Privacy Policy

BASIC INFORMATION
Data Controller	SAMAIPATA VENTURES, S.G.E.I.C., S.A.‍ CIF: A87436812

	Calle Salustiano Olózaga 5, escalera izquierda, planta 3ª, 28001, Madrid, Spain.
	Data Protection Officer: dataprotection@samaipata.vc
Purposes of the processing of personal data	- Manage and maintain the business relationship. - Attend to requests for information. - Send commercial communications of our own or of third parties, always through SAMAIPATA (including without limitation, newsletters in Samaipata’s activity). - Offer commercial communications and personalized services based on obtaining profiles and segmentation tasks. - Conduct market research and statistical analysis.


	Data retention periods: As long as the commercial relationship is maintained or its elimination is not requested by the data subject, they should not be deleted because they are necessary for the fulfillment of a legal obligation or for the formulation, exercise and defense of claims.
Source	- Provided by the users themselves. - Obtained by browsing the website.
Legal basis	- The execution of the contract with the user. - The legal obligations of SAMAIPATA. - The legitimate interest of SAMAIPATA, in relation to those processes necessary for the fraud prevention during the contracting, money laundering or commercial communications related to its products or services. - The user’s consent, to send commercial communications from third parties, always through SAMAIPATA or the installation of tracking systems according to the Cookies Policy"

Data transfers	All are necessary for the fulfillment of the above mentioned purposes or are carried out in compliance with a legal obligation. Public administrations, suppliers for the provision of the requested services, companies and collaborating entities.
Data Subjects’ Rights	They will be exercised by e-mail: dataprotection@samaipata.vc
	We inform you that you can exercise, where appropriate, the rights of access, rectification or deletion, limitation of processing, opposition, to the portability of the data or not to be subject to a decision based solely on the automated processing, as well as to withdraw the consent given.
	You can file complaints at the Spanish Data Protection Agency: www.aepd.es, Spanish Control Authority
	More information in the complete Privacy Policy of this document

1. Identification of the Controller

SAMAIPATA VENTURES, S.G.E.I.C., S.A. (hereinafter “SAMAIPATA”) is the Controller of the processing of your personal data in order to provide you the services identified in this website (the “Website”).

SAMAIPATA is a company domiciled at Calle Salustiano Olózaga 5, escalera izquierda, planta 3ª, Madrid, Spain and its Tax ID number is A87436812.

SAMAIPATA is committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights.

We inform you that SAMAIPATA has a Data Protection Officer in accordance with the GDPR, who is at your disposal for any doubts or queries you may have in relation to this matter, and whom you may contact at any time by sending an email to dataprotection@samaipata.vc.

2. What information will we collect from you?

You should be aware that there are different ways to collect personal data:

a) The data you provide directly to us.

We collect information about you when you contact us though the channels provided for this purpose, such as the register or contact form, or when you give us your CV to work with us as an employee or consultant.

In our forms, all the fields marked with an asterisk (*) will be mandatory, the omission of any of them could lead to the impossibility of us being able to provide the services requested. You must provide truthful information, and it is forbidden to impersonate anyone or to use an alias or anonymous name.

You may not, when providing any information that may be requested from you, choose expressions that are offensive, coinciding with brands, tradenames, names or pseudonyms of public figures or celebrities for whose use you are not authorized.

It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect, you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.

In order to ensure that the information provided is always up to date and free of errors, you must notify SAMAIPATA as soon as possible of any changes to your personal data by sending an e-mail to dataprotection@samaipata.vc

Likewise, by clicking on the “I accept” (or equivalent) button incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.

b) Data obtained indirectly.

When you browse, different cookies and other tracking devices may be installed on your device, as explained in our Cookies Policy.

3. What is the source of your data?

We consider that all the data processed by SAMAIPATA has been provided to us freely.

In the event that the personal data provided is from a third person, you guarantee that you have informed them of this Privacy Policy and have obtained their authorisation to provide the data to SAMAIPATA for the purposes indicated above. You also guarantee that the information provided is accurate and up to date, and you are responsible for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.

4. How will we use your personal information and what services will we provide you?

SAMAIPATA acts as the controller of the personal data for the following purposes:

Based on the management of the contractual or precontractual relationship:

a) To manage the provision of the services that we offer on our website and to attend to any type of incident or request derived from the same, as well as to facilitate the exercise of your rights.
b) To evaluate the CVs received and manage the selection processes in which SAMAIPATA processes personal data as a controller.

Based on the management of the contractual or precontractual relationship:

a) Allow data subjects to exercise their rights.
b) Comply with the regulations applicable to SAMAIPATA.

Based on the existence of a legitimate interest of SAMAIPATA:

a) To keep you informed about the services of SAMAIPATA, as well as to send you news, events and other activities that we carry out in SAMAIPATA, by conventional and/or electronic means (e-mails, SMS, …), related to the products or services that we carry out and that may be of your interest.
b) To carry out periodic reviews of our services and carry out satisfaction surveys in order to evaluate and improve the quality of the service we provide.
c) Carry out internal reviews and, if necessary, contact the client in the event that a possible fraud or identity theft is detected or there are well-founded suspicions.

However, if you do not wish your data to be processed for these purposes, you may object at any time by contacting us at dataprotection@samaipata.vc as indicated in the Exercising your rights section of this Privacy Policy.

On the basis of the explicit, free and unequivocal consent that you give us at the time of collecting your data:

a) Carry out segmentation and profiling tasks according to your interests and through the analysis of the use of the offered services, such as browsing history through the website, in order to adapt the services to each client, offering personalized services and information.
b) If applicable, to keep you informed about products and services of third parties, always sent through SAMAIPATA, and provided that you have given us your explicit consent to do so, by conventional and/or electronic means (emails, SMS).

However, if you do not wish your data to be processed for any of these purposes, you may object at any time by contacting us at dataprotection@samaipata.vc, as indicated in the Exercising your rights section of this Privacy Policy.

5. Data transfers and international transfers.

All transfers of personal data that we carry out are necessary for the fulfilment of the above-mentioned purposes, or are made in order to fulfil a legal obligation:

a) To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us.
b) Companies providing IT services, tools or IT infrastructure on which the services provided by SAMAIPATA are based, such as hosting providers, CRMs, emailing service companies, etc.
c) Companies providing audit services in compliