Introduction
Indexa Capital Group S.A. (hereinafter Indexa Capital Group) is responsible for the website group.indexacapital.com, hereinafter referred to as "the website." The user should be aware that the information they provide about themselves on the website will identify them to Indexa Capital Group. We have a keen interest in protecting the personal data of users of the website and hereby inform you, through this privacy policy, about the treatment we give to them.
Who is responsible of the data treatment?
INDEXA CAPITAL GROUP, S.A. - VAT: ESA95770004
Postal Address: 35 Gran Vía Don Diego López de Haro, floor 2, 48009, Bilbao (Bizkaia), Spain.
Email: info@indexacapital.com
Phone: (+34) 91 220 72 53
Data Protection Officer:
Juan Aguado Peña - dpo@indexacapital.com - Phone: (+34) 91 220 72 53
Security measures for the protection of personal data?
Indexa Capital Group has taken the necessary technical and organisational measures to ensure that the GDPR is applied to the various processes carried out within the company, in order to protect the rights and freedoms of the user.
However, all data transfer over the Internet carries the risk of interception. Indexa Capital Group has implemented the necessary measures to minimise the risk of this happening, although the user should be aware that this is a risk over which Indexa Capital Group has no control and, therefore, cannot be held responsible.
In those web services that require user registration, a password must be chosen. The user is responsible for maintaining the confidentiality of this password, as well as for all activities that occur in the session initiated with their username and password. The user agrees to promptly notify Indexa Capital Group of any unauthorised use of their username and password or any other security breach. Indexa Capital Group will not be liable for any damages or losses that may arise due to the user's failure to comply with this obligation.
How do we collect your data?
To access some of the website's services, registration is necessary, depending on the personal data requested to carry out such registration for the service you wish to access. It will be necessary for the user to provide all the requested data in order to adequately provide the requested services.
Indexa Capital Group will use your personal data solely for the purpose of providing you with the services requested by you at all times, through the marking of the corresponding boxes for each purpose of processing.
Indexa Capital Group will not transfer users' personal data to third parties without first requesting their consent, informing them of the recipient of that data and the purpose of that possible transfer.
In order to access our services, it is necessary for the personal data provided by the user to be truthful and up-to-date at all times.
The user is responsible for the accuracy of the data provided to Indexa Capital Group, and the usurpation of identity or the provision of personal data of third parties without their express consent is expressly prohibited.
What is the purpose of processing your personal data?
Indexa Capital Group will only process personal data that are appropriate, relevant and limited to what is necessary in relation to the purposes for which they are processed. In this regard, you may provide personal data to Indexa Capital Group through the different procedures established for that purpose on the website, which will process them for the following purposes:
Website navigation
- Handling information requests and communications made through the help and information service via email. For this purpose, Indexa Capital Group will process identification and contact data. Such information is necessary to assess a potential engagement with Indexa Capital Group and therefore the application, at the user’s request, of pre-contractual measures (lawful basis art. 6.1.b of the GDPR).
- Due to the communication protocols existing on the Internet, when the website is visited, Indexa Capital Group automatically receives the IP (Internet Protocol) address assigned to your computer by your access provider. As a general rule, the IP address for the same user differs from one Internet connection to another, so it is not possible to track a particular user’s browsing habits through the website. Logging such IP address is used only for exclusively internal purposes, such as access statistics to this website. Indexa Capital Group may use cookies when browsing its websites and pages in order to optimise navigation and for statistical purposes. Cookies that are not considered necessary for browsing are subject to your consent and you may always configure the consent granted (lawful basis art. 6.1.a and b of the GDPR). You can find more information about cookies in our cookies policy.
Email support
Since an email address is provided by the user, Indexa Capital Group will also handle information requests and communications through this means. For this purpose, Indexa Capital Group will process identification and contact data, necessary for the application, at the user’s request, of pre-contractual or contractual measures (lawful basis art. 6.1.b of the GDPR).
