Privacy Policy

What is the scope of this policy?

GPF PARTNERS S.G.E.I.C., S.L. (hereinafter, “GPF”) is committed to protecting the privacy of its customers and users who access our website: https://gpf- partners.com/ (hereinafter, “the Website”).

The contents of the website are owned or operated, licensed, or controlled by GPF.

The use of this website confers the status of user (hereinafter, the “user”) on individuals who access it.

Users are not required to register in order to use the website.

Users can browse and use the Website without providing any personal data. The only personal data to which GPF will have access will be that which users voluntarily provide through the forms contained on the website or when contacting GPF by email or any other means provided on the Website.

If personal data is collected through cookies, you will be duly informed through the Cookies Policy, as well as through the channels required by current legislation.

This document sets out how GPF uses the user’s personal data collected through our website or auxiliary devices such as mobile phones or tablets, as well as the user’s rights in relation to the processing of their personal data. Likewise, the use of the website implies the user’s acceptance of the provisions contained in this Privacy Policy and that their personal data will be processed in accordance with the provisions thereof.

In compliance with the provisions of Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights, and in accordance with the provisions of and current regulations, we hereby inform you of the following:

Who is responsible for processing your data?

The Data Controller for your personal data is:

GPF PARTNERS S.G.E.I.C., S.L.

Tax ID Number: B87074910

Address: Calle Velázquez 86-D – 1st Floor, 28006, Madrid Email: info@gpf-partners.com

Tel: (+34) 91 737 81 95

Registration in the Madrid Commercial Registry ( ), volume 32795, folio 180, page number M-590.311.

Contact details of the Data GRUPO ATICO34, S.L. – lopd-gdd@atico34.com

What types of data are processed?

Users can provide the following contact details on the contact form: First name, last name, email address, and telephone number.

How do we obtain your data?

We will process the data that users have provided directly when interacting with GPF or by any other means as a result of accessing and using the website (such as cookies and other analysis or tracking technologies that may be used to collect certain information when you visit our website located at https://gpf-partners.com/ or third-party sites to which we direct you, or which you access in order to communicate with you about our products and services). For more information about our automatic collection tools, please see our Cookie Policy.

For what purposes will we process your personal data?

GPF will process personal data in a lawful, fair, transparent, adequate, relevant, limited, accurate, and up-to-date manner for the following purposes:

PURPOSE	LEGAL BASIS FOR DATA PROCESSING
To respond to and resolve user requests and inquiries made via the contact email address on our website (info@gpf-partners.com ) or the contact telephone number on the website ((+34) 91 737 81 95) in relation to investment funds, etc.	Express consent to the extent that the user expressly consents by sending the email or making the relevant phone call. In the event that the request relates to the exercise of rights, our legitimacy will be the fulfillment of a legal obligation.

Will automated decisions be made?

We do not make automated decisions based on profiles, except for the personalization of advertising and the prevention of internet fraud.

With the information collected about your preferences based on your activities when you use our website, we create a user profile to personalize and enhance the quality of our communication and interaction with you. The logic behind our profiling activities is to identify areas that may be useful or of interest to you and to inform you about those areas in a more efective and targeted manner. The algorithms used apply this logic and automatically deliver targeted content or information to you.

In accordance with the General Data Protection Regulation (Article 21 (2)), you have the right to object to the use of your personal data for direct marketing purposes, including the profiling described above. Please refer to the section “Your data protection rights” for more information about your rights and how to exercise them.

Where is the data stored?

Personal data is stored on secure servers located within the European Economic Area. GPF ensures that these servers comply with applicable data protection regulations, including the technical and organizational measures necessary to safeguard the security and integrity of the information.

How long will we keep your data?

Personal data will be kept for the duration of the provision of services and for the time necessary to comply with legal obligations. In any case, the information collected by our cookies will be kept for the period indicated in the Cookies Policy.

Is your personal data transferred to third parties?

Information about our users is very important to us, so we will only transfer data for the purposes set out above. Notwithstanding the above, if we have to transfer your data to groups or individuals not mentioned in this paragraph, we will inform you in advance to allow you to object to such transfer.

In this regard, we inform you that your data may be transferred to:

The company that GPF uses for hosting. Specifically, for the private area, you can consult more details of their privacy policy via the following link: https://dinahosting.com/legal/proteccion-datos
Depository bank EFG Bank (Luxembourg) S.A. to initiate the KYC process for a legal entity investor. You can consult more details of their privacy policy via the following link: https://www.efginternational.com/website-privacy- policy.html
Data processors necessary for the provision of the service with whom we have signed a service provision contract that obliges them to maintain confidentiality and security measures.
Authorities or other third parties in cases where required by law or in the context of legal proceedings.

Are there any international data transfers?

GPF will not transfer your personal data to recipients in countries outside the European Economic Area.

What are your rights when you provide us with your data?

Users may exercise their rights of rectification, restriction of processing, erasure, objection, and the right not to be subject to automated individual decision-making by sending a signed written request, including their name, surname(s), and a photocopy of their ID card or other valid supporting document, to GPF at the above address or by contacting us at info@gpf-partners.com .

We may request additional proof of identity to protect your personal data from unauthorized access. We will carefully consider your request and may discuss with you the best way to satisfy it.

The exercise of these rights is free of charge, unless unfounded or excessive requests are made, in which case the user will bear the cost of processing the request.

If you have any questions about how we process your personal data or wish to make a complaint about how we have processed your personal data, you can contact us at the contact address indicated above. listed below so that the matter can be investigated. If you are not satisfied with our response or believe that your rights have not been properly addressed, you have the right to file a complaint with the Spanish Data Protection Agency at www.aepd.es

What if the user is under 16 years of age?

If you are under 16, you must obtain permission from your parents or guardians before providing us with your personal data. Minors under 16 cannot provide us with their personal data without such consent.

Social Media

GPF may also use social media, such as LinkedIn. For more information about these, you can consult their Privacy Policies at the following links:

Link: https://es.linkedin.com/legal/privacy-policy?

How do we protect your personal data?

GPF informs you that it has adopted the necessary technical and organizational measures to maintain the required level of security in relation to the personal data processed and has also implemented the necessary mechanisms to prevent, as far as possible, unauthorized access, theft, unlawful modification, and loss of data.

We have physical, electronic, and procedural security systems in place in relation to the collection, storage, and disclosure of users’ personal information.

In compliance with current regulations, GPF undertakes to comply with its obligation of secrecy regarding the personal data that users provide us with while browsing this website and its duty to keep such data confidential.

In cases of personal data security breaches that pose a risk to users’ rights, GPF will take the necessary measures to remedy the situation and mitigate any possible negative efects that such a breach may have.

What cookies do we use?

Without prejudice to the Cookies Policy, this website uses Google Analytics, a web analytics service provided by Google, Inc., a Delaware company whose main ofice is at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of tracking your use of the website, compiling reports on website activity, and providing other services related to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the processing of data or information by rejecting the use of cookies by selecting the appropriate settings on your browser; however, you should be aware that if you do so, you may not be able to use the full functionality of this website. By using this website, you consent to the processing of information about you by Google in the manner and for the purposes indicated above.

How do we protect our website in terms of intellectual and/or industrial property?

All the contents of the website are protected by intellectual property rights.

This includes, but is not limited to, the graphic design, source code (except for logos, texts, graphics, illustrations, photographs, language code, software, and other elements that appear on the website). Therefore, the user acknowledges that the reproduction, distribution, commercialization, transformation, and in general, any other form of exploitation, by any procedure, of all or part of the contents of this website constitutes an infringement of the intellectual and/or industrial property rights of GPF or the owner thereof.

The trademarks or distinctive signs of any kind contained on the website are also protected by law.

Under no circumstances may the user modify or use said intellectual or industrial property in such a way that its disclosure causes damage to GPF, in which case it will claim damages arising from the misuse of its intellectual and industrial property by third parties.

GPF does not grant any license or authorization of use of any kind over its industrial and/or intellectual property rights or over any other property.

What automatic information do we collect when you use this website?

Here are some examples of the information we collect and analyze: The Internet Protocol (IP) address you use to connect to the Internet with your computer, information about your computer and your Internet connection, and the version and type of your browser; your time zone settings, the types and versions of your browser’s connection, the operating system and platform you use, the “visit history” of web pages (URLs) from, through, and to our website (including date and time), number of cookies, any phone number you have used to call our customer service. We may also use browser data such as cookies, Flash cookies (also called Local Shared Objects), or similar data in certain places on our website to prevent fraud, among other purposes.

During your visits to the website, we may use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, information about page interaction (mouse clicks, scrolling down the page, or number of times you hover over certain items), and ways you exit the website. We may also collect technical information that helps us identify your device for diagnostic analysis and fraud prevention purposes.

How should you contact GPF?

If you have any questions regarding GPF’s privacy policy, please send us an email to info@gpf-partners.com , detailing the reasons for your query, and we will try to resolve it.

Responsibility for the accuracy and veracity of data

The user is responsible for the accuracy and veracity of the data provided to GPF through any form or means of contact enabled in our services. The interested party undertakes to keep the data provided duly updated and to communicate any changes to GPF as soon as possible. When the data provided is false, incomplete, out of date, or inaccurate, the user will be solely responsible for any direct or indirect, material or immaterial damage that may be caused to third parties or to GPF as a result. However, GPF will implement reasonable measures to verify the identity of users and maintain the quality of the data during its processing, as well as to facilitate the exercise of the rights of access, rectification, erasure, restriction of processing, portability, and objection by the interested parties. GPF reserves the right to suspend the services provided to the user, as well as to terminate any contractual relationship, without prejudice to any other actions that may be applicable by law, when the provision of false or inaccurate data is detected.

Modification of GPF’s privacy policy

GPF may modify and update this Privacy Policy as necessary to reflect any changes in the way we use user data or changes in legal requirements. Therefore, the user must check that they are up to date with our Privacy Policy, Cookies Policy, and Terms and Conditions of Use in order to be informed at all times of the content that is collected through the website, how we use it, and the circumstances under which it may be disclosed to third parties. Any changes to the modified data privacy notice policy will apply from the date they are published on our website.

Notwithstanding the provisions of the previous paragraph, any changes that may afect the commercial relationship between the parties will be notified.