Privacy Policy

Management of Enquiries and Contacts via the Website Facilitating ongoing contact with users interested in investment funds, financial advisory services, and opportunities managed by Lift Asset Management. Managing information of potential clients and contacts interested in Lift’s investment products and services, including funds of related entities. Management of potential clients and contacts. Management and communication with users. Responding to requests and enquiries received through the contact forms on the Lift Asset Management website.

Management of Social Media and Followers Increase the visibility of Lift Asset Management and its related funds, strengthening its market presence and brand. Create, manage, and publish content on social media to inform and promote Lift Asset Management’s services. Interact with followers and respond to enquiries regarding investment products and services. Monitor social media activity to analyze impact and follower response, optimizing communication strategies.

How long do we retain your data?

We use your data for the period strictly necessary to fulfill the purposes indicated above. Unless there is a legal obligation or requirement, the envisaged retention periods are as follows:

 

8. LAWFUL BASIS FOR PROCESSING

Why do we process your data?

The collection and processing of your data is always based on one or more lawful bases, which we detail below:

 

9. RECIPIENTS OF YOUR DATA

To whom do we disclose your data within the European Union?

On certain occasions, in order to comply with our legal obligations and our contractual commitments to you, we are required to disclose some of your data to certain categories of recipients, which are detailed below:

• Management of Enquiries and Contacts via the Website: Entities within the corporate group. The recipient entities include:
  • LIFT Investment Advisors EAFI S.L (Lift, Tax ID CIF B87425187) for the management of enquiries regarding financial advisory services.
  • Almagro Capital Gestión SL (Almagro Capital Gestión, Tax ID CIF B87858916) for information on real estate investment opportunities.
  • Inversa Prime SOCIMI, S.A (Inversa Prime, Tax ID CIF A87858908) to respond to enquiries regarding investments in reverse housing assets.
  • Ac Residencial SA (Ac Residencial, Tax ID CIF A72517410) for enquiries regarding residential investment projects.
  • Smart Kitchen Property SOCIMI (Smart Kitchens, Tax ID CIF A10962686) to address interest in real estate investments focused on delivery operators.

  These disclosures enable group entities to directly manage user enquiries, ensuring appropriate attention based on their specific interests and aligned with the services and products of each entity.

• Management of Social Media and Followers: Social media service providers
  • Newsletter Subscription: Entities within the corporate group
  • Cookies, pixels, and tracking: Companies engaged in advertising or direct marketing activities

Do we carry out International Data Transfers outside the European Union?

No international transfers of your data are carried out.

 

10. DATA PROCESSING ACTIVITIES

The data processing activities carried out through https://lift-am.com are described below, specifying:

• Activity: Name of the data processing activity.
• Purposes: Uses and processing operations carried out on the collected data.
• Legal basis: Legal grounds that legitimize the processing.
• Data processed: Types of data processed.
• Source: Origin of the data.
• Retention: Data retention period.
• Recipients: Third parties to whom data is disclosed.
• International transfers: Transfers of data outside the European Union.

 

Processing activities

These are data processing activities whose purposes are necessary for the provision of services.

 

Management of Social Media and Followers
Legal basis	Explicit consent of the data subject (GDPR: Article 6(1)(a) – Consent of the data subject).
Purposes	Increase the visibility of Lift Asset Management and its related funds, strengthening its market presence and brand; Create, manage, and publish content on social media to inform and promote Lift Asset Management’s services; Interact with followers and respond to enquiries regarding investment products and services; Monitor social media activity to analyze impact and follower response, optimizing communication strategies.
Categories of data and data subjects	Followers (Identifying data)
Source of data	The data subject themselves or their legal representative
Categories of recipients	Social media service providers
International transfers	None envisaged
Retention period	Until the data subject requests their erasure. The personal data provided will be retained as long as they are necessary or relevant for the purpose for which they were collected or recorded. We are required to block the data when erasure is applicable. Data blocking consists of identifying and reserving the data, adopting technical and organizational measures to prevent their processing, including their display, except for making the data available to judges and courts, the Public Prosecutor’s Office, or the competent Public Administrations, in particular data protection authorities, for the establishment of potential liabilities arising from the processing, and for a period of three years, which is the applicable limitation period. Blocked data may not be processed for any purpose other than the one indicated.
Security measures	Access control and authentication: Restricting access to social media accounts to authorized personnel only, with two-factor authentication to protect the accounts. Monitoring of published content and comments: Continuous monitoring of posts and comments to prevent improper processing of personal data and to detect inappropriate content. Privacy Impact Assessments: Periodic assessments to analyze risks associated with data processing on social media and to optimize information security. Backup of published data: Backing up content and comments on social media to ensure availability in the event of incidents. Training in social media best practices: Ongoing training for staff responsible for managing social media on data protection regulations and secure user interaction practices.

