Access to this Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each User - in the different devices that may be used to navigate - so that the server remembers certain information that subsequently and only the server that implemented it will read. Cookies make browsing easier, more user-friendly, and do not damage the browsing device.

Cookies are automatic procedures for collecting information relating to the preferences determined by the User during his visit to the Website in order to recognize him as a User, and personalize his experience and use of the Website, and may also, for example, help to identify and resolve errors.

Information collected through cookies may include the date and time of visits to the Website, the pages viewed, how long you have been on the Website, and the sites visited just before and just after the Website. However, no cookie allows this cookie to contact the User's telephone number or any other means of personal contact. No cookie can extract information from the User's hard drive or steal personal information. The only way for the User's private information to be part of the Cookie file is for the User to personally give that information to the server.

Cookies that allow a person to be identified are considered personal data. Therefore, the Privacy Policy described above shall apply to them. In this sense, for the use of the same will require the consent of the User. This consent will be communicated, on the basis of a genuine choice, offered by an affirmative and positive decision, before the initial processing, removable and documented.

Own cookies
They are those cookies that are sent to the User's computer or device and managed exclusively by Stelvio for the better functioning of the Website. The information collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies make it possible to recognize the User as a repeat visitor to the Website and adapt the content to offer content that suits your preferences.

Disabling, rejecting and deleting cookies
The User can disable, reject and delete cookies -totally or partially- installed on your device by configuring your browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must follow the instructions provided by the Internet browser that he/she is using. In the event that you reject the use of cookies - in whole or in part - you may continue to use the Website, although the use of some of its features may be limited.

I. PRIVACY AND DATA PROTECTION POLICY
Respecting the provisions of current legislation, Stelvio undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected through the Website.

Identity of the person responsible for the processing of personal data
The person responsible for the processing of personal data collected on the website, www.steviopartners.com (hereinafter, the "Website") is: STELVIO ADVISORY PARTNERS, S.L.U., with Tax Identification Number: B-87917613 and registered in: Commercial Registry of Madrid with the following registry data: Volume 36.464, Folio 51, Section 8, Page M-654585 and 1st inscription, whose representative is: Daniel Lainsa (hereinafter, Data Controller). His contact details are as follows:

Dirección: Calle Pinar 5, 28006 Madrid, España

Contact telephone number: +34 91 745 58 31

Contact Email: info@stelviopartners.com

Personal Data Registry
In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Stelvio, through the forms on their pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between Stelvio and the User or the maintenance of the relationship established in the forms that this fill, or to respond to a request or query from the same.

Furthermore, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR"), and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights ("LOPD-GDD"), unless the exception provided for in Article 30. 5 of the GDPR, a register of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data
The processing of the User's personal data shall be subject to the following principles contained in Article 5 of the RGPD and in Article 4 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the consent of the User will be required at all times after fully transparent information of the purposes for which personal data are collected.


• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.


• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.


• Principle of accuracy: personal data must be accurate and always up to date.


• Principle of limitation of the storage period: personal data will only be kept in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.


• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.


• Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data
The categories of data processed by Stelvio are solely identification data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data
The legal basis for the processing of personal data is consent. Stelvio undertakes to obtain the express and verifiable consent of the User for the processing of his personal data for one or more specific purposes.

The User shall have the right to withdraw consent at any time. It shall be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

In the occasions in which the User must or may provide his/her data through forms to make inquiries, request information or for reasons related to the content of the Website, he/she will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing for which the personal data is used
Personal data is collected and managed by Stelvio for the purpose of contacting the User within the framework of the professional relationship, or to respond to a request or inquiry from the User.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses to which the collected information will be put.

Retention periods of personal data
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period, and unless the User requests their deletion:

(i) When we process your data to manage the contractual relationship, we will keep it for as long as the relationship remains in force.

(ii) When the User makes an inquiry made through our website, we will process your data for the time necessary to manage and resolve the inquiry.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data
The User's personal data will not be shared with third parties.

In any case, at the time the personal data is collected, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors
In compliance with the provisions of Articles 8 of the GDPR and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Stelvio. In the case of a minor under 14 years of age, the consent of the parents or guardians is required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data
Stelvio undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Web Site has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, because Stelvio cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights deriving from the processing of personal data
The User has over Stelvio and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the right of the User to obtain confirmation of whether or not Stelvio is processing their personal data and, if so, obtain information about their specific personal data and the treatment that Stelvio has done or will do, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned thereof.


