1. Introduction
The right to privacy, and specifically the right to personal data protection, is one of XP Advisory’s core values, enshrined in our Code of Ethics.
The purpose of this policy is to explain how XP Advisory will process personal data that may be collected through the various forms found on XP Advisory’s websites. Your personal data will be treated confidentially and only for the purposes you have consented to, as explained below in this General Privacy Policy and in each of the Privacy Policies for the different forms.
2. Commitment to Privacy
XP Advisory is fully committed to complying with the regulations and the General Data Protection Regulation of the European Union, as well as the personal data protection regulations in force at all times, this being a priority objective for XP Advisory.
Therefore, XP Advisory has decided to implement the following principles, with privacy being the foundation upon which all processing is configured:
· Transparency in data processing is one of our priorities, so whenever we collect personal data about you, we will duly inform you of the purposes of such processing in the corresponding privacy policy.
· We will always process only the data strictly necessary to carry out the informed processing.
· We will never compel you to provide personal data, unless it is truly necessary to provide you with the service you may request from us.
· Whenever possible, we will provide you with simple means to control your personal data.
· We will not share data with any third party, except for those providers who offer us a service, or with those whom we have previously informed you about and for whom you have given your consent.
3. Purposes of Processing
XP Advisory collects your personal data to manage your requests and offer you the services and products you may be interested in. Specifically, we process your personal data for the following purposes:
To address your inquiries, questions, or requests made through the customer service or communication channels identified on each website and to contact you to resolve them.
a) To improve our websites, services, products, and to offer better service and content.
b) To offer you access to the restricted areas of our website (registration may require acceptance of a specific privacy policy).
c) To send you our service proposals.
d) To send you our Newsletter.
e) To send you invitations.
In some cases, it may be necessary to process your personal data to comply with legal obligations, or in relation to any contractual relationship we may have with you.
In other cases, and whenever appropriate, we will request your consent to process your personal data.
4. Sending Commercial Communications
XP Advisory, within the framework of its promotional activity, may provide you with registration or subscription resources for company news or commercial information. Such resources will always be subject to your consent to send them.
If you have authorized us, XP Advisory will send you information about its products, activities, and services personalized for you according to your tastes and preferences.
You may revoke your consent to receive commercial communications at any time, by using the link or button provided for this purpose in each communication, or by communicating your wish to revoke consent by sending an email to xpalencia@xpadvisory.com
5. Segmented Communications, Based on a Profile
The communications that XP Advisory may send you may be segmented according to your profile, taking into account the tastes and preferences you have expressed to us, either because they are necessary for the execution of a contract between the data subject and the data controller, or because we have your explicit consent, or because there is a regulation that authorizes it, informing you appropriately in each case.
6. Duration of Processing and Retention Period
At XP Advisory, we are committed to processing personal data only as long as it is useful to us and we can offer you a quality service through its use. Therefore, we will make all appropriate and reasonable efforts to minimize the processing and retention period of personal data.
In this regard, in each data collection form, we will inform you of the foreseen processing and/or retention period of your personal data.
In any case, and even if you ask us to delete your data, we may keep and maintain it, duly blocked, for the period necessary to comply with our legal obligations and to make it available to the competent Authorities in the various applicable matters.
7. Exercise of Rights and Complaints to the AEPD
As a result of XP Advisory processing your personal data, current legislation grants you a series of rights. Below is a summary explanation of each right, to facilitate your exercise:
1. Right of access: You have the right to know what personal data we process about you and the purposes for which we process it.
2. Right to rectification: Your data will always be yours, and as such, you can request their rectification at any time if the data in our records are incorrect.
3. Right to erasure: You may request, at any time, that your personal data be deleted from our files. However, as indicated in the data retention section above, please note that in certain circumstances, compliance with current legislation may prevent the effective exercise of this right.
4. Right to object: You may object to the processing of your data in relation to any of the purposes for which we process your data, in accordance with the applicable privacy policies in each case.
5. Right to restriction of processing: You may request the restriction of processing in the following cases:
a. If you consider that the data we hold about you is not correct or accurate;
b. If you consider that we are not processing your data lawfully, but you prefer that we restrict its processing rather than delete it;
c. If the data we hold is no longer necessary for the purpose for which we collected it, but you need us to retain it for legal claims;
d. If, having exercised the right to object to certain processing, you are awaiting our response regarding it.
6. Right to data portability: You have the right, whenever technically possible and reasonable, to request that the personal data you have provided directly to us be communicated to another data controller. If possible, we will directly provide your data to that other data controller, but if not, we will provide it to you in a standard format.
Whenever we process your data based on consent, you may revoke it at any time, without consequences for you beyond, depending on the right exercised, not being able to provide you with certain services.
You can exercise your rights by contacting XP Advisory by sending an email to xpalencia@xpadvisory.com, attaching a copy of your ID or equivalent identification document.
If you do not wish to exercise a specific right but need to make an inquiry or suggestion regarding the processing of your personal data, you may also contact the addresses provided for exercising rights.
Please note that you can always, in any case, file a complaint with the Competent Data Protection Authority if you believe that we have not processed your data lawfully or that we have not addressed your requests or rights.
In Spain, this Competent Authority is the Spanish Data Protection Agency.
8. Confidentiality and Security in Data Processing
Your personal data is very important to us, and we commit to treating it with the utmost confidentiality and discretion, as well as implementing all security measures we deem appropriate and reasonable.
In this regard, XP Advisory declares and guarantees that it has established all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of the data provided by users.
9. Social Networks
Social Networks are part of the daily lives of many Internet users, and for them, we have created various XP Advisory profiles on them.
All users have the opportunity to join the pages or groups that XP Advisory has on different social networks.
However, you should be aware that, unless we request your data directly (for example, through marketing actions, contests, promotions, or any other valid form), your data will belong to the corresponding Social Network, so we recommend that you carefully read their terms of use and privacy policies, and ensure you configure your preferences regarding data processing.
10. International Transfers
As a general rule, we try to keep your data within the European Union (EU) or the European Economic Area (EEA). However, sometimes we may need to provide it to other group companies or service providers located in other countries, either out of necessity to provide the requested service, or to provide you with the service with the highest quality standards.
In these situations, XP Advisory guarantees that it will apply all measures and controls to ensure and protect the processing of your personal data, such as:
a. Communication to countries that, despite not being part of the EU or EEA, have been deemed by the European Commission to have data protection regulations that guarantee a level of security similar to that applicable in Europe.
b. Standard Contractual Clauses of the European Commission: The European regulator has foreseen that third countries may not have data protection regulations similar to those applicable in Europe, and has therefore developed contract models designed to ensure that companies in countries not part of the EU or EEA comply with a similar level of protection. XP Advisory will sign these contracts whenever there is no equivalent alternative that guarantees the protection of your personal data.
c. Binding Corporate Rules: These are rules approved by companies and reviewed and approved by Supervisory Authorities, which ensure that the company to whom we provide your data complies, in any country, with an adequate level of protection.
d. Certifications: In certain cases, the company to whom we provide the data may have data protection Certifications that guarantee proper use of your data in accordance with current regulations.
11. Contact XP Advisory
If you have any questions or concerns about the processing of your personal data, please contact us through:
(i). Email to be sent to xpalencia@xpadvisory.com
(ii). Contact through the website owner: Javier Palencia Mourelo by phone +34 690 650 131 or by sending an email to xpalencia@xpadvisory.com
