Privacy policy
Information on the processing of personal data
Data controller
The data controller responsible for processing your personal data is VALUE TREE A.V., S.A. (“Value Tree”), with tax identification number A83003574, registered office at Paseo Eduardo Dato 21, Ground Floor Left, Madrid, Spain, and telephone number +34 91 781 24 10.
Value Tree has appointed a Data Protection Officer (DPO), who may be contacted at:
Email: staff@rcmjit.com
Postal address:
Data Protection Officer
Calle Norias 25
28220 Majadahonda, Madrid, Spain.
Purposes of processing
Purposes requiring your consent
Subject to your consent, Value Tree may carry out commercial activities, including sending communications related to its business activities and services, by any means, including electronic communications.
Refusing consent for these purposes will not affect the maintenance or performance of any contractual relationship with Value Tree.
Main purposes of processing
Compliance with legal obligations
Value Tree may process your personal data to comply with legal obligations, including regulations applicable to investment firms and anti-money laundering and counter-terrorist financing legislation.
This may include:
- Reporting information to the Financial Ownership Register maintained by the Spanish authorities.
- Providing payment transaction information to public authorities and official bodies inside and outside the European Union where required by anti-money laundering, anti-terrorism financing or organised crime prevention regulations.
- Implementing measures aimed at preventing, investigating and detecting fraud.
Performance of a contract
Your personal data will be processed for the purpose of managing the products and services you request or contract with Value Tree.
To ensure proper performance of contractual obligations and compliance with regulatory requirements, Value Tree may update your information using:
- Publicly available sources (such as public registries or land registries).
- Information you have made publicly available (including social media).
Where you act on behalf of a legal entity, your personal data will be processed in connection with the management of services provided to that entity.
Information about products and services that may interest you
Where you have not objected and can reasonably expect such communications, Value Tree may contact you by any communication channel, including electronic means, regarding products or services similar to those already contracted with the firm.
This processing is based on Value Tree’s legitimate interest and will continue for up to one year after the end of the contractual relationship.
You may object to such processing at any time by exercising your rights as described below.
Information about other products and services
Where you have expressly consented, Value Tree may:
- Inform you about products or services offered by Value Tree, affiliated companies, subsidiaries, investee companies or third parties with whom Value Tree has entered into collaboration agreements.
- Share your personal data with affiliated companies so that they may contact you regarding products and services that they market.
- Personalise communications and offers based on your profile, preferences and needs.
Such consent will remain valid for up to one year unless withdrawn earlier.
Personalisation of commercial communications
To tailor communications and develop new products and services, Value Tree may analyse:
- Information provided by you during the contractual relationship.
- Demographic information.
- Information relating to other products held with Value Tree.
- Transactional activity and savings capacity.
- Anonymised geo-statistical information.
Where consent has been provided, Value Tree may supplement this information using:
- Publicly available sources.
- Information made public by you, including social media.
- Information obtained from third parties.
Value Tree also uses anonymised data to develop predictive behavioural models for commercial and product development purposes.
Data retention
Your personal data will be retained for as long as necessary to provide the contracted services.
Once no longer required, the data will be blocked and retained only for the period necessary to address potential administrative, legal or judicial claims. After this period, the data will be permanently deleted.
Where consent has been provided for commercial communications, personal data may be retained for up to one year following termination of the contractual relationship.
Legal basis for processing
The legal bases for processing personal data are:
| Purpose | Legal basis |
|---|---|
| Compliance with legal obligations | Legal obligation |
| Provision of products and services | Performance of a contract |
| Marketing of similar products and services | Legitimate interest |
| Marketing of unrelated products and services | Consent |
| Sharing data with affiliated companies | Consent |
| Personalisation and profiling | Legitimate interest and/or consent, depending on the processing activity |
Withdrawal of consent will not affect any products or services already contracted.
Recipients of personal data
Personal data may be disclosed to:
- Public administrations, regulators, courts and supervisory authorities.
- Group companies and affiliated entities.
- Service providers acting as data processors.
- Credit information agencies and similar organisations where legally permitted.
Service providers may include companies operating in areas such as:
- Technology and IT services.
- Legal advisory services.
- Professional services.
- Security services.
- Infrastructure management.
- Logistics and communications services.
- Call centre services.
Your rights
You may exercise the following rights, subject to applicable law:
- Right of access.
- Right to rectification.
- Right to erasure.
- Right to object.
- Right to restriction of processing.
- Right to data portability.
You may also:
- Withdraw any consent previously granted.
- Object to processing carried out for direct marketing purposes.
To exercise your rights, you may contact Value Tree through:
Telephone: +34 91 781 24 10
Website: www.valuetree.es
Postal mail: VALUE TREE A.V., S.A.
You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD).
Source of personal data
Value Tree processes:
- Information provided directly by you when contracting products and services.
- Information generated through your use of those services.
- Information obtained from public sources.
- Information obtained from companies within the Value Tree group and collaborating entities.
- Information from credit reference agencies and financial risk databases where permitted by law.
Categories of data processed may include:
- Identification data.
- Personal and social characteristics.
- Professional and academic information.
- Commercial information.
- Financial, economic and creditworthiness information.
- Transaction data.
Data storage and international transfers
Personal data is stored within the European Economic Area (EEA).
Value Tree does not transfer personal data outside the EEA unless required by law.