PRIVACY POLICY

Last updated: 07-10-2021

This policy expresses how the personal information of all persons who interact with AGLAIA CAPITAL S.L.U. through this website will be treated and protected. Please, you must read all the sections of the Legal Notice, the Cookies Policy, if applicable, and this Privacy Policy before using this website.

In accordance with the provisions of Regulation EU 2016/679, of the European Parliament and of the Council of April 27, 2016 (RGPD) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, AGLAIA CAPITAL S.L.U., informs you that, by accepting this Privacy Policy, you give your express, informed, free and unequivocal consent so that the data you provide, and on which the security measures and the technical and organizational provisions provided for in current regulations are applied are processed by Aglaia Capital DeFi Platform SL, as the data controller.

The personal data that we may collect directly from the interested party through www.aglaiacapital.com will be treated confidentially and will be incorporated into the corresponding treatment activity owned by AGLAIA CAPITAL S.L.U.

ADDITIONAL INFORMATION ABOUT OUR DATA PROTECTION POLICY

Common questions for all treatment activities:

WHO IS RESPONSIBLE FOR THIS WEBSITE?

Identity of the person in charge: AGLAIA CAPITAL S.L.U.

TAX Number.: ESB88311105

Address: Calle José Ortega y Gasset, 22, 5º, CP 28006 Madrid, Spain

Email: aglaia@aglaiacapital.com

Phone: +34 910472000

WHAT PERSONAL DATA IS COLLECTED ON THIS WEBSITE?

For the purposes established in this Privacy Policy, AGLAIA CAPITAL S.L.U. collects and processes the personal data detailed below, which will depend on the different products or services requested on this Website: Identification data: name, surname.

Contact details: postal address, email, mobile phone number.

Contractual data: data of contractual operations, DNI, products and services purchased, financial operations, payment data.

Navigation data: IP address, type and identification of the device, type of browser, domain through which you access the Website, browsing data, activity on the Website.

ON WHAT LEGAL BASIS ARE THESE DATA PROCESSED?

We treat your personal data with the following legal bases:

• The execution of a contract with AGLAIA CAPITAL S.L.U., for the contracting of services and / or products and management of the requested services.

• The user’s consent in relation to contact, subscription to content and sending commercial communications, via mail, cookies or messaging systems.

• The legitimate interest of the person responsible for the treatment to protect the users of the AGLAIA CAPITAL S.L.U. website from abuse and fraud in the use of our services.

FOR WHAT PURPOSES WILL WE TREAT YOUR DATA?

On this website, there may be different forms. In each of them, the information we collect will be used as follows:

Content subscription forms: The data provided will be used exclusively to activate the subscription, send newsletters and keep you updated on news and specific offers, exclusive to our subscribers.

Comments form: The personal data entered in the form to insert these comments will be used exclusively to moderate and publish them.

Contact form: In the forms for making queries, suggestions or professional contact, the email address will be used to respond and send the information that the user requires through the web.

Registration form: In this case, we will request your personal data so that you can create an account in our system and be able to access its functionalities.

Sales form: We will process your data to manage the purchase of our products and / or services, including the management of the order, payment and all operations related to the contracting of the service or product chosen. This includes sending follow-up emails, responses, invoices, receipts, etc.

TIME OF CONSERVATION OF PERSONAL DATA

The personal data provided will be kept for the shortest possible time taking into account the reasons why the processing of the data is needed, as well as the legal obligations to keep the data for a certain time, such as labour, tax or anti-fraud legislation that require the retention of personal data for a certain period or as long as the data subject does not withdraw his consent.

Subsequently, the data will be deleted in accordance with the provisions of the data protection regulations, which implies its blocking, being available only at the request of Judges and Courts, the Public Prosecutor’s Office or the competent Public Administrations during the limitation period of the actions that may arise and, after this, they will be completely deleted.

Customer data: The period of conservation of personal data will vary depending on the service that the client hires. In any case, it will be the minimum necessary, being able to be maintained until:- 4 years: Arts. 66 and ss. General Tax Law (accounting books…).

– 5 years: Art. 1964 of the Civil Code (personal actions without special term).- 6 years: Art. 30 of the Commercial Code (accounting books, invoices …). – 10 years: Article 25 of the Law on the Prevention of Money Laundering and Financing of Terrorism. Subscriber or registration data: From the time the user gives his consent until he withdraws it.

WHAT ARE YOUR RIGHTS REGARDING THE USE OF YOUR DATA?

Anyone has the right to obtain confirmation as to whether AGLAIA CAPITAL S.L.U. is processing personal data concerning them or not. Interested persons have the right to:

• Request access to personal data relating to the interested party.

• Request its rectification or deletion.

• Request cancellation.

