Privacy Policy
1. Purpose
The purpose of this Privacy Policy is to inform you about how we collect, process, and protect your personal data within our organization, including through this website (hereinafter "Website" or "Site"), so that you can freely decide whether or not you want us to process your data.
This policy also aims to comply with the General Data Protection Regulation 2016/679 (hereinafter GDPR) and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPDGDD).
2. Data Controller Identification
Entity: COLUMBUS VENTURE PARTNERS S.G.E.I.C., S.A.U (“Columbus”)
Tax ID (CIF): A81745002
Postal Address: Ronda Guglielmo Marconi, 8. C.P. 46980 – Parque Tecnológico (Valencia)
Phone: +34 963 946 599
Email: inversor@columbusvp.com
Corporate Purpose: Venture Capital Management Company
Website: https://www.columbusvp.com/
Registration Details: Mercantile Registry of Valencia, Sheet V-224148, IRUS 1000295112245.
3. Data Protection Officer Identification
Our organization has appointed a Data Protection Officer (DPO) to whom you may address any questions, suggestions, or complaints regarding the processing of your personal data, indicating our company name or commercial name. You can contact the DPO via:
ACELLA INCUBATOR, S.L.
Calle Santa Cecilia no. 8, 46113 Moncada, Valencia
Email: dpo@acellaincubator.com
4. Personal Data Processing
Personal data — including identifying, contact, financial, or any other type — provided in person, by email, phone, or through our forms, will be processed confidentially and only by personnel authorized by our entity.
All categories and types of personal data processed will be duly identified in the corresponding processing activities under our ownership.
No special category data is processed.
5. Purpose
As a general rule, the processing of personal data by our organization is aimed at maintaining the contractual relationship with our clients, or a legal relationship with job applicants, website or social media users, and any interested party who contacts us via our forms, email, phone, or in person.
Depending on the nature of the relationship, your data will be processed for different purposes:
We may also process your data for additional purposes when you accept our cookie policy upon visiting our website. For more details, please see our Cookie Policy.
6. Legal Basis
Our processing of personal data is based on the following legal grounds:
a. Fulfillment of contractual obligations with investors.
b. The controller’s legitimate interest in sending you commercial communications about investment products.
c. Compliance with our legal obligations.
7. Data Retention
Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected, for as long as legally required, and as long as necessary to handle any liabilities arising from the processing. The controller must block the data when it is subject to rectification or deletion. Blocking involves identifying and reserving the data using appropriate technical and organizational measures to prevent processing (including viewing), except when required by judges and courts, the Public Prosecutor’s Office, or data protection authorities, for as long as the legal liability period lasts. After that period, the data must be securely destroyed.
8. Profiling
We do not currently create profiles based on your personal data using automated decision-making. If we do so in the future, you will be informed and your explicit prior consent will be requested.
9. Data Disclosure
As a general rule, our entity does not disclose personal data to third parties unless legally required — for example, to the Tax Agency, SEPBLAC, auditors, banks, the Public Prosecutor’s Office, or judges and courts.
Personal data of investors may also be processed by third parties to whom we delegate certain obligations (e.g., tax/accounting advisors). All of them are bound by data processing agreements requiring compliance with applicable data protection laws, implementation of appropriate security measures, and confidentiality obligations under Article 28 of the GDPR.
Columbus does not transfer data outside the EEA. If such transfers occur in the future, you will be informed and your explicit consent will be requested, or we will apply the necessary safeguards as provided by the GDPR.
10. Security Measures
Our organization has implemented all necessary technical and organizational measures to protect the personal data we process, ensuring its confidentiality, integrity, and availability.
These measures are tailored to the type of data processed and their purposes, and are periodically reviewed through internal compliance checks and external audits.
11. Data Subject Rights
You have the right to know whether we are processing your personal data. Accordingly, you have the right to access your data, rectify inaccuracies, or request its deletion when no longer necessary, where legally possible.
You may also exercise your right to object, restrict, or transfer your data, and withdraw your consent at any time. Requests can be sent in writing via email to: inversor@columbusvp.com, with a copy of your ID to verify your identity.
For suggestions or inquiries related to your data processing, you may also contact our DPO (ref. Columbus):
ACELLA INCUBATOR, S.L.
Calle Santa Cecilia no. 8, 46113 Moncada, Valencia
Email: dpo@acellaincubator.com
If you believe your rights have been violated, you may file a complaint with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 Madrid or www.aepd.es.
12. Commitment to Data Protection
Scope
Our commitment to data protection applies to all departments, employees, and any individuals acting on our behalf.
Purpose
We have established data processing protocols in line with European and Spanish data protection legislation.
Principles
Lawfulness, fairness, transparency, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability.
Special Categories of Data
The processing of personal data revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, or data concerning health, genetic or biometric data, or sexual orientation is prohibited unless legally allowed and with the data subject’s prior consent.
Data Subject Rights
Data subjects have the right to access, rectify, erase, restrict, port, and object to the processing of their personal data, as well as the right not to be subject to profiling.
Activity Records, Impact Assessments, and Security Measures
We maintain a record of processing activities, including purposes, data categories, recipients, international transfers, retention periods, and risks, in order to implement appropriate security measures.
We have also assessed the need to conduct Data Protection Impact Assessments and have appointed a DPO with the necessary knowledge and experience as required by applicable law.
Monitoring
We work with external consultants to monitor any publications by relevant supervisory authorities or related organizations to ensure continuous compliance with data protection regulations.
13. Updates to this Policy
Our organization reserves the right to amend this Policy without prior notice. Therefore, we recommend reviewing it regularly when visiting our website.
