I. Data Protection:

PHI ASSET MANAGEMENT PARTNERS, S.G.E.I.C., S.A., (hereinafter, “PHI ASSET”) in the exercise of its professional activity, performs personal data processing of different categories of stakeholders (staff, customers, suppliers, etc.), following the same guidelines imposed by applicable current legislation on data protection.

Specifically, some of the personal data that are collected by PHI ASSET through the contact form that appears on the Website www.phi-industrial.com (hereinafter, the “Website”). On the aforementioned form, the user who wishes to provide his/her data to contact PHI ASSET, must complete the fields indicated as default (*), and may also provide the rest of the information of an optional nature.

The updated list of the processing activities carried out by PHI ASSET is duly documented in the Registry of Processing Activities that said company has implemented for that purpose. If you would like additional information about the aforementioned activities, you can contact PHI ASSET through the postal address or email address indicated in section 1 below.

1. Data controller:

Identity of the Data Controller:

PHI ASSET MANAGEMENT PARTNERS, S.G.E.I.C., S.A., holding corporate tax identification number A-86.292.489 and registered in the Mercantile Registry of Madrid, in Volume 29155, Page 64, Sheet M-524917, Entry 1.
Contact data:
Address: General Castaños 4, 2º Izquierda, 28004, Madrid.
Contact telephone/fax: (+34) 915.613.371 / (+34) 914.117.216.
Email address: info@phi-industrial.com.

2. Purpose and legitimacy of the processing:

PHI ASSET processes personal data for specific, explicit and legitimate purposes, without the aforementioned data being used later for purposes incompatible with the initial purposes.

Similarly, PHI ASSET processes personal data in a lawful manner in relation to the interested parties, being empowered to carry out the different processing activities under the legitimating bases established for that purpose by the current legislation on data protection that are applicable (consent of the data subject, contractual or pre-contractual relationship, legal obligation applicable to the Data Controller, vital interest of the data subject or another natural person, mission carried out in the public interest, legitimate interest of the Data Controller or a third party). In most cases, the processing of the data by PHI ASSET, is based on the consent of the data subject, the existence of a contractual relationship therewith or due to compliance with a legal obligation.

If you would like additional information about the purpose and the legitimising basis of each of the processing activities carried out by PHI ASSET, you can contact us through the postal address or email address indicated in section 1.

3. Origin and types of data that are collected:

In general, the personal data involved in the different processing activities carried out by PHI ASSET are (i) provided by the data subject, (ii) assigned by a Third Party that is legitimised to do so, or (iii) collected from sources accessible to the public.
The types of data subject to processing (identification, professionals, etc.) will vary depending on the purposes of the processing, being in all cases appropriate, relevant and limited to what is necessary in relation to the purposes for which they are collected.
If you would like additional information about the origin and category of the data subjected to each of the processing activities carried out by PHI ASSET, you can contact us through the postal address or email address indicated in section 1.

4. Time of conservation of personal data:

In general, the storage periods of the personal data processed by PHI ASSET are determined by the legitimising basis of the aforementioned processing, without prejudice to the additional storage periods that may correspond to the care of possible responsibilities as a result of the processing. (limitation period for legal obligations and/or limitation period for shares):

Legal Basis
Consent until revocation or end of need.
Contract or precontract until the end of the duration of the contract or the contractual relationship.
Legal obligation until fulfilment of the obligation or, as the case may be, term established under applicable legislation.
Vital interest until the end of the need.
Public interest until satisfaction of the public interest, end of need or term marked in legislation.
Legitimate interest to the satisfaction of the legitimate interest, end of the need or, in some cases, opposition of the data subject.

If you would like additional information about the conservation periods for the personal data subjected to each of the processing activities carried out by PHI ASSET, you can contact us through the postal address or email address indicated in section 1.

5. Reporting:

In general, PHI ASSET shall:

(i) transmit the personal data that are necessary for the provision of the service to the Data Processors with which it has subscribed the corresponding contracts.

For these purposes, in accordance with current legislation on data protection, “Data Processor” is understood as the “natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.”

(ii) not transmit the personal data to Third Parties, unless such transmission is necessary for the fulfilment of a legal obligation or for the execution of a legally authorised power, without the existence of assignments requiring the consent of the data subjects being detected or that they rely on another legitimating basis.

For these purposes, in accordance with current legislation on data protection, “Third Party” means the ” individual or legal entity, public authority, service or organisation other than the data subject, data processor, data controller and the persons authorised to process personal data under the direct authority of data controller “.

Similarly, please note that that the data communications that PHI ASSET performs do not constitute international data transfers.

If you would like additional information about the communication actions in relation to each of the processing activities carried out by PHI ASSET, you can contact us through the postal address or email address indicated in section 1.

6. Rights of the Data Subject:

Data subjects may exercise their rights of access, rectification, deletion, limitation, opposition and portability in the terms established in the applicable current legislation on data protection, as well as to withdraw the consent given, at any time, without that the exercise of such rights affecting the legality of the processing based on the consent prior to its withdrawal.

The aforementioned rights may be made exercised with PHI ASSET, by writing a document, dated and signed, to the postal address or email address indicated in section 1, indicating the right exercised, your address for the purposes of communications, and accompanying photocopy of your national identity card, and, where appropriate, documents accrediting the request that you make.

Likewise, data subjects may file any complaint with the Spanish Data Protection Agency in the event that their rights are violated.

7. Integrity and confidentiality in the processing of personal data:

PHI ASSET has adopted the necessary security measures to guarantee the integrity and confidentiality of the personal data it deals with, and carries out periodic reviews of their effectiveness, updating them, complementing them and improving them whenever it is appropriate according to the review of the relevant risk analysis on the data processing performed.

II. COOKIES:

PHI ASSET utiliza en la Web una tecnología denominada “cookies” con la finalidad de poder recabar información acerca del uso de la Web.

1. What is a cookie?

PHI ASSET uses a technology called “cookies” on the Website in order to collect information about the use of the Website.

2. What cookies does the Website use?

• Google Analytics: They are first-party cookies to make reports on the interactions of users on the Website. These cookies are used to store non-personal identification information. Browsers do not share first-party cookies through different domains. For more information visit:
https://www.google.com/analytics/learn/privacy.html

• Technical Cookies: They allow the user to use the website and the use of different options or services as may exist.

3. Consent

Those users who have consented to the use of cookies, on the occasion of their acceptance in the banner that appears for this purpose on the Website, expressly and unequivocally authorise the use of this information for the indicated purpose.

4. How to withdraw my consent?

Simply delete the cookies stored on your computer (computer or mobile device) through the settings of your Internet browser. The following link provides all the necessary information about the elimination, disabling or blocking of cookies:
http://www.allaboutcookies.org/es/

Do NOT follow this link or you will be banned from the site!