• Request the limitation of your treatment.

• Object to the processing.

• Request data portability. If you have given your consent for a specific purpose, you have the right to withdraw the consent granted at any time, without affecting the legality of the treatment based on the consent prior to its withdrawal. In the event that you feel that your rights regarding the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you can file a claim with the Control Authority in matters of Data Protection. To exercise these rights, you can write to aglaia@aglaiacapital.com. Forms also can be presented in person or sent by letter to the contact addresses of the responsible indicated above. In case of acting through legal representation, you must also provide a DNI and a document accrediting the representation of the representative.

It will be necessary to provide a photocopy of the DNI or equivalent document that proves the identity and is considered valid in law, in those cases in which the person responsible for the treatment has doubts about your identity.

NOTIFICATION AND DECLARATION OF GAPS

In AGLAIA CAPITAL S.L.U. we assume security measures appropriate to the level of risk to protect personal information against loss, misuse and unauthorized access, its disclosure, alteration and destruction, taking into account the risks involved in the processing and nature of personal information; however, if AGLAIA CAPITAL S.L.U. determines that the personal data it processes have been misappropriated, exposed by a security breach or acquired incorrectly by a third party, AGLAIA CAPITAL S.L.U. will act immediately taking into account the provisions of the RGPD and the competent data protection authorities.

All of them will have signed a contract for the provision of services that obliges them to maintain the same level of privacy that applies to the treatments carried out on this website in accordance with current data protection regulations.

DATA SECRECY AND SECURITY

AGLAIA CAPITAL S.L.U. undertakes to the use and processing of the user’s personal data, respecting its confidentiality, in accordance with the purpose of those; as well as to comply with its obligation to save them and adopt all measures to avoid alteration, loss, treatment or unauthorized access, in accordance with the provisions of current data protection regulations.

AGLAIA CAPITAL S.L.U. cannot guarantee the absolute impregnableness of the Internet, nor, therefore, the violation of data through fraudulent access to them by third parties. With regard to the confidentiality of the processing, AGLAIA CAPITAL S.L.U. will ensure that any person who is authorized by AGLAIA CAPITAL S.L.U. to process the client’s data (including its staff, collaborators and providers), is under the due obligation of confidentiality (whether a contractual or legal duty).

ACCURACY AND VERACITY OF THE DATA

As a user, you are solely responsible for the veracity and correctness of the data you send us, exonerating AGLAIA CAPITAL S.L.U. from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated.

PERSONAL DATA OF THIRD PARTIES

In the event that the personal data provided belonged to a third party, as a user you guarantee that you have informed said third party of this Privacy Policy and have obtained their authorization to provide their data to AGLAIA CAPITAL S.L.U. for the purposes indicated. Likewise, you guarantee that the data provided are accurate and updated, being responsible for any damage, direct or indirect, that may be caused as a result of the breach of such obligation.

CHANGES TO THE PRIVACY POLICY

AGLAIA CAPITAL S.L.U. reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as well as to industry practices. In such cases, it will announce on this page the changes introduced with reasonable anticipation of its implementation.

ADDITIONAL INFORMATION ON DATA PROTECTION

If you need additional information on data protection, you can send us an email to aglaia@aglaiacapital.com or a communication addressed to Calle José Ortega y Gasset, 22, 5o, CP 28006 Madrid and, depending on the type of relationship you have with our entity and the processing of personal data we carry out, we will provide you with the corresponding additional information.

ADDITIONAL INFORMATION ABOUT OUR DATA PROTECTION POLICY

Common questions for all treatment activities:

Who is responsible for the processing of your data?

Responsible for the data: AGLAIA CAPITAL S.L.U.

Document number: ES B88311105

Fiscal address: Calle José Ortega y Gasset, 22, 5º, CP 28006 Madrid, Spain

Telephone: + 34 910472000

Email: aglaia@aglaiacapital.com

What are your rights when you provide us with your data?

Anyone has the right to obtain confirmation on whether we are processing personal data that concerns them. In this sense, you have the right to request:

Access: The person who provides us with their data will have the right to obtain confirmation from the data controller whether or not the data concerning them is being processed, as well as detailed information about certain aspects of the treatment that is being carried out
Rectification: The person who provides us with their data will have the right to obtain the rectification of inaccurate personal data that concerns them or to have incomplete data completed
Deletion: The person who provides us with their data will have the right to request the deletion of their personal data; in any case, the deletion will be subject to the limits established in the regulatory standard
Limitation of your treatment: The person who provides us with your data will have the right to request the limitation of the treatment of their personal data
Opposition to the treatment: In certain circumstances, and for reasons related to your particular situation, the people who provide us with your data may oppose the treatment of the same. The entity will stop treating them, except for legitimate, imperative reasons, or the exercise or defense of possible claims
Right to the portability of your data: The person who provides us with their data will have the right to receive the personal data that is incumbent on them, which they have provided to the person responsible for the treatment, in a structured format, of common use and machine readable, as well as to transmit them to any other person who may be responsible for the treatment