Indexa’s legitimate interest (basis art. 6.1.f of the GDPR)
- Indexa Capital Group may inform you about other products and services, send you information relating to Indexa Capital Group or about other investment-related products and services provided by Indexa Capital Group, both by ordinary and electronic means, provided you have not objected to this processing. Within this processing, Indexa Capital Group may inform you about news relating to Indexa and its services, as well as other investment services that could be provided by other entities within Indexa Capital Group (for example, Indexa Capital AV or Bewater Asset Management SGEIC, among others). For this purpose, Indexa Capital Group will process identification data, contact data and, where applicable, financial and banking data, and data relating to your financial situation.
- Indexa Capital Group may send commercial communications tailored to your preferences or needs and carry out specific commercial profiling based on your subscription history with Indexa Capital Group, as well as information obtained directly in meetings.
- To assess and improve the service provided, we will ask for your opinion about the service provided by Indexa Capital Group. For this purpose, Indexa Capital Group will process identification and contact data.
Only if Indexa has the user’s consent (art. 6.1.a of the GDPR) will Indexa disclose the data to other entities within the same group as Indexa that could offer you another investment service (for example, Indexa Capital AV or Bewater Asset Management SGEIC, among others). For this purpose, Indexa Capital Group will process identification data, contact data and, where applicable, financial and banking data, and data relating to your financial situation.
How long do we keep your data?
Personal data provided by the user will be kept until its deletion is requested by the interested party or, where applicable, for as long as the business relationship with Indexa Capital Group is maintained or, where applicable, for the period required by law for Indexa Capital Group to retain information about its customers. When the legitimacy of data processing is based on the user's consent, we inform you of your right to withdraw it at any time through the rights exercise procedure recognised in this Privacy Policy.
To which recipients will your data be disclosed?
Indexa Capital Group may disclose personal data when required by legal obligation, to respond to claims related to the infringement by advertisements or other content of third-party rights, or for the protection of its interests, provided that these prevail over the user's rights.
Indexa Capital Group may only disclose personal data in cases not covered in the previous paragraph if it has the specific, informed, and unequivocal consent of the user.
Furthermore, we inform you that third parties may process the user's personal data on behalf of Indexa Capital Group to provide the services requested by the user. These third parties will be considered data processors and provide sufficient guarantees to apply appropriate technical and organisational measures for GDPR compliance.
What are your rights when you provide us with your data?
- Right of access: The user has the right to obtain confirmation as to whether Indexa Capital Group processes personal data that concern them, and if so, to access them. Likewise, they will have the right to obtain a copy of the data.
- Right to rectification: The user has the right to request the rectification of inaccurate personal data concerning them.
- Right to erasure: The user has the right to request the erasure of their data, among other reasons, when the data are no longer necessary for the purposes for which they were collected.
- Right to object: The user has the right to object to the processing of their personal data for reasons relating to their particular situation. In such cases, Indexa Capital Group will cease processing such data, unless there are compelling legitimate grounds, or for the exercise or defence of legal claims.
- Right to restriction of processing: Under certain conditions, the user may request the restriction of the processing of their data, in which case Indexa Capital Group may only process them, with the exception of their storage, for the exercise or defence of legal claims, for the protection of the rights of third parties, or for reasons of public interest.
- Right to data portability: The user has the right to receive or, where technically feasible, have Indexa Capital Group transmit to another controller their personal data in a structured, commonly used, and machine-readable format, provided that such processing is based on consent and is carried out by automated means.
The user may exercise their rights of access, rectification, erasure, objection, restriction, and data portability via postal mail to 35 Gran Vía Don Diego López de Haro, Floor 2, 48009 Bilbao (Bizkaia), Spain, or via email to info@indexacapital.com, attaching a photocopy of their ID.
Indexa Capital Group undertakes to respond to all requests within the time limits established by current regulations.
Furthermore, the user may lodge a complaint with the Spanish data protection agency (Agencia Española de Protección de Datos, AEPD), whose contact details are provided on the website www.aepd.es