• Right of rectification: This is the User's right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.


• Right of deletion ("the right to be forgotten"): This is the User's right, unless otherwise provided for by the legislation in force, to obtain the deletion of his or her personal data when such data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Controller, taking into account the technology available and the cost of its implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject's request for the deletion of any link to such personal data.


• Right to limitation of processing: This is the User's right to limit the processing of his/her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.


• Right to data portability: In case the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Data Controller. Whenever technically possible, the Controller shall transmit the data directly to such other controller.


• Right of opposition: This is the User's right not to have his or her personal data processed or to cease the processing of such data by Stelvio.


• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by applicable law.

Thus, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD-www.stelviopartners.com", specifying:

• Name, surname of the User and copy of the ID card. In cases where representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be replaced by any other means valid in law that proves the identity.
• Request with the specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request you are making.

This application and any attachments may be sent to the following address and/or e-mail address:

Mailing address: Avda. Doctor Arce 14, 28002 Madrid, España

E-mail: info@stelviopartners.com

Links to third party websites
The Web Site may include hyperlinks or links that allow access to third party websites other than Stelvio, and therefore are not operated by Stelvio. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority
In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY
It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Web Site will imply the acceptance of the Privacy Policy of the same.

Stelvio reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

I. GENERAL INFORMATION

Identity of the holder
In compliance with the duty of information provided for in Law 34/2002 of Services of the Information Society and Electronic Commerce (LSSI-CE) of July 11, the following general information about this website is provided below:

The ownership of this website, www.stelviopartners.com, (hereinafter Website) is held by: STELVIO ADVISORY PARTNERS, S.L.U., with Tax Identification Number: B-87917613 and registered in: Commercial Registry of Madrid with the following registry data: Volume 36.464, Folio 51, Section 8, Page M-654585 and 1st inscription,

Contact details

Address: Calle Pinar 5, 28006 Madrid, Spain

Contact telephone number: +34 91 745 58 31

Contact email: info@stelviopartners.com

II. GENERAL TERMS AND CONDITIONS OF USE

User Acceptance
The access, browsing and use of the Website, confers the condition of User.

The User accepts, from the moment he/she starts browsing the Website, the present Terms of Use as well as our Privacy Policy and our Cookies Policy.
To navigate through the Website, the User is not required to register or provide any personal data to Stelvio.

However, the User may contact Stelvio through the form provided on the Website, which will have to outline certain personal data.

In relation to personal data that are collected, Stelvio will take the necessary technical and organizational measures to ensure their protection and prevent their alteration, loss, treatment and / or unauthorized access, given the state of the art, the nature of the data stored and the risks to which they are exposed, complying at all times with the applicable regulations.

The User assumes responsibility for the correct use of the Website.

III. ACCESS AND NAVIGATION ON THE WEBSITE: DISCLAIMER OF WARRANTIES AND LIABILITY

Stelvio will make every effort for the proper functioning of the Website, however, does not guarantee the continuity, availability and usability of the Website, nor assumes any liability for any damages that may arise from disconnections, interference or interruptions that may occur in accessing or browsing the Website, nor for damages that may arise for the User or third parties from the existence and spread of computer viruses or other harmful elements.
Stelvio also assumes no responsibility for any errors or omissions that may be in the content of the Website, nor for the actions that the User may perform on the basis of such content.

IV. LINKS POLICY
Reproduction - in whole or in part - of any of the content and / or services of the Website is not permitted without the express permission of Stelvio.

V. INTELLECTUAL AND INDUSTRIAL PROPERTY
Stelvio is the owner of all intellectual and industrial property rights in the Website.

Stelvio does not assign to the User any intellectual or industrial property rights over the contents or elements comprising the Website.

Reproduction, distribution and public communication, including its mode of making available, of all or part of the contents of this website, for commercial purposes, in any medium and by any technical means, without the authorization of Stelvio is expressly prohibited.

VI. LEGAL ACTIONS, APPLICABLE LAW AND JURISDICTION
The relationship between the User and Stelvio shall be governed by the laws of Spain.

Should any dispute arise in connection with the interpretation and/or application of these Terms and Conditions, the parties shall submit their disputes to the Courts and Tribunals of Madrid.