Privacy Policy

ADDITIONAL AND DETAILED INFORMATION ON PERSONAL DATA PROTECTION

This privacy policy (hereinafter, the “Privacy Policy”) aims to provide data subjects with additional and detailed information regarding the Privacy Policy of ATLANTE GESTIÓN FINANCIERA, S.L (hereinafter “ZELSIOR”), complying with applicable regulations, especially Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights.

Its purpose is to help the User make informed decisions when using the Website and to understand how we process the personal information provided through various data collection forms available on the Website. We invite you to read it carefully to maintain control over your personal data at all times.

The User guarantees that the data submitted or provided is true, accurate, complete, and up-to-date, being responsible for any direct or indirect damage or harm that may arise from non-compliance with this obligation. If the data provided belongs to a third party, the User guarantees that they have informed such third party of the contents of this Privacy Policy and have obtained prior authorization to provide their data to ATLANTE GESTIÓN FINANCIERA, S.L (hereinafter “ZELSIOR”) for the purposes stated.

Who is responsible for processing the User’s personal data?

  • Identity: ATLANTE GESTIÓN FINANCIERA, S.L – B87474029
  • Address: Calle De La Basílica 17, 1, 28020, Madrid
  • Telephone: 917526760
  • Email: rgpd@zelsior.es
  • Data Protection Officer email: rgpd@ateacompliance.com

For what purpose do we process the User’s personal data?

ATLANTE GESTIÓN FINANCIERA, S.L (hereinafter “ZELSIOR”) will process the information provided by Users in each section of the website for the following purposes:

  • DO YOU WANT TO WORK WITH US: Data will be processed to assess the suitability of candidates and to consider their incorporation into the corresponding selection processes.
  • ETHICAL CHANNEL: Data will be processed to manage complaints, decide whether to initiate an investigation, detect possible offenses, prevent liability, and avoid any conduct contrary to the internal and external regulations of the entity.

How long will we retain the User’s personal data?

ATLANTE GESTIÓN FINANCIERA, S.L (hereinafter “ZELSIOR”) will retain data as long as there is a legitimate interest and the data subject does not object to their processing.

For data received via the Ethical Channel, data will be retained for a maximum of 3 months from entry, unless the retention aims to provide evidence of the operation of the crime prevention model by the entity. In such cases, data may continue to be kept in the information register and processed by internal compliance controllers or designated processors for internal investigations. Communications not processed will only be stored anonymized, making it impossible to identify individuals involved.

What is the legal basis for processing the User’s personal data?

Processing by ATLANTE GESTIÓN FINANCIERA, S.L (hereinafter “ZELSIOR”) is based on explicit consent.

For the Ethical Channel, legitimacy is imposed by a legal obligation of the Controller (Article 6.1.c GDPR) and Articles 10 and 13 of Law 2/2023 regulating the protection of whistleblowers.

To whom will the User’s personal data be disclosed?

User data will not be shared with third parties except as required by law.

What rights does the User have regarding their personal data?

The User can exercise the following rights regarding their personal information provided to ATLANTE GESTIÓN FINANCIERA, S.L (hereinafter “ZELSIOR”):

  • Right of access: Confirm if their data is being processed and access it.
  • Right of rectification: Request correction of inaccurate data or completion of incomplete data.
  • Right of erasure: Request deletion of personal data when no longer necessary or consent is withdrawn.
  • Right to restriction of processing: Request temporary limitation of data processing in certain circumstances.
  • Right to data portability: Obtain personal data in a structured, commonly used format and request transfer to another controller where technically feasible.
  • Right to withdraw consent: Withdraw consent at any time.
  • Right to lodge a complaint with the supervisory authority: Contact the Spanish Data Protection Agency (agpd.es) if dissatisfied with our practices.

Users can exercise these rights by writing to ATLANTE GESTIÓN FINANCIERA, S.L at the postal address indicated in this Privacy Policy (Reference: “RGPD Rights Exercise”), including their name, ID copy, specific request, contact address, date, signature, and relevant supporting documents.

  1. MANDATORY OR OPTIONAL NATURE OF INFORMATION PROVIDED BY THE USER

By marking the corresponding checkboxes and entering data in fields marked with an asterisk (*) in contact or download forms, Users expressly consent that such data is necessary to fulfill their request. Other fields are optional. The User guarantees that the personal data provided is truthful and undertakes to update it if modified.

The CONTROLLER informs and guarantees that all data requested via the website is mandatory for optimal service provision. Failure to provide all data may affect the service or information provided.

  1. SECURITY MEASURES

In compliance with current data protection regulations, the CONTROLLER complies with GDPR and Organic Law provisions, treating data lawfully, fairly, transparently, and limited to necessary purposes (Article 5 GDPR). Appropriate technical and organizational measures have been implemented to protect Users’ rights and freedoms, and Users have been informed to enable the exercise of their rights.

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