I. PRIVACY AND DATA PROTECTION POLICY

In accordance with the provisions of current legislation, CS Financial Planning (hereinafter also referred to as the ‘Website’) undertakes to implement the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk associated with the data collected.

Legislation covered by this privacy policy

This privacy policy complies with current Spanish and European legislation on the protection of personal data online. Specifically, it complies with the following regulations:

• 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 data (GDPR).
• Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007 of 21 December, approving the implementing regulations for Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for the personal data collected at CS Financial Planning is: Capitalsur Advisors Sl., with the following company registration number: B93422038. Their contact details are as follows:

Address: Camino de Cortes, no. s/n, Marbella, postcode 29670

Contact telephone number: 34627507902

Contact email: masoriano@capitalsuradvisors.com

Record of Personal Data

In accordance with the provisions of the GDPR and the LOPD-GDD, we hereby inform you that the personal data collected by CS Financial Planning, via the forms provided on these pages, your details will be recorded and processed in our database in order to facilitate, streamline and fulfil the commitments established between CS Financial Planning and the User, or to maintain the relationship established through the forms they complete, or to respond to a request or enquiry from them. Furthermore, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception set out in Article 30(5) of the GDPR applies, a record of processing activities is maintained which specifies, according to their purposes, the processing activities carried out and the other circumstances set out in the GDPR.

Principles governing the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights:

• Principle of lawfulness, fairness and transparency: the User’s consent must be obtained at all times, following the provision of fully transparent information regarding the purposes for which personal data is collected.
• Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected shall be limited to that which is strictly necessary in relation to the purposes for which it is processed.
• Principle of accuracy: personal data must be accurate and kept up to date at all times.
• Principle of data retention limitation: personal data shall only be retained in a form that allows the User to be identified for as long as is necessary for the purposes of its processing.
• Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure its security and confidentiality.
• Principle of proactive accountability: the data controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed in CS Financial Planning These are solely identifying details. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed in CS Financial Planning These are both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are defined as those that reveal a person’s ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.

In all cases, the processing of special categories of personal data will require the User’s explicit consent for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. CS Financial Planning undertakes to obtain the User’s express and verifiable consent to the processing of their personal data for one or more specific purposes.

The User shall be entitled to withdraw their consent at any time. Withdrawing consent will be just as easy as giving it. As a general rule, the withdrawal of consent shall not affect the use of the Website.

On those occasions when the User is required or able to provide their personal data via forms in order to make enquiries, request information or for reasons relating to the content of the Website, they will be informed if the completion of any such form is mandatory, as these fields are essential for the operation to be carried out correctly.

Purposes for which personal data is processed

Personal data is collected and processed by CS Financial Planning in order to facilitate, streamline and fulfil the commitments agreed between the Website and the User, or to maintain the relationship established through the forms completed by the User, or to respond to a request or enquiry.

Similarly, the data may be used for commercial purposes relating to personalisation, operational and statistical purposes, and activities falling within the corporate purpose of CS Financial Planning, as well as for data extraction, storage and marketing research, with a view to tailoring the Content offered to the User and improving the quality, performance and navigation of the Website.

At the time the personal data is collected, the User will be informed of the specific purpose or purposes for which the personal data will be processed; in other words, of the use or uses to which the information collected will be put.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes for which it is processed and, in any event, only for the following period: , or until the User requests its erasure.

At the time the personal data is collected, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any event, at the time the personal data is collected, the User will be informed of the recipients or categories of recipients of the personal data.

The User’s personal data will be shared with the following recipients or categories of recipients:

Where the data controller intends to transfer personal data to a third country or an international organisation, at the time the personal data is collected, the User shall be informed of the third country or international organisation to which the data is intended to be transferred, as well as whether or not a Commission adequacy decision exists.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, only those aged 14 or over may give their consent to the lawful processing of their personal data by CS Financial Planning. In the case of a child under the age of 14, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.

Confidentiality and security of personal data

CS Financial Planning undertakes to implement the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk posed by the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, because CS Financial Planning It cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who gain unauthorised access to personal data; the Data Controller undertakes to notify the User without undue delay should a personal data breach occur that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is defined as any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or to the unauthorised disclosure of, or access to, such data.

Personal data will be treated as confidential by the data controller, who undertakes to ensure, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom it makes the information available.

Rights arising from the processing of personal data

The User has the right to CS Financial Planning You may therefore exercise the following rights, as recognised in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, vis-à-vis the data controller:

• Right of access: The User has the right to obtain confirmation as to whether CS Financial Planning whether or not your personal data is being processed and, if so, to obtain information about your specific personal data and the processing that CS Financial Planning has carried out or carries out, as well as, amongst other things, the information available on the origin of such data and the recipients of the communications made or planned in relation to it.
• Right to rectification: The User has the right to have their personal data amended where it is inaccurate or, having regard to the purposes of the processing, incomplete.
• Right to erasure («the right to be forgotten»): The User has the right, unless otherwise provided for by applicable legislation, to have their personal data erased where such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate ground for continuing with it; the personal data have been processed unlawfully; the personal data must be erased in order to comply with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under the age of 14. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable steps to inform those responsible for processing the personal data of the data subject’s request to remove any links to that personal data.
• Right to restriction of processing: The User has the right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of their personal data; where the processing is unlawful; where the Data Controller no longer needs the personal data, but the User needs it to establish, exercise or defend legal claims; and where the User has objected to the processing.
• Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive their personal data from the data controller in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. Where technically feasible, the data controller shall transmit the data directly to that other data controller.
• Right to object: It is the User’s right to ensure that their personal data is not processed, or that the processing of such data by CS Financial Planning.
• The right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided for by applicable legislation.

The User may therefore exercise their rights by sending a written request to the data controller, quoting the reference «GDPR-https://capitalsurplanning.com/«, specifying:

• The User’s first name, surname(s) and a copy of their National Identity Card. Where representation is permitted, the person representing the User must also provide proof of identity using the same method, as well as a document evidencing the power of representation. A photocopy of the National Identity Card may be replaced by any other legally valid means of proving identity.
• A request setting out the specific grounds for the request or the information to which access is sought.
• Address for service of notice.
• Date and applicant’s signature.
• Any document supporting the request you are making.

This application and any other accompanying documents may be sent to the following address and/or email address:

Postal address: Camino de Cortes, no. s/n, Marbella, postcode 29670

Email: masoriano@capitalsuradvisors.com

Links to third-party websites

The Website may contain hyperlinks or links that provide access to third-party websites other than CS Financial Planning, and are therefore not operated by CS Financial Planning. The owners of these websites will have their own data protection policies and will, in each case, be responsible for their own data files and privacy practices.

Complaints to the supervisory authority

Should the User consider that there is a problem or a breach of current legislation regarding the way in which their personal data is being processed, they shall be entitled to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the country where they have their habitual residence, place of work or the place where the alleged infringement occurred. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

Users must have read and agreed to the conditions regarding the protection of personal data set out in this Privacy Policy, and must consent to the processing of their personal data so that the Data Controller may process such data in the manner, for the duration and for the purposes specified. Use of the Website implies acceptance of its Privacy Policy.

CS Financial Planning reserves the right to amend its Privacy Policy, at its own discretion, or in response to a change in legislation, case law or doctrine issued by the Spanish Data Protection Agency. The User will not be explicitly notified of any changes or updates to this Privacy Policy. Users are advised to check this page regularly to keep abreast of the latest changes or updates.

This Privacy Policy has been updated to comply with 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 data (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.