Privacy Policy

1. Data Controller

This privacy policy applies to personal data processed by:

2. Data We Collect

We collect the following personal data when you use our services:

• Contact Information: Name, email address, phone number
• Investment Profile: Investment experience, financial capacity, qualified investor status
• Communication Data: Messages, consultation requests, WhatsApp communications
• Technical Data: IP address, browser type, device information (via cookies)

3. Legal Basis for Processing

We process your personal data based on:

• Legitimate Interest: To provide investment consultation and services
• Consent: For marketing communications and newsletter subscriptions
• Legal Obligation: To comply with financial services regulations and anti-money laundering requirements
• Contract Performance: To execute investment agreements and provide ongoing services

4. How We Use Your Data

• Assess your suitability for investment opportunities
• Provide investment consultation and advisory services
• Send investment guides and market updates
• Comply with regulatory requirements (KYC, AML)
• Improve our website and services
• Communicate via WhatsApp for real-time updates

5. Data Sharing

We may share your data with:

• Legal Advisors: For transaction structuring and compliance
• Regulatory Bodies: When required by Spanish financial regulations
• Service Providers: Albato (forms), WhatsApp (communications), hosting providers
• Investment Partners: Only with your explicit consent for specific opportunities

We never sell your personal data to third parties.

6. International Transfers

Some of our service providers may be located outside the EU. When transferring data internationally, we ensure adequate protection through:

• EU Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules where applicable

7. Data Retention

We retain your personal data for:

• Active Investors: Duration of investment relationship plus 7 years (regulatory requirement)
• Prospects: 3 years from last contact or until consent withdrawal
• Marketing Data: Until consent is withdrawn
• Legal Claims: As required by Spanish limitation periods

8. Your Rights (GDPR)

Under EU data protection law, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal obligations)
• Restriction: Limit how we process your data
• Portability: Receive your data in a structured format
• Object: Opt-out of processing based on legitimate interests
• Withdraw Consent: For consent-based processing

To exercise these rights, contact us at info@acerva.es or +34 851 000 825.

9. Cookies

We use essential cookies for website functionality. We do not use tracking or advertising cookies. You can disable cookies in your browser settings, though this may affect website functionality.

10. Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• SSL/TLS encryption for data transmission
• Access controls and authentication
• Regular security assessments
• Staff training on data protection

11. Complaints

If you have concerns about our data processing, you can:

• Contact us directly at info@acerva.es
• Lodge a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es

12. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via email or website notice.

13. Contact Us

For any questions about this privacy policy or our data practices: