ALTAN and the funds it manages are subject to “Law 35/2003, of 4 November, on Undertakings for Collective Investment”.
In addition to the preceding regulation issued by the Ministry of Economy and Competitiveness, the Management Company and its funds under management are subject to additional regulations and regulatory bodies.
ALTAN and the funds it manages must regularly settle and send tax returns to the Spanish Tax Agency, the body charged with managing, inspecting and collecting taxes.
Furthermore, the provisions of the “Foreign Account Tax Compliance Act” (FATCA) adopted by the United States on 1 July 2014 have entered into effect. The aim of FATCA is to facilitate the inspection and collection of tax from U.S. taxpayers in order to prevent offshore tax evasion. The funds managed by ALTAN will operate with the following Global Intermediary Identification Numbers (GIIN) for the purposes of FATCA:
- ALTAN Funds: KUQKTM.00000.SP.724
The obligations of the institutions covered by FATCA can be found in the “Agreement between the United States of America and the Kingdom of Spain to improve international tax compliance and to implement the Foreign Account Tax Compliance Act – FATCA, entered into in Madrid on 14 May 2013” and in “Ministry of Taxation and Public Administrations Order HAP/1136/2014, of 30 June, regulating certain questions related to the information obligations and due diligence requirements imposed by the provisions of the agreement between the Kingdom of Spain and the United States of America to improve international tax compliance and to implement the U.S. law on tax compliance of foreign accounts and approving the annual return of financial information on specific accounts of certain U.S. persons, model 290”.
ANTI-MONEY LAUNDERING AND TERRORIST FINANCING PREVENTION
ALTAN Management Company must comply with all requirements set forth in the regulations in effect on this matter, and in particular with “Law 10/2010, of 28 April, on anti-money laundering and the prevention of terrorist financing” and “Royal Decree 304/2014, of 5 May, approving implementation of Law 10/2010, of 28 April, on anti-money laundering and the prevention of terrorist financing.”
SEPBLAC, a body of the Bank of Spain, is in charge of performing control functions. Additionally, the Management Company is audited annually by PricewaterhouseCoopers.
PROTECTION OF PERSONAL DATA
ALTAN is in full compliance with its obligations on the subject of data protection. As part of that compliance, ALTAN has appointed a Data Protection Officer (DPO), who is responsible for overseeing all tasks carried out for the purpose of allowing compliance with the obligations derived from the data protection legislation. You can contact this person at any time at the email address firstname.lastname@example.org, or by postal mail at Paseo de la Castellana, 91, 28046, Madrid, Spain.
The primary purposes of the data processing carried out by ALTAN include processing that is required in order to allow performance of the specific agreements established, as well as processing required for compliance with the legal and tax-related obligations that could derive from the relationship with ALTAN. The clients’ personal data will only be transferred by ALTAN among the companies belonging to Grupo Altamar for commercial purposes, and only when it has its clients’ consent to do so.
In conformity with the data protection legislation, ALTAN has identified all the data processing it performs and has adopted the security measures that are necessary in order to prevent any losses or incidents.
ALTAN is committed to treating all communications that contain its clients’ personal data as confidential, although depending upon the product being contracted, personal data may be transferred to other entities. Those entities include, among others: (i) the depositary entities for the funds contracted, when applicable; (ii) regulatory bodies and public institutions from Spain’s national, regional, and local governments, or other authorities that may be located within or outside of the European Economic Area, in cases where the law requires data to be provided to them; (iii) entities from Grupo Altamar; or (iv) service providers such as those providing IT, administrative, or consultation services.
Users may exercise their rights to access, rectify, and erase for their data, along with the rest of the rights indicated in the additional information, by sending a written request, signed by the data subject and with a copy of the data subject’s national identification document or other official identity document attached, to ALTAN’s Data Protection Officer at the address indicated above.
You can also view detailed data protection information for the Depositary at “Data Protection Policy for the Depositary”.