Data Protection Policy for the Personal Data

Data Protection Policy of Altan Capital S.G.I.I.C., S.A.U. for the Personal Data of its Investors.

Who is the data controller for the personal data?

 For processing of the personal data obtained through this relationship, the data controller is Altan Capital, S.G.I.I.C., S.A.U. (the ‘Securities Brokerage’ or ‘Altan).

  • Address: Paseo de la Castellana, 91, 28046, Madrid, Spain
  • Telephone: +34 91 290 07 00
  • Email:

Altan has appointed a Data Protection Officer, who is responsible for monitoring compliance on the subject of data protection, and who can be contacted at:

What type of personal data does Altan process and how is it obtained?

Altan may engage in processing of the identification data for: (i) the Investor; (ii) the Investor’s legal representative(s); (iii) the Investor’s persons with significant control; (iv) the owners that indirectly control the Company; (v) members of the Investor’s management team; and (vi) family members and minors, if applicable. In addition, Altan may engage in processing of socio-economic data; data on reputation, solvency, risk, and fraud; and data on compliance or non-compliance with financial obligations. Here, all this data will be referred to jointly as the ‘Personal Data’. Altan obtains the Personal Data using the following means, as applicable: (i) from interviews with the Securities Brokerage or from telephone conversations, whether in relation to queries, requests, or contracting of any product, or in relation to any transaction or operation; (ii) from third-party databases maintained for purposes of combatting money laundering and fraud; (iii) from various open-access media; (iv) from the records of public entities; and finally (v) from databases on compliance or non-compliance with financial obligations. All this personal data may be stored in the Securities Brokerage’s computerised file systems. The Investor must provide, when necessary, all the data requested by the Securities Brokerage in order for the pertinent requests to be processed. Refusal to provide that data could make it impossible to manage those requests.

What is the purpose and legal basis for Altan’s processing of their personal data?

Execution of the order requested, based on the contractual relationship with the Securities Brokerage:

  • The Securities Brokerage will process the Personal Data whenever necessary to manage the pertinent requests.
  • The Securities Brokerage may also transfer the Personal Data, as necessary, to third-party depositary entities, managers, or other parties that have a contractual relationship with the funds represented. If you would like to know the identity of the depositary entities for the funds, you can obtain this information by contacting the Securities Brokerage.
  • Compliance with accounting, legal, tax-related, and administrative obligations.
  • Management of queries, suggestions, claims, and complaints.
  • The Securities Brokerage may view and process their data related to financial solvency and credit history as obtained from entities that provide services on information about financial solvency and credit, and it may also disclose data about their situation to these entities when applicable. Therefore, such personal data may be communicated to the underlying funds, co-investments or investments in other types of vehicles, to their depositary entities, as well as to the various companies that may provide them with services for the sole purpose of making possible or maintaining such investments. Likewise, the communication of said data will be carried out following all the guarantees and under all the principles of proportionality and minimisation of personal data. These entities may be located within or outside the European Union and the Investor will be periodically informed of their identity. In any case, if you would like to know more details of the information relating to such entities, you may request such information from Altan’s Data Protection Officer.
  • To prevent any fraudulent conduct, the Securities Brokerage may disclose the Investor’s Personal Data to centralised information systems, and also to entities based within the European Economic Area (‘EEA’) in which Altamar Capital Partners S.L. directly or indirectly holds an ownership interest, with further details on those entities available at the following link:

Consequently, by participating in the Investment Agreement, the Investor is aware of and accepts the aforementioned conditions.

  • Compliance with a legal obligation:
  • Also, as a result of the obligations on prevention of money laundering and financing of terrorism, the Securities Brokerage is required to formally identify the Investor’s actual professional or business activities, or those of other parties requesting products from the Securities Brokerage. The Securities Brokerage will request from the Investor any documents it considers necessary for verification of the activity declared.
  • For measures on prevention of money laundering and financing of terrorism, transfer of the Investor’s Personal Data to the entities based within the EEA in which Altamar Capital Partners S.L. directly or indirectly holds an ownership interest, with further details on those entities available at the following link:
  • Also for purposes of prevention of money laundering and financing of terrorism, collection and updating of the Investor’s personal data, either using the internal databases maintained by Grupo Altamar or from external sources.
  • Disclosure of the Investor’s Personal Data to government offices and regulatory bodies located within or outside of the EEA, when the transfer is mandatory under current legislation, for important reasons of public interest.