 

Newsletter Subscription
Legal basis	(GDPR Article 6(1)(a)) Consent of the data subject
Purposes	Periodically sending informative, promotional, and up-to-date content about Lift Asset Management’s services, products, and investment funds; Managing user subscriptions to Lift Asset Management’s corporate newsletter; Keeping users informed about events, articles, and relevant news of the organization and the investment sector.
Categories of data and data subjects	Subscribers (Identifying data)
Source of data	The data subject themselves or their legal representative
Categories of recipients	Entities within the corporate group
International transfers	None envisaged
Retention period	Until the data subject requests their erasure. The data will be retained as long as the user maintains an interest in receiving the newsletter. Upon unsubscribing, the data will be blocked for a period of three years in order to comply with the limitation periods for potential liabilities, allowing access only to competent authorities if required.
Security measures	Access control to the subscriber database: Limiting access exclusively to authorized personnel responsible for communication and marketing. Data encryption: Implementation of encryption during transmission of subscription data and storage of email addresses, ensuring information confidentiality. Unsubscribe mechanism in each mailing: Inclusion of an automatic unsubscribe link in each newsletter, allowing users to easily withdraw their consent. Audit and control of consent records: Maintaining an up-to-date consent register, allowing verification of user consent at any time. Impact assessments and security audits: Periodic privacy impact assessments and security audits to ensure regulatory compliance.

 

Cookies, Pixels, and Tracking
Legal basis	(GDPR Article 6(1)(a)) Consent of the data subject
Purposes	Web Analytics: Perform statistical analysis of user navigation to optimize website content and usability. Issue Identification: Detect technical and navigation issues on the website to ensure optimal performance. Personalization: Retain user preferences (such as language) to improve the browsing experience.
Categories of data and data subjects	Website users (Identifying data; Other categories)
Source of data	The data subject themselves or their legal representative
Categories of recipients	Companies engaged in advertising or direct marketing
International transfers	None envisaged
Retention period	You should consult our Cookie Policy to find out the retention period of each cookie as well as the information collected.
Security measures	Access control: Limiting access to analytics and tracking data exclusively to authorized Lift Asset Management personnel and providers acting as data processors. Consent management: Implementation of a cookie banner to transparently collect and manage user consent, allowing preference customization. IP and navigation data anonymization: Use of anonymization and pseudonymization techniques on navigation data whenever possible to minimize risk. Encryption of data in transit: Protection of navigation and tracking data through encryption during transmission. Privacy Impact Assessment: Periodic assessments to verify risks and ensure compliance with applicable regulations. Third-party auditing and monitoring: Regular supervision of tracking providers and platforms to ensure data protection and compliance with privacy policies.

 

11. DATA RELATING TO MINORS

How do we handle data relating to minors?

Minors under the age of 14 may not use the services offered through our website without the prior authorization of their parents, guardians, or legal representatives. Such persons shall be solely responsible for all actions carried out through the website by the minors under their care, including the completion of online forms containing the minors’ personal data and, where applicable, the selection of the corresponding consent checkboxes.

In accordance with Article 8 of the GDPR and Article 7 of the LOPD/GDD, only individuals over the age of 14 may give valid consent for the lawful processing of their personal data by Lift Asset Management.

