Likewise, this policy aims to comply with the General Regulation on protecting and processing of personal data 2016/679 (GDPR) and the Organic Law 3/2018 on the protection of personal data and the guarantee of digital rights (LOPDGDD).
2. Identification of the Data Controller
|COLUMBUS VENTURE PARTNERS S.G.E.I.C., S.A.U (“Columbus“)
|C/José Abascal,58-7-derecha, 28003 – Madrid (Madrid)
|963 946 599
|Venture Capital Management
|Madrid Commercial registry Volume 33551, Sheet 109, Section 8, Page M 603897
3. Identification of the Data Protection Officer
Our company has designated a Data Protection Officer to whom you can address your questions, recommendations or complaints about the processing of your data, showing the name of our company or trade name. You can use the following means to contact them:
ACELLA INCUBATOR, S.L.
Calle Santa Cecilia número 8, 46113, Moncada, Valencia
4. Processing of personal data
Personal identification data, contacts, economic data, and any other data, whether provided in person, by e-mail, telephone, through our forms, etc., shall be treated confidentially by our company’s authorized Personnel.
Our company will duly identify all categories and types of personal data processed in the corresponding processing activities.
We do not process any data subject to special protection.
The processing of personal data carried out by our company is for maintaining the contractual relationship with our customers, legal job applicants, users of our website or social networks and interested parties who contact our company through our web forms, email, telephone or in person.
Depending on the type of relationship, we will process your data for different purposes.
If you are an investor, we will process your personal data solely to maintain the contractual relationship, including communicating through various means always related to your status as investor and your investment contract. Also for accounting management and for compliance with different regulations to which we are obliged as the company responsible for the treatment.
If you are a potential investor or you are requesting information, we will process your data only to fulfill your requests, including in our reply commercial information related to your request and for the time strictly necessary to follow up and respond appropriately to your inquiries or requests.
If you have requested us through the corresponding form on our website that we register you in our Bulletins/Newsletters, we will process your data to send you e-mail communications with information related to our company, which may include commercial content. We will offer you in these communications an easy and free method to stop receiving them whenever you wish.
If you have filled in the Internal Reporting System form, we will process your data in order to receive and analyze the reported actions or omissions and decide whether to start an investigation into the reported facts. Under the legal obligations set forth in Law 2/2023, we will process your personal data based on the legitimate basis of compliance and for the time required to adequately address and resolve your complaints.
If you are a job applicant, we will process your data in order to include you in our selection processes and job vacancies.
By accepting the installation of our cookies in your browser when visiting our website, you may also allow the processing of data for different purposes. For more information, visit our Cookies Policy.
Our company carries out the processing of personal data on the following legitimate bases.
- Fulfillment of the contractual relationship with investors.
- Legitimate interest of the responsible party in receiving commercial communications about the investment products offered.
- To comply with our legal obligations.
7. Data Retention
We will keep the personal data processed for the time necessary to fulfill the purpose for which we collect them, for the time required by law, and as long as necessary to purge potential liabilities arising from such processing. The data controller must block the data after rectification or deletion. The blocking of the data comprises the identification and reservation of the data, adopting technical and organizational measures to prevent its processing, including its visualization, except for the provision of the data to the judges and courts, the Public Prosecutor’s Office or the competent Public Administrations, in particular the data protection authorities, for the demand of responsibilities derived from the processing and only for the period of prescription of the same. Once this period has elapsed, the data must be effectively destroyed.
We do not create profiles using your personal data through automated decisions, but if we do so in the future, we will inform you and request your prior express consent to do so.
9. Transfer of data
In general, our company does not disclose personal data to third parties, although there may be cases in which this is legally necessary, for example, to the Tax Agency, SEPBLAC, Auditors, Banks, the Public Prosecutor’s Office and Judges and Courts.
In addition, investors’ personal data may be processed by third parties to whom we delegate some of our obligations (for ex. Tax advisors/accountants). All of them have agreed, through a data processor contract, to comply with the obligations that the data protection regulations imposed on data processors and to implement the security measures required by our company, as well as to submit to the duty of secrecy and confidentiality of the personal data processed, among the other obligations regarding the protection of personal data regulated by article 28 of the RGPD.
In the processing activities of Columbus, there are no assignments or transfers of data outside the EEA. In the event of transfers to other companies or to other countries outside the EEA, we will inform you and request your prior express consent or, otherwise, we will implement the guarantees regulated by the GDPR in order to carry out the intended transfer safely and legitimately.
10. Security Measures
Our company has implemented all the technical and organizational measures to protect the personal data processed, guaranteeing its confidentiality, integrity and availability.
We created these measures according to the type of data we process and the purposes for which we process it. Our internal controls periodically verify compliance with personal data protection regulations for these measures.
11. Rights of interested parties
You have a right to know whether our company is processing your personal data; therefore, you may access your data, rectify it if it is inaccurate, or request its deletion when the data is no longer necessary and when legally possible.
You may also exercise your right of opposition, limitation or portability if you deem it convenient, you may even revoke your consent and to do so, you can do so in writing by email to firstname.lastname@example.org, attaching a copy of your ID to provide us with your identification.
If you have any suggestions or questions about the processing of your personal data, please contact our data protection officer (ref. Columbus):
ACELLA INCUBATOR, S.L.
Calle Santa Cecilia número 8, 46113, Moncada, Valencia
If you wish to make a claim for considering that your rights have been violated, you may do so before the Spanish Data Protection Agency, C/ Jorge Juan, 6, 28001 Madrid or at www.aepd.es.
12. Commitment to Personal Data Protection
Scope of application
Our commitment to protecting personal data will be mandatory for all departments, employees of our company and those acting on our behalf.
We have established protocols for the processing of personal data under European and Spanish data protection regulations.
Lawfulness, loyalty, transparency, data minimization, accuracy, retention period limitation, integrity, confidentiality and active responsibility.
Special category of data
The processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic or biometric data, data concerning health or data concerning sexual orientation is prohibited, except in the legally allowed exceptions and with the prior consent of the data subject.
Right of interested parties
Data subjects may access their personal data, and have a right to rectify them in case of is inaccuracy, to delete them when they is no longer necessary or when processing is no longer desired, to limit them to certain processing, to have the possibility of receiving their data easily and in structured formats commonly used by the data controller, as well as the right not to have their data used for profiling purposes and to object to the processing at any time.
Registration of Activities, Impact Assessment and Safety Measures
Our company has kept a record of processing activities and has analyzed the purposes of processing, categories of data subjects and of data, recipients, international transfers, storage periods, etc., in order to assess the risks of processing and implement the security measures to ensure the confidentiality, integrity and availability of the personal data processed.
Additionally, we analyzed the necessity to prepare an Impact Assessment and appoint a Data Protection Officer, establishing that the person appointed for this position must have sufficient knowledge and experience under the current legislation.
We also have external consultants who monitor any publication made by the competent control authorities and other European and Spanish entities related to data protection regulations in order to comply with these regulations.
13. Updating this Policy
Our company reserves the right to change this policy without prior notice. Therefore, we recommend you consult it every time you visit our website.