data protection regulations.
This Privacy Policy applies to all Users, who are understanding as visitors to the website as well as any other person who provides personal information through the different channels (hereinafter, the “User” or “Users”).
In this context, “Channels” are understood as the different channels or services that are made available to interact with BESTINVER SV, whether or not they imply registration, such as websites, applications, platforms, mailboxes, addresses or information or customer service telephone numbers, profiles on social networks, forms, events, etc.
Some online Channels may contain links to other websites, third-party applications accessible through BESTINVER Channels or, in general, any other service provided by third parties outside of BESTINVER. This Privacy Policy does not apply to them. Please also review the Privacy Policies of such third parties to familiarise with their practices. If using these other resources, services or systems, the User agrees to submit to the provisions of the corresponding use and privacy policies. BESTINVER offers Users these links and information and/or services solely for their convenience. It is the Users’ responsibility to read and accept the terms of use and privacy policies published on these websites or linked applications. Their inclusion in BESTINVER’s Channels does not imply BESTINVER’s approval.
BESTINVER SV adopts the necessary technical and organisational measures to guarantee personal data security and to prevent unauthorised alteration, loss, processing or access, taking the state of technology, the nature of the data and the risks to which they are exposed into account. The presence of the SSL certificate can also be verified by checking the website properties in your browser. A connection is secure when “https://” appears instead of “http://” in the address bar of the browser and a padlock symbol is displayed.
BESTINVER SV informs Users of the Website that their personal data may only be obtained for processing when it is adequate, pertinent and not excessive in relation to the scope and specific, explicit and legitimate purposes for which it is obtained. BESTINVER SV expresses its commitment to comply with current legislation at all times regarding data protection.
Users expressly consent that BESTINVER SV may process the personal data provided by them for the purposes expressed herein, pursuant to the terms included in this Privacy Policy. They therefore need to know that in order to register for some products/services offered through the Website, personal data will be requested.
WHO IS THE DATA CONTROLLER RESPONSIBLE FOR PROCESSING THE PERSONAL DATA?
The Data Controller responsible for processing your data is:
BESTINVER SOCIEDAD DE VALORES S.A.
Tax no.: A83563767. Registered in the Madrid Commercial Registry, Volume 9,891, Folio 169, Page M-90.299, Entry 1.
Address: C/ Velázquez núm. 140, 2º, 28006 Madrid
Telephone: 91 566 24 00
Activity: investment services company
Page: https://www.bestinver.es/securities/
Email address: infosecurities@bestinver.es
The Data Protection Delegate is a point of contact with the Data Controller for matters related to personal data processing. If you wish to do so, you may contact the Data Controller at protecciondedatos@bestinver.es.
WHAT PERSONAL DATA IS COLLECTED THROUGH THE WEBSITE?
The data provided by Users is collected as a result them visiting the Website or from their interaction with BESTINVER through the following options:
1. In some cases, personal data is obtained indirectly from Users for purely statistical purposes, in order to analyse the use made of the Website through the use of cookies, or to provide value-added services such as the location map for BESTINVER’s offices (you can consult BESTINVER’s Cookies Policy here).
2. In other cases, the personal data is provided directly by Users through the data collection forms for the purposes indicated in each form and obtaining their consent.
When personal data is collected through BESTINVER’s Channels for specific purposes, information will be previously provided to the User in a clear and unequivocal manner regarding i) the Data Controller and contact information, iii) the purposes of the specific processing and the legal basis to do so, iv) the recipients or categories of recipients, as the case may be, as well as the existence or not of international transfers, v) the conservation criteria or periods, vi) as well as your rights as the Data Subject.
Users are also solely responsible for the information provided and its veracity and legality.
BESTINVER SV processes your personal data with absolute confidentiality, undertaking to maintain its secrecy and guaranteeing the duty to safeguard it, adopting all the necessary measures to prevent unauthorised alteration, loss, processing or access, pursuant to the legal obligations that apply to you as the Data Controller responsible for processing your personal data.
FOR WHAT PURPOSE IS YOUR PERSONAL DATA PROCESSED AND WHAT IS THE LEGAL BASIS TO DO SO?