 

12. SOURCE AND TYPES OF DATA PROCESSED

Where have we obtained your data from?

What types of your data have we collected and process?

 

13. RIGHTS OF DATA SUBJECTS

What rights do you have in relation to your data?

Data protection regulations grant you specific rights that you may exercise in relation to the processing of your data. These rights are personal and non-transferable, meaning that only you, as the data subject, may exercise them after verification of your identity.

The following rights are available to you:

• Right of access: You may request confirmation as to whether Lift Asset Management is processing your data and access information related to such processing.
• Right to rectification: If your personal data is inaccurate or incomplete, you may request its correction.
• Right to erasure (“right to be forgotten”): You may request the deletion of your data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent.
• Right to restriction of processing: You may request the restriction of the processing of your data, for example while its accuracy is being verified or in other cases provided by law.
• Right to data portability: You have the right to receive your data in a structured, commonly used, and machine-readable format and to transmit it to another data controller.
• Right to object: You may object to the processing of your data on grounds relating to your particular situation, or where the processing is based on legitimate interest.
• Right not to be subject to automated decision-making: You may request not to be subject to decisions based solely on automated processing of your data, including profiling.
• Right to withdraw consent: You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
• Right to lodge a complaint: If you believe your rights have not been respected, you may lodge a complaint with the competent supervisory authority: Spanish Data Protection Agency | Email: info@aepd.es – Website: https://www.aepd.es
• To exercise any of these rights, you may contact Lift Asset Management using the following contact details:
  • Controller: LIFT ASSET MANAGEMENT SL
  • Address: Paseo de Recoletos 16, 7th Floor, 28001, Madrid (Madrid), Spain
  • Telephone: +34 918 280 295
  • Email: info@lift-am.com
  • Website: https://lift-am.com

You may also exercise your rights through the Data Protection Officer:

• Email: rgpd@auratechlegal.es
• Telephone: +34 911 134 963

How can you exercise your rights in relation to your data?

To exercise your rights of access, rectification, erasure, restriction, objection, data portability, and withdrawal of consent, you may do so by sending an email to rgpd@auratechlegal.es or info@lift-am.com, or by sending postal mail to Paseo de Recoletos 16, 7th Floor, 28001, Madrid (Madrid), Spain.

How can you lodge a complaint if you believe your rights are not being respected?

If you believe that the processing of your personal data does not comply with data protection regulations, you have the right to lodge a complaint with the relevant Supervisory Authority in your country of residence or place of activity.

Depending on your location, you may contact the competent authority in your country. For example:

• In Germany, you may contact the Berliner Beauftragte für Datenschutz und Informationsfreiheit.
• In France, the competent authority is the Commission Nationale de l’Informatique et des Libertés (CNIL).

The specific contact details for Spain are as follows:

• Spanish Data Protection Agency
  Calle Jorge Juan 6, 28001, Madrid (Madrid), Spain
  info@aepd.es – +34 912 663 517
  https://www.aepd.es

If you are unsure which authority applies to you or need information about other supervisory authorities, you may consult the article on Data Protection Supervisory Authorities , where you will find contact details and links according to your location.

 

14. AMENDMENT AND INFORMATION PRINCIPLE

This document ensures that you understand how we process your personal data. By using our website or services, you confirm that you have been informed of the terms of our Privacy Policy, in accordance with the information principle established in Article 13 of the GDPR. The legal bases for the processing of your personal data are set out in Article 6 of the GDPR and may include, among others, the performance of a contract, compliance with legal obligations, or legitimate interest.

This policy has been prepared with the collaboration of Auratech Legal, a law firm specialising in data protection, and will be periodically reviewed to ensure its adequacy and compliance.

Lift Asset Management reserves the right to modify this Privacy Policy in response to legislative changes, case law developments, or guidelines issued by supervisory authorities. Any relevant modification affecting the purposes of processing, retention periods, or users’ rights will be expressly communicated.

 

Last updated: 15 November 2024