OVERVIEW

The purpose of this “Privacy and Data Protection Policy” is to publicize the conditions governing the collection and processing of your personal data by LIFT Investment Advisors EAFI S.L to ensure fundamental rights, their honor and freedoms, all in compliance with the current regulations governing the protection of personal data according to the European Union and the Spanish Member State.

In accordance with these regulations, we need to have your authorization and consent for the collection and processing of your personal data, so all the details that could be of your interest regarding how we perform these processes, for what purposes, that other entities may have access to your data and what your rights are, are outlined below.

For all these reasons, once our Data Protection Policy is reviewed and read, it is essential that you accept it in proof of your compliance and consent.

REPONSIBLE FOR DATA PROCESSING

Who collects and processes your data?

The Data Controller is a natural or legal person, of a public or private nature, or administrative body, who alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of the processing are determined by regulations of the European Union or the Spanish Member State.

In this case, our identifying data as Data Controller are as follows: LIFT Investment Advisors EAFI S.L CIF B87425187

How can you contact us?

Mailing address and our offices: Calle Velázquez, 41, 1º B. 28001 Madrid
Registered office: Calle Velázquez, 41, 1º B. 28001 Madrid
Email: info@lift-am.com- Phone: 918 280 295

Who can help you with our Data Protection Policy?

We have a person or entity specialized in data protection, which is responsible for ensuring the correct compliance in our entity with the current legislation and regulations. This person is known as the Data Protection Officer (DPO) and, if needed, can contact him as follows:

AURATECH LEGAL SOLUTIONS SL- CIF B87984621
Email: rgpd@auratechlegal.es- Phone: 0034 91 113 49 63

SAFETY MEASURES

LIFT Investment Advisors EAFI S.L adopts the necessary organizational and technical measures to guarantee the security and privacy of your data, prevent its alteration, loss, treatment, or unauthorized access, depending on the state of technology, the nature of the data stored and the risks to which they are exposed.
Among others, the following measures stand out:

• Ensure the permanent confidentiality, integrity, availability and resilience of treatment systems and services
• Restore availability and access to personal data quickly, in the event of a physical or technical incident.
• Check, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to ensure the security of the treatment.
• Pseudonymize and encrypt personal data, in case it is sensitive data.

PURPOSES FOR PROCESSING

What do we want to process your data for?

We need your authorization and consent to collect and process your personal data, so below we detail the intended uses and purposes:

Web users: Respond to requests through the website.

Newsletter subscriber management: Sending publications to which you have subscribed through the form on our website.

How long do we keep your data?

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

Web users: For a period of 5 years from the last confirmation of interest. The personal data provided will be kept as long as its deletion is not requested by the data subject, and if they are necessary – including the need to keep them for the applicable limitation periods – or relevant to the purpose for which they were collected or registered.

Newsletter subscriber management: As long as its deletion is not requested by the interested party. The personal data provided will be kept as long as they are necessary or relevant for the purpose for which they were collected or registered, and if it does not revoke the consent given.

LEGITIMATION OF PROCESSING

Why do we process your data?

The collection and processing of your data is always legitimized by one or more legal bases, which we detail below:

Web users: Explicit consent of the data subject

Subscriber Management Newsletter: (Art. 6.1.a GDPR) Data Subject Consent

RECIPIENTS OF YOUR DATA

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

We do not transfer your data to third parties or entities, except legal obligation.

Do we make international transfers of your data outside the European Union?

We do not make international transfers of your data.

SOURCES AND TYPES OF DATA PROCESSED

Where did we get your data?

Web users

Web Contacts: The data subject himself or his legal representative Newsletter managing subscribers.

Subscribers: The data subject himself or his legal representative

What types of data have we collected and process from you?

Web users Web contacts

Identification data (Electronic address; First and Last Name; Phone)

Subscriber Management Newsletter Subscribers

Identification data (Name and Surname; E-mail address; Phone)

RIGHTS OF INTERESTED PARTIES

What are the rights that protect you?

Current data protection regulations protect you with several rights in relation to our use of your data. Each and every one of its rights are single-person and non-transferable, that is, they can only be performed by the data subject, subject to verification of their identity.
Here are the rights that assist you:

• Request ACCESS to your personal data
• Request the RECTIFICATION of your data
• Request the DELETION of your data (right to “forgotten”)
• LIMIT or OPPOSE our use of your data
• Right to PORTABILITY of your data for cases of telecommunications or internet services.
• Right to WITHDRAW your consent at any time
• Right to present a data protection CLAIM to the Supervisory Authority: Spanish Data Protection Agency

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

For the exercise of your rights of access, rectification, deletion, limitation or opposition, portability, and withdrawal of your consent, you can do so as follows:

• Responsible: LIFT Investment Advisors EAFI S.L
• Address: Paseo de la Castellana 123 Esc.dc 9ºB . 28046, Madrid, Spain
• Website: https:/ lift-am.com/

How can I file a claim?

In addition to your rights, if you believe that your data is not being collected or processed in accordance with current data protection regulations, you may make a complaint to the Supervisory Authority, whose contact details we indicate below:
Spanish Data Protection Agency
C/. Jorge Juan, 6. 28001, Madrid (Madrid), Spain
Email: info@aepd.es- Phone: 912663517
Web: https:/ www.aepd.es

CONSENT AND ACCEPTANCE

Your acceptance of this document indicates that you understand, accept all the clauses of our privacy policy and authorize the collection and processing of your personal data in these terms. This acceptance is made by selecting the “Read and Accept” checkbox in our Privacy Policy.