The Data Controller is “ALTER5 FINANCIAL TECHNOLOGIES S.L.”, with its registered office at Madrid, Manuel Pombo Angulo St., 10 – Floor 1, Office 2, (28050) and with Corporate Tax Identification Number B-88357769 (hereinafter “Alter 5”), a Spanish company duly incorporated and existing under the laws of Spain for an indefinite period of time and registered with the Commercial Registry of Madrid under volume 24.985, Page 192, Section 8, Sheet M-449888, is the owner and administrator of the domain name www.alter-5.com ( the “Web” or the “Website”).

You can contact Alter 5 at the following email address info@alter-5.com.

Alter 5 takes the privacy of Users very seriously, guaranteeing the confidentiality of the Personal Data to which it has access, and that this processing will always be carried out in accordance with this Privacy Policy and the applicable data protection and privacy legislation at all times. Alter 5, in its capacity as the data controller, guarantees to Users that it will always apply the applicable technical and organizational security measures set out in the current legislation given the nature of the Personal Data processed and the circumstances of the processing, as well as those that are advisable given the state of technology, guaranteeing the integrity, security and confidentiality of the Personal Data.

Alter 5 will collect and process Personal Data of the Users, registered in the Website in accordance with the provisions of this Privacy Policy, as well as in accordance with the specific data protection clauses for certain services that may be applicable in each case. Compulsory Personal Data to register in the Website:

• Name and Surname
• e-mail address
• Name of the Company/Fund/Investment Vehicle/Institution and job position
• Cellphone or phone number

Alter 5 will limit the Personal Data collection and processing only to the purposes of Personal Data Processing, detailed in the following clause.

The Personal Data collected will be processed for the purpose of:

1. Provide the Products and Services.
2. Perform reports and analytics on aggregate data.
3. Create new products and services.
4. Support the User.
5. Manage the Website and the Platform.
6. Prevent fraud.
7. Commercial/Marketing communications with the users.

• Data Processors: Alter 5 will share Personal Data with Data Processors (service providers of Alter 5) with the purposes established by Alter 5 and supported by a Data Processing Agreement according to the Spanish and European regulations on Personal Data Protection. Data Controllers are inside the European Union.
• Third Parties: Alter 5 shall not share Personal Data with third parties.
• International Transactions: Alter 5 does not carry out Personal Data International Transactions. In such event, Alter 5 will comply with all the provisions established in the Spanish and European regulations on Personal Data Protection.

The personal data provided by the User will be kept by Alter 5 as long as they are necessary for the provision of the products and services. Nevertheless, Personal Data stored will be under revision periods.

The legal basis for the processing of the Personal Data by Alter 5 are:

1. The free and explicit consent of the Data Subject.
2. The provision of the Products and the execution of the Services provided by Alter5.
3. Legitimate interest of Alter 5 to send commercial/marketing communications.

The User or the Data Subject can exercise the following Rights on her/his Personal Data processed by Alter 5.

• Right of Access: an User/Data Subject has the right to access their personal data in order to verify that they are processed in accordance with the law.
• Right of Correction: an User/Data Subject has the right to request the rectification of any own data that is inaccurate or incomplete, in order to protect the accuracy of said information and adapt it to data processing.
• Right of Erasure: an User/Data Subject has the right to request that the Data Controller delete their information and that they no longer process such data. However, a series of exceptions are regulated in which this right will not proceed.
• Right to the Limitation of the Processing Data: an User/Data Subject has the right to request that the Data Controller responsible for restricting the processing of their data.
• Right to Data Portability: an User/Data Subject has the right to request the portability of the data, which means that the an User/Data Subject may receive the personal data originally provided in a structured and commonly used format or that may request the transfer of the data to another data controller.
• Right to Object: a User/Data Subject who provides personal data to a Data Controller has the right to object, at any time, to the processing of data for a number of reasons, as established in the GDPR, without the need to justify their decision.
• Right not to be Subject to Automated Individualized Decisions: an User/Data Subject has the right not to be subject to a decision based solely on automated processing, including the creation of profiles, if said profile produces a legal effect on the an User/Data Subject or affects it significantly.
• Right to file a complaint / claim to Control Authority: all Users/Data Subjects have the right to file a complaint with a Control Authority, in particular in the EU Member State of their habitual residence, place of work or place of alleged infringement if the interested party considers that the processing of personal data related to it infringes the GDPR; in Spain, the supervisory authority is the Agencia Española de Protección de Datos.
• For the exercise of these rights the User may contact Alter 5 by regular mail (address above at the identification of the data controller) or sending an e-mail to privacy@alter-5.com.

The User may find links on the Website to other websites controlled by third parties. Alter 5 does not have the power to control the content provided by these other websites and nor is it responsible for the processing of the personal data of Users that is carried out by those responsible for these websites. We remind you that this Privacy Policy is only applicable to the Personal Data collected and processed by Alter 5 through the Website. Therefore, Alter 5 accepts no responsibility for any aspect relating to the processing of User data that may be carried out by those responsible for these third party websites.

Alter 5 uses cookies, which are files that are stored on the computer of the User who accesses the Website and browses through it and, in particular, contain a number that uniquely identifies the User’s computer, even if they change location or IP address. For more information about the types of own and third-party cookies used by Alter 5, their configuration and/or deactivation, please read and accept our Cookies Policy (www.alter-5.com/cookiespolicy)

This Privacy Policy is effective as of the effective date established above. Alter 5 reserves the right to change this Privacy Policy always in accordance with the applicable laws regarding Data Protection in Spain and in Europe. If Alter 5 makes changes to this Privacy Policy, it will notify you through a notice on our website or, if appropriate, through a communication via e-mail or push notification in your user area in the Website. In any case, the date of the last update will appear in the heading of this Privacy Policy. By continuing to access or use the Alter 5 services after making such changes or updates, the user is subject to the revised Privacy Policy.

If you have questions about this Privacy Policy or about the use of your Personal Data, please send an email to privacy@alter-5.com