BESTINVER SV collects and processes the personal data of the Users of the aforementioned digital platforms or other channels, for different purposes.
– Standard Securities Custody and Administration Contract Form:
This data processing is necessary for formalising the agreement and providing the security custody and administration services as well as compliance with the obligations derived from it. Among others, this processing includes the provision of brokerage services (sending and receiving orders) and executing purchase or sale orders of securities owned by the CUSTOMER traded on the markets; exercising the political and economic rights of the securities; sending relevant information in relation to the securities deposited and managed, information on the entities with whom the administration has been carried out, information on the situation of your securities account, extract from the securities account and other information that is mandatory for BESTINVER SV as well as tax information for the purposes of filing the corresponding tax return; customer service and processing, if applicable, claims; voice recordings and/or your image and conservation of the telephone and/or video conversation, when so expressly indicated, in order to prove that certain actions have been carried out by the customer and to send satisfaction and quality surveys regarding the service.
The legal basis for processing this data is to maintain the contractual relations established between BESTINVER SV Users, customers and suppliers.
The data will be kept as long as the contractual relationship is maintained pursuant to the legal time periods and, once extinguished, during the prescribed period for the actions that cover the responsibilities arising from the relationship.
– Contact forms
The purpose of processing the data is to answer Users’ queries and send them the requested information. The Users’ email contact information may be used to send you information about products and services offered by BESTINVER SV or other BESTINVER entities or companies, provided that you have expressly authorised it by marking the corresponding acceptance box.
In this sense, the data provided will also be processed to attend to the requests for services and for information from Users received through any Channel, as well as to be able to process, if applicable, suggestions, claims or complaints. In these cases, your data will be collected in order to formalise the pre-contractual or contractual relationship that enables BESTINVER to efficiently provide you with its products and services.
The data you provide through cookies collected by browsing web environments is also processed.
Your email address will be pursuant to the terms indicated above and with your consent if you check the corresponding box.
The legal basis for data processing in these cases is the consent provided by Users when entering the data and marking the corresponding read and acceptance boxes, as well as completing the different forms and applications.
Data for the purpose of sending communications will be kept as long as its deletion is not requested.
The data will be kept for as long as it is necessary to attend to your queries and as long as you do not request its deletion.
– Browsing data
Browsing data will be processed pursuant to the Cookies Policy.
– Compliance with legal obligations that affect BESTINVER
Whether these are legal obligations of a commercial, fiscal, accounting or administrative nature.
The legal basis that enables BESTINVER to process the data is compliance with legal obligations.
– Money laundering prevention
For compliance with money laundering and terrorism financing prevention laws, the data is processed for the sole and exclusive purpose of adopting the appropriate due diligence measures with respect to customers. The recipients of this data are BESTINVER SV’s internal control and compliance bodies and it will not be used for purposes other than those related to the purpose mentioned above, unless the data is necessary for the ordinary management of the business relationship. There is no transfer of data to third parties, except within the framework of the legally stipulated information obligations. The right to access personal data, modify or erase it, place limitation on processing it or oppose processing it, as well as the right to data portability, does not apply to this processing.
The data will be kept for a period of ten years after the termination of the business relationship or the performance of the transaction, after which it will be deleted.
These obligations will exist and will be maintained even after the contractual relationship has ended, if necessary.
The legal basis is compliance with applicable legal obligations, in this case Law 10/2010, 28 April, on the prevention of money laundering and financing terrorism.
– Security and surveillance of the facilities
BESTINVER facilities have cameras and video surveillance systems in order to safeguard the security of property and people.
The legitimate basis for processing this data is BESTINVER SV’s legitimate interest in guaranteeing the security of its facilities.
– Managing visits and third parties
In order to control visitor, collaborator or other third-party access to the facilities, identification data may be collected in some of the Company’s facilities.
The legitimising basis is, in this case, the consent provided, as well as BESTINVER SV’s legitimate interest in guaranteeing the security of goods and people in its facilities.
– Direct marketing
In general, BESTINVER does not use Users’ personal data for direct marketing purposes, unless consent is previously obtained.
As a User you may, at any time, unsubscribe from direct marketing campaigns and oppose future processing of your personal data for these purposes by sending an email to the Data Controller’s address or by using the “unsubscribe” option included in the emails.
– Automated decisions
BESTINVER does not make automated decisions based on profiling, except when it is expressly informed and the User’s express consent is required for such purpose.
The fields on forms on the Website that are marked with an asterisk (*) are considered mandatory fields in order to be able to attend to your request or evaluate the information that you wish to provide.
FOR HOW LONG DOES BESTINVER SV KEEP USERS’ PERSONAL DATA?
In general, the data will be kept for the time necessary for the purpose for which it is collected and as long as the User does not exercise his/her rights to erasure and/or cancellation. The data will also be kept by virtue of compliance with the legal time periods pursuant to the current regulations in each case.
TO WHICH RECIPIENTS WILL USERS’ PERSONAL DATA BE COMMUNICATED?
Depending on the activity carried out by BESTINVER SV, the following data transfers are envisaged:
To service providers, whether BESTINVER companies or third parties engaged in certain cases to perform services on our behalf (e.g. IT services, administrative functions, financing, audits, etc.). In these cases, where necessary, the relevant data processing agreements are signed in accordance with data protection regulations.
To business partners, independent agents, intermediaries or brokers, financial institutions, counterparties and trade registries with which we have a relationship if such transfer is required for us to provide the services and products to you or to fulfil our contractual obligations and perform our transactions (for instance, depositary institutions, banks, custodians, issuers of securities, paying agents, exchange platforms, etc.).
To regulatory bodies, public institutions, private entities, courts and tribunals, government security forces, third party fraud prevention entities and third party trust service providers.
We may disclose your personal information (1) if we are permitted or required to do so by law or by legal proceedings (such as a court order or subpoena); (2) to law enforcement or other public officials to comply with a lawful and legitimate request; (3) when we believe it is necessary to prevent physical harm or financial loss; (4) to establish, exercise or defend our legal rights; (5) in connection with an investigation of suspected or actual fraud or unlawful conduct; or (6) with the User’s express and informed consent.
We reserve the right to transfer any information we hold about Users to a third party in the event of any actual or potential transfer or sale of all or part of our business or assets (including cases of merger, acquisition, joint venture, restructuring, assignment, dissolution or liquidation) or other structural or business operation. In this case, such third parties will be required to ensure levels of protection that are comparable to those provided by BESTINVER SV with respect to the information to be shared.
Web analytics service managers: The Site has enabled the services of Adobe Analytics provided by Adobe Systems Software Ireland Limited. Interaction with users through the use of this tool means that their personal information may be transferred to Adobe entities in countries outside the European Economic Area, such as Adobe Inc. (Adobe USA). When this occurs, Adobe relies on standard contractual clauses (SCCs) and decisions on country suitability, as appropriate, and has concluded SCCs between its relevant entities to cover these transfers.
Social media headlines: BESTINVER SV uses social networks to share our content: Interaction with users through the use of such profiles or tools involves the international transfer of analytical and technical data in relation to the Site and social network profiles. The data provided by users through such profiles are processed on the social network companies’ servers.
WHAT RIGHTS DO USERS HAVE WHEN PERSONAL DATA IS PROVIDED TO BESTINVER?
Data Subjects may exercise their rights to access, modification, erasure, portability and limitation or opposition by sending a request addressed to the Data Controller at BESTINVER’s Personal Data Protection Department: BESTINVER, “Data Protection,” C/ Juan de Mena 8, 3rd floor, 28014 Madrid or by sending an email to: protecciondedatos@bestinver.es, always providing a copy of your National ID or an official document that identifies you. You may also withdraw the consent given at any time by contacting the address indicated above, or you may also complain to the Control Authority (Spanish Data Protection Agency www.aepd.es).
VALIDITY
Any change made to the Privacy Policy and information management practices will be reflected in a timely manner and BESTINVER SV may add, modify or replace said Policy when deemed necessary to do so.
The Privacy and data protection policy is published in Spanish and English. In case of any discrepancy between versions, the Spanish version will prevail.
Last update: 5 November 2021