Personal data is any information about you, for example, your name, surname, address, email, phone number, age, and specific interests in our products. Your information will be processed in full, strict compliance with the applicable legal requirements. Because your privacy is extremely important to us, we strive to protect it.
Who is the data controller?
The entities responsible for processing your data are “EDM GESTIÓN, S.A.U. SGIIC.” and “EDM HOLDING, S.A.” (“EDM”).
What is the purpose and legal basis of processing your data?
At EDM, we mainly process your personal data in order to respond to your requests for information and manage the contracting of products and services, for example, to attend requests we receive through the online form, email, or phone. Specifically, we may process the data in order to provide you with all the information you need or request about our products and services or third party products and services sold by EDM. In short, we process your data in order to provide you with more personalised care.
We may also process your personal data to develop and maintain the contractual and/or business relationship we have formalised with you. The information you provide us serves to facilitate the process of contracting any of our products and services, and managing those you may have already contracted.
We specify below the legal basis for processing your data in each circumstance. As we indicated at the outset, we will notify you of the specific privacy terms and conditions applicable in each instance and i) when the information we request is essential to the contract you wish to formalise, ii) when and why we request information that we are legally mandated to obtain, and iii) when and why we need your authorisation to request and use your data.
a) Legitimate interest:
We need to process your data in order to offer assistance when you request it from us. You may provide this data through our website, or by email or phone, whenever you request information about our products and services, for example.
In these instances, EDM has a legitimate interest in using the information you provide. It is our belief that the interest we have in using your data to address requests from you does not harm your privacy or expectations of privacy.
b) Compliance with the contractual relationship:
Upon your request, we will process your data to facilitate the contracting of any of our products and services, and manage those you have already contracted from EDM.
In these cases, EDM must be able to process your personal data because it is considered essential information without which it is impossible to formalise, manage, and fulfil the contract you wish to sign with us, nor can we provide the services requested.
c) Compliance with legal mandate:
In certain circumstances, due to our status as an investment services provider, we must use your personal data to comply with certain legal mandates that apply to us. In these cases, to the extent possible, you will be notified and informed of the imposing regulation. The foregoing is particularly important given that we are subject to the special controls and supervisory processes of different public authorities and bodies (ie: the Bank of Spain, the CNMV, etc.).
To process your data for purposes not previously foreseen (ie: those that are not necessary to fulfil a contract, not legally binding, or for which we have no legitimate interest) your prior authorisation is required. In this instance we will inform you in detail about how we wish to use your data and for what purpose.
Will your personal data be shared?
The entities legally responsible for collecting, using, storing, and deleting your data are EDM Holding, S.A. and EDM Gestión S.A.U. SGIIC. Therefore, as a general rule, only EDM will use your data and it will not be disclosed to any third party unless required by legal mandate (ie: by law enforcement, or the courts) with your express prior consent or when it corresponds to your legitimate interest and that of EDM. With the exception of these cases, your data will not be communicated to any third party.
Nevertheless, we wish to inform you that in order to render our services, EDM relies on the collaboration of third-party service providers (ie: companies that provide tech support or call centre services), who may occasionally have access to your personal data.
In this respect, we wish to inform you that we will sign the corresponding data processing contracts with these parties, which impose the obligation to apply the appropriate technical and organisational measures and process the data only to fulfil our orders or instructions.
How long will your data be kept?
The personal data you provide will be kept for the period strictly necessary in order to manage your request and respond to your query. Once we have responded, that is, when this data is no longer strictly necessary, we will only retain the information that may be requested in certain court cases, in the event of a claim, for example. This data will be retained, duly blocked and for that purpose alone.
We may have a legal obligation to keep your data for a longer period of time if you have contracted any of our financial products or services (ie: in relation to the prevention of money laundering). In this case, we will notify you about how long we intend to keep and use your data or, failing that, how we will determine the extent of the storage period.
What are your rights when furnishing personal data?
The law recognises a series of rights that you may exercise in order to protect your privacy. We refer primarily to your right to:
Confirm whether EDM is processing your personal data. If so, you retain the right to i) access your data, ii) request rectification if the data is inaccurate or as appropriate, iii) request deletion of the data when—among other reasons—you believe it is no longer necessary, considering the original reason for the data submission.
In certain circumstances, you may also request that we limit the use of your data or even object to its continued use. In this instance, we will cease to use it, except in compelling cases, or in the support or defence of possible claims.
If we use your personal information to develop behavioural profiles (ie: to better understand your interests and needs through your browsing habits) in a fully automated way, you have the right to be informed of this and may request the personal intervention of any of our agents to challenge the decisions based on those profiles or simply to express a point of view.
You will also be entitled to request the portability of the data provided so we can send it directly to you or to the third party you designate, in a commonly used, machine-readable format.
Naturally, you have the right to revoke consent to use your personal data at any time.
Finally, if considered appropriate, you may file a claim with EDM and/or the Spanish Data Protection Agency (as the competent authority in data protection matters), especially if you have attempted unsuccessfully to exercise your rights according to the legally established terms.
In order to exercise the above rights, you may email firstname.lastname@example.org, or send a written request to Avenida Diagonal 399, 08008, Barcelona, or Paseo de la Castellana 78, 28046, Madrid.
Who is EDM’s Data Protection Officer?
EDM has a designated Data Protection Officer to protect your privacy and ensure that we comply with all the legal requirements concerning personal data protection, both Spanish and European.
You may contact the DPO at any time to receive all the information related to your personal data at: email@example.com.