Privacy Policy

Privacy Policy

In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council 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 Personal Data (“GDPR”), as well as the national implementing regulations, we hereby inform you of our Privacy Policy governing the processing of the personal data you provide to us:

1. DATA CONTROLLER
   The company responsible for the processing of your personal data (the “Personal Data”) is BLACKPEARL CAPITAL MANAGEMENT SGEIC, S.A., with CIF nº A-02669786 and registered office at Calle Barquillo, 10, 1º Derecha, Madrid 28004 (“BLACKPEARL” or the “Company”), with email address admin@bkpcap.com.
   You can contact the Company via the following email address: info@bkpcap.com for any inquiries regarding the processing of personal data by BLACKPEARL.
   This Privacy Policy defines the processing that the Company will carry out of the Personal Data that you, as a user (the “User” or “You”) of the website www.blackpearlcapital.es (the “Website”), are freely and informedly providing in order to manage and enable navigation of the Website, ensure the security of the User, contact and receive communications from and with the User, through the forms (the “Forms”) that BLACKPEARL makes available to you.
   In accordance with the GDPR, BLACKPEARL, the owner of the Website, informs the User of the existence of one or more automated files of Personal Data, created, managed, and under the responsibility of BLACKPEARL.

2. PURPOSES OF PROCESSING
   BLACKPEARL will only collect the Personal Data that is necessary solely for the purposes described below, which You freely, informedly, and unequivocally consent to through the acceptance of this Privacy Policy that you expressly accept in the Forms.

2.1. Management and access to navigation on the Website. Ensuring your security
Navigation through the Website does not require prior registration. However, the development of different functionalities requires our web servers to temporarily store certain information—IP address, domain from which access is obtained, date and time of access, etc.—and to install certain technical cookies (more information in the Cookies Policy).
Additionally, this information may be used to analyze access and access attempts and ensure the security of web traffic.

2.2. User Service
Respond to inquiries and requests for information made by Users (whether or not they are clients) through the contact Forms provided for this purpose on the Website or through corporate email addresses.
The User’s Personal Data collected through the Forms available on the Website is collected by BLACKPEARL in order to contact and receive communications from and with the User for informational purposes.

3. LEGITIMATION. LAWFULNESS OF PERSONAL DATA PROCESSING

   The purposes of processing described in the previous section correspond to the following legal bases:

4. DATA PROCESSED

   4.1. Management and access to navigation on the Website. Ensuring your security

   To develop this purpose, the following data will be processed:

• Identification data: Mainly, the IP address and other identifiers.

• Other data (derived from user navigation): Date and time of access, request made, etc.

4.2. User Service
To develop this purpose, the following data will be processed:

• Identification data: Mainly, the user’s name and email address.

• Other data: Any personal data that may be processed in connection with resolving the inquiry.

All data marked with * (or similar) is mandatory. If you do not provide this data or if it is not accurate, BLACKPEARL will not be able to fulfill the User’s request.

5. ACCURACY OF DATA
   The User guarantees that the Personal Data provided is accurate and is responsible for communicating any changes to BLACKPEARL. The User will be liable for the accuracy of the Personal Data provided, exempting the Company from all responsibility if the intended purpose cannot be fulfilled.

6. DATA RETENTION
   Personal Data will be retained for as long as necessary to fulfill the purposes for which it was collected unless the granted consents are revoked. Subsequently, if necessary, the information will be kept blocked for the legally established periods.

7. COMMUNICATION OF PERSONAL DATA
   The Company informs the User that their Personal Data may be communicated to third parties when such communication is essential to fulfill the purposes for which the Personal Data was obtained. They will also be communicated when such communication is based on a legal obligation or judicial requirement.

8. INTERNATIONAL DATA TRANSFERS
   The User is informed that the Company, as a result of the contracted services, may occasionally have to carry out international transfers of their Personal Data. In such cases, the User will be duly informed.
   In this regard, the Company will take all measures within its reach to ensure that Personal Data is processed in accordance with the security levels guaranteed by the applicable regulations and in compliance with the GDPR, as well as the instructions and decisions issued by the various authorities on personal data protection.

9. USER RIGHTS IN RELATION TO THEIR DATA
   As a result of the processing of Personal Data by BLACKPEARL, it is considered the data controller. Therefore, the User, as the owner of the Personal Data, has the right to exercise the following rights:

• Access: The right of access allows interested parties to be provided with a copy of the personal data held about them, along with the purpose for which it was collected, the identity of the data recipients, the expected retention periods, or the criteria used to determine it.

• Rectification: The right to rectification involves modifying the data of interested parties that were inaccurate or incomplete in relation to the purposes of the processing. The interested party must indicate in the request which data is being referred to and the correction to be made, providing, when necessary, the documentation justifying the inaccuracy or incompleteness of the data being processed.

• Erasure: The right to erasure involves deleting the data of interested parties when they express their refusal to the processing, and there is no legal basis to prevent it, the data is no longer necessary in relation to the purposes for which it was collected, they withdraw the given consent, and there is no other legal basis that justifies the processing, or the processing is unlawful.

• Objection: The right to object allows interested parties to express their refusal to the processing of their personal data to the controller, who will stop processing it as long as there is no legal obligation that prevents it.

• Restriction: The right to restrict processing allows interested parties to request the suspension of their data processing to challenge its accuracy while the controller performs the necessary verifications, or if the processing is based on the controller’s legitimate interest or in compliance with a public interest mission, while it is verified whether these reasons prevail over the interests, rights, and freedoms of the interested party. The interested party may also request the retention of the data if they consider the processing unlawful and, instead of erasure, request the restriction of processing, or if the controller no longer needs them for the purposes for which they were collected, the interested party needs them for the formulation, exercise, or defense of claims.

• Portability: The right to data portability allows interested parties to receive a copy of their personal data in a structured, commonly used, and machine-readable format if the processing is carried out by automated means and is based on consent or is performed within the framework of a contract. They also have the right to request that the data be transmitted directly to a new controller, whose identity must be communicated, when technically possible.

• Not to be subject to automated decisions: The User has the right not to be subject to automated decisions. However, when requesting this right, they may not be able to continue contracting some of the services offered by BLACKPEARL.

The User can exercise all these rights, proving their identity with their DNI, at the following email address: info@bkpcap.com or by regular mail to the following address:

BLACKPEARL CAPITAL MANAGEMENT SGEIC, S.A.
Calle Barquillo, 10, 1º Derecha, Madrid 28004

Finally, in accordance with the GDPR, the User is informed that if they consider that the exercise of any of the rights granted by this regulation has not been satisfied, they can file a complaint with the Spanish Data Protection Agency.

10. DATA SECURITY
    The protection of privacy and your Personal Data is very important to BLACKPEARL. Therefore, the Company maintains the levels of security for the protection of Personal Data in accordance with the applicable regulations and has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of the Personal Data that the User provides through the Website.
    Additionally, BLACKPEARL and its professionals are committed to fulfilling the duty of secrecy and confidentiality regarding Personal Data in accordance with the GDPR.

11. ACCEPTANCE AND CONSENT
    The User declares that they have been informed of the conditions regarding the protection of Personal Data, accepting and consenting to their processing by BLACKPEARL, in accordance with the provisions of this Privacy Policy and for the purposes indicated by the User.