PRIVACY POLICY

 

Introduction:

This Privacy Policy (the “Policy”) has been established by Ithaka Infrastructure Partners SGEIC, S.L. together with its affiliates, and covers all aspects of the processing of your personal data through our website www.ithaka.com (the “Website”) our social media profiles and those generated as a result of the use thereof, included, where appropriate, disclosure or international data transfers that might take place in accordance with this Policy.

Personal data is any data which is provided to us or which we obtain that can be used to identify you (“you”) or that Ithaka Infrastructure Partners SGEIC, S.L. can link to you.

 Who is responsible for processing your personal data?

For the purposes of data protection law, the data controller (hereinafter the “Controller”) of your personal data is:

Ithaka Infrastructure Partners SGEIC, S.L.

C/Velázquez 11, 1º Izq, 28001, Madrid

gdpr@ithaka.com

You are hereby informed, and consent to, the processing of data provided during the navigation of the Website

What personal data do we process?

We collect the following data through our Website and social media profiles:

  1. Identification data – name, surname, company when applicable and email address of users who request information to the Controller.
  2. Contact details – address, email address and telephone number
  3. Financial data – if and when provided – billing address, bank details, quearterly reports, annual reports, income, balance sheets, as well as any personal data related to the products or services which may be contracted.
  4. Transaction data – if and when applicable – data on investments made by you, distributions received, as well as details of the products or services contracted
  5. Curriculum vitae data -all data included in curriculum vitae which you may provide the Controller for the purposes of managing selection processes.
  6. Profile and technical date -username and password.

 

For what purpose do we process your personal data?

The personal data you provide to the Controller will be processed for the following purposes:

  1. To manage queries, requests and doubts made by you through the contact form on the Website, gdpr@ithaka.com mail address or otherwise
  2. Manage Cvs for potential candidates in selection processes.
  3. To manage your investments and the products contracted by you.
  4. We can treat your data when you interact and make use of our social media profiles, in accordance with this Policy
  5. All data collected and processed for the purposes detailed above, is necessary for the management of the Website and social media profile and, where appropriate the maintenance, development and control of the relationship with the Controller.

What is the legitimacy for processing your personal data?

The processing of your personal data is based on the following legal grounds:

  1. Your express consent to this Policy by ticking the relevant box or submitting your contact information, as well as sending your curriculum vitae
  2. Compliance with legal obligations on the part of the Controller, including but not limited to prevention of fraud and communication when required to public administrations.
  3. In relation to execution of investment agreements, other services or products contracted by you, to manage the development, execution of such agreements, manage your user profiles, attend your queries, suggestions or requests of information.

How long do we keep your personal data?

Personal data will be kept during the time necessary to fulfill the purpose for which they were provided, and for the period in which the Controller is required and/or permitted to retain them by law or regulation.

To which recipients will your personal data be disclosed?

Your persona data may be communicated to the Controllers affiliates, or external suppliers when such communication is necessary for the purpose for which they were provided. Third parties accessing your personal data will enter into contracts with us to regulate their access and conditions for the treatment of data, and their compliance with applicable data protection regulations.

In addition, your personal data may be provided to public administrations, provided that this is necessary for the fulfilment of legal or regulatory obligations.

If the processing of your personal data involves international transfers outside the European Economic Area, we will ensure that they are carried out in compliance with legal requirements, and will be carried out in compliance with applicable regulations.

What are your rights with respect to your personal data?

You can exercise the following rights with respect to your personal information:

  • Confirm whether we are processing your personal data
  • Request access to your personal data
  • Request rectification of inaccurate or incomplete data
  • Request data deletion– when they are no longer necessary dor the purposes for which they were provided, in which case the Controller will cease to process them except when legally required or when required to defend from possible claims
  • To revoke consent to processing data…

You may, under the terms established in the data protection regulations in force at any time, and in accordance with the regulations, revoke at any time the authorisation granted for the processing and transfer of personal data, as well as exercise the rights of access, rectification, deletion, opposition, right to request the limitation of the processing of your personal data, the right to portability and the right to file a complaint with the Spanish Data Protection Agency. You may do so by contacting the Controller with proof of your identity at gdpr@ithaka.com

The Controller may nevertheless retain data when legally required or when required to defend from possible claims.

Privacy policy updates:

The Controller may update this Policy due to regulatory changes, recommendation from competent authorities or changes in the processing of your personal data. Whenever updated, you will find the latest version of the Policy in our Website and, if legally applicable, will be notified to you through email or by other means.