1. Introduction

This privacy policy (“Privacy Policy“) sets out the terms and conditions which govern the processing of the personal data by XENIA SPAIN REAL ESTATE FINANCE, S.L. (“Xenia Capital“).

Xenia Capital is committed to the correct processing of personal data; therefore, Xenia Capital only collects the minimum data considered necessary for the right performance of our professional activity, and we adopt measures to guarantee confidentiality and proper preservation.

  1. How do we collect your personal data?

Xenia Capital may collect and process personal data in the following cases:

  1. a) When you use the Website (as this term is defined in the User Conditions which can be viewed at this link: INSERT LINK TO XENIA T&C PAGE HERE and when you communicate (by mail, e-mail or telephone) with Xenia Capital or the companies of its group, using the contact details provided for in the Website, marketing presentations or business cards.
  2. b) When you provide this kind of data, directly or indirectly, to Xenia Capital or the companies of its group, as a consequence of a contractual relationship (either in your condition of employee, collaborator, client, supplier or any other derived from the ordinary activity of Xenia); or even a precontractual relationship (as examples, considering labor matters, imaging the candidate who sends his/her CV to Xenia Capital; or considering the ordinary activities of Xenia Capital, image the personal data which could be provided at the non-binding stage of the negotiation proceeding of an eventual investment transaction).
  3. c) Xenia Capital may also obtain personal data using external sources of information such as official journals and gazettes, public registries, Public Administration’s resolutions, telephone directories, list of persons registered with professional associations, official lists for fraud prevention, social networks and Internet, or third companies to whom you have given your consent to the transfer of your data.
  1. Why do we need your personal data?

In general, your personal data will be collected and processed solely and exclusively to maintain the relationship with Xenia Capital  or any of the companies of its group. For example, your personal data may be used as a point of contact, and to send information within the scope of the professional activities carried out by Xenia Capital; or just to answer any questions sent through the channels provided for in the Website.

Xenia Capital may process your personal data also to comply with applicable legal and tax regulations (e.g. anti-money laundering and terrorism financing prevention regulations).

For any specific purpose different from the above we will ask first for your prior consent.

  1. Legal basis for processing your personal data

The legal basis for processing your personal data is Xenia Capital’s legitimate interest in maintaining the relationship with you and, if applicable, your consent.

Besides Xenia Capital may be legitimate to process your personal data specifically by virtue of a contractual relationship.

In some cases, the legal basis for processing your personal data may be Xenia Capital’s legal obligations (such as the obligations related to anti-money laundering and terrorism financing prevention regulations).

¡! Please consider that if you provide us with their third parties’ personal data, you must have proviously informed them of their inclusion and the terms of this Privacy Policy. You will be personally liable to Xenia Capital for any harm and loss caused in the event of breach.

  1. For how long do we store your personal data? 

Xenia Capital will process your personal data only for as long as this is necessary for the purpose that the data was collected. Therefore, Xenia Capital will process your data for as long as the relationship continues and, if applicable, you do not withdraw the consent provided for data processing. When personal data is not required for the purpose for which it was collected and until it is deleted, it will be retained, but blocked.

  1. Transfer of data and security

Confidentially is an essential principle for Xenia Capital.

Therefore, Xenia Capital will not transfer personal data to third parties unless strictly necessary to manage and maintain the relationship with Xenia Capital, or with your prior authorization. In particular, only those third parties to whom Xenia Capital is contractually and legally bound will have access to personal data.

In any case, your personal data will be processed with a security level adjusted to conform the Data Protection regulations and will not be subject to automated decisions.

  1. Who is the data controller? 

The controller of the personal data is XENIA SPAIN REAL ESTATE FINANCE, S.L. (“Xenia Capital“) with registered office at Ruben Dario 3, 1a Izquierda, Madrid 28010.

You may contact Xenia Capital’s data protection officer at info@xenia-cap.com.

  1. How to exercise your rights or ask a question

Under current law, you may exercise your rights of access, rectification or deletion of data, request that processing be restricted, oppose it or request data portability, at any time, by sending written notice to Xenia Capital at Ruben Dario 3, 1a Izquierda, Madrid 28010, or by sending an email to info@xenia-cap.com, attaching a copy of your identification document or similar document providing your identity. You can also file a claim with the Spanish Data Protection Agency.

Besides, you may also contact us through these channels should you have any question or suggestion regarding Data Protection.