Legitimate Interest:

  • The Securities Brokerage may send the Investor information about its funds or other products, whether by ordinary means or electronically, and unless the Investor has expressed its opposition to this processing.
  • For administrative purposes and for coordination of activities related to its company objects involving advising and management for alternative assets, disclosure of the Investor’s Personal Data to the entities based within the EEA in which Altamar Capital Partners S.L. directly or indirectly holds an ownership interest, with further details on those entities available at the following link:

Those types of processing will take place based upon the Securities Brokerage’s legitimate interest, and in no case will this cause any restriction of the Investor’s data protection rights, since the data processed will be solely and exclusively that required for the purposes indicated. In all cases, the Investor will always be able to express opposition to this processing using the means described under the heading How can I exercise my rights on the subject of data protection?

In the case of transfers to countries outside the European Union, whose level of protection has not been recognized by the European Commission, Altan takes the appropriate safeguards established by the General Data Protection Regulation, such as the application of contractual clauses approved by the European Commission to guarantee the protection of your personal data. For further information, please contact the Altan Data Protection Officer at:

Do we process data on third parties?

The Securities Brokerage may process the personal data of third parties such as: the Investor’s legal representative(s) and persons with significant control, persons having indirect control over the Company, members of the management team, family members, and minors. The Investor is declaring that the Personal Data and information it has provided in relation to third parties is accurate and reflects their actual situation; that those third parties have been informed about disclosure of their data; and that their consent has been obtained for disclosure of their personal information during the appropriate process. In cases where the data processed is related to a minor, the Securities Brokerage will only process that information related to a minor with proper authorisation from the legal representative (mother/father/guardian).

Do we transfer your data to third-party entities, or can they gain access to it?

The Securities Brokerage will only disclose your Personal Data to:

The depositary entities of the contracted funds.

  • The entities managing the underlying funds or the funds themselves.
  • Regulatory bodies and public institutions from Spain’s national, regional, and local governments, or to other authorities that may be located within or outside of the European Economic Area when provision of data to them is required by law.
  • Courts or tribunals.
  • Collective databases on financial solvency or credit risk: these may be collective databases that record failures to comply with financial obligations or the Bank of Spain’s Risk Information Centre.
  • To prevent fraudulent conduct, Personal Data may be sent to the various companies belonging to Grupo Altamar, or to centralised information systems.

Also, the Securities Brokerage has third-party service providers that can access personal data for purposes of providing their services, such as auditors, outside experts, lawyers, consultation services, advisers, IT maintenance firms, potential buyers or investors, administrative services, and document destruction services, among others. The Securities Brokerage pre-screens these providers in accordance with criteria related to data protection compliance. It has signed agreements with all of them on that subject, and it monitors their compliance with their obligations on that subject.

How long will we store their personal data?

Any personal data to which access is given will be processed for as long as the relationship exists between the Securities Brokerage and the Investor. The Securities Brokerage will also store the personal data after the relationship has ended, but with access appropriately blocked, until the limitation periods have expired for any legal actions that could be derived from the relationship maintained with the data subject. In all cases, the Security Brokerage will store any information that the Anti-Money Laundering and Financing of Terrorism legislation obligates it to store, for a period of 10 years after termination of the business relationship or execution of the transaction.

How can I exercise my rights on the subject of data protection?

In relation to the data provided at any time, the Investor can exercise the rights to access, rectification, and erasure for that personal data, and the right to oppose or restrict processing of that data, and the right to oppose being subject to automated individual decision-making, by sending a written request to the Securities Brokerage’s Data Protection Officer / Control Department at Paseo de la Castellana, 91, 28046, Madrid, Spain, attaching a copy of the Investor’s national identification document or other official identity document. This can also be done by email, using the address:

Where can claims on the subject of data protection be submitted?

If any of the Investor’s data protection rights appear to have been violated, or for any other claim related to personal information, the Investor can write to Grupo Altamar’s Data Protection Officer to request resolution of that claim at: In all cases, the data subjects can submit a claim to the Spanish Data Protection Agency (AEPD), which is Spain’s supervisory authority on the subject of data protection: C/Jorge Juan número 6, 28001, Madrid, Spain. Tel: 901 100 099 / 91 266 35 17.

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