You can exercise the aforementioned rights by contacting the responsible person. To do this, you can use the contact information provided at the beginning of this document. If you wish to obtain additional information regarding the exercise of your rights, you can also contact the Spanish Agency for Data Protection (AEPD). Likewise, we inform you that, and if you consider it appropriate, you have the right to withdraw the consent granted for any specific purpose at any time, without affecting the legality of the treatment, based on the consent prior to its withdrawal. In the event that you understand that your rights have not been adequately addressed, you can file a claim with the Spanish Agency for Data Protection (C / Jorge Juan, 6 – 28001 Madrid or at www.agpd.es).

Specific questions for each treatment activity:

TREATMENT OF SECURITY GAPS

For what purpose do we process your personal data?

Management and notification of security breaches

For how long will we process your data?

They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may derive from said purpose and the treatment of the data. Once said time has elapsed, they will be automatically canceled / suppressed.

Why do we process your data?

Legal obligation

To whom will your data be disclosed?

Other organs of public administration

TREATMENT OF COMMERCIAL COMMUNICATIONS

For what purpose do we process your personal data?

Carrying out commercial and marketing actions and communications to inform and retain customers

For how long will we process your data?

Why do we process your data?

Consent and signature of the person, legitimate interest.

To whom will your data be disclosed?

No data is transferred to third parties, except legal obligations, and to affiliated entities, or partners, or people related to the Responsible

CONTACT TREATMENT

For what purpose do we process your personal data?

Manage and attend to requests for contact, advise, consultation, information and / or professional proposals that you can send us, as well as to send you commercial information about the Entity that may be of interest to you, as well as maintaining contact for professional or business purposes with the natural persons, including those representing legal persons, with whom the entity has a relationship.

For how long will we process your data?

Why do we process your data?

Legitimate interest

To whom will your data be communicated?

No data is transferred to third parties, except legal obligations, and to affiliated entities, or partners, or people related to the Responsible.

TREATMENT OF EXERCISE OF RIGHTS

For what purpose do we process your personal data?

Management of the exercise of the rights contemplated in the data protection legislation and the complaint forms

For how long will we process your data?

They will be kept for the time necessary to resolve the claims

Why do we process your data?

Legal obligation

To whom will your data be disclosed?

Other bodies of the public administration, affiliated entities, or partners, or people related to the Responsible

SERVICE PROVIDING TREATMENT

For what purpose do we process your personal data?

Provision of our services derived from the activity, or for tax and accounting management in order to comply with legal obligations

For how long will we process your data?

They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from said purpose and the data processing. Once said time has elapsed, they will be automatically canceled / suppressed.

Why do we process your data?

Execution of a contract

To whom will your data be disclosed?

Tax administration, entities, affiliates, partners, or people directly related to the Responsible

MONEY LAUNDERING PREVENTION TREATMENT

For what purpose do we process your personal data?

Enable compliance with the Law on Prevention of Money Laundering and Terrorist Financing in relation to indications or suspicions of money laundering that may be known in the exercise of our activity

For how long will we process your data?

Why do we process your data?

Legal obligation

To whom will your data be disclosed?

Other bodies of the public administration, public registries, or entities specialized in contrasting these matters, affiliated entities, or partners, or people related to the Responsible

TREATMENT OF PROMOTION OF THE ENTITY (PUBLICATION OF IMAGES)

For what purpose do we process your personal data?

Use of personal data (image) through photographs and audiovisual material, provided within the relationship with the entity, to be published on the entity’s Website and social media profiles, films intended for commercial dissemination, printing in magazines or publications related to our sector

For how long will we process your data?

Why do we process your data?

Consent

To whom will your data be disclosed?

No data is transferred to third parties, except legal obligations, affiliated entities, or partners, or people related to the Responsible

SUPPLIER TREATMENT

For what purpose do we process your personal data?

Management of the commercial relationship with suppliers.

For how long will we process your data?

Why do we process your data?

Execution of a contract

To whom will your data be disclosed?

Tax administration, Banks, or other financial entities, affiliated entities, or partners, or people related to the Responsible

PERSONNEL SELECTION TREATMENT

For what purpose do we process your personal data?

Management of the relationship with the candidates for a job in the entity, curriculum management and participation in the selection processes for vacancies

For how long will we process your data?

Why do we process your data?

Legitimate interest

To whom will your data be disclosed?

No data is transferred to third parties, except legal obligations, or affiliated entities or partners, or people related to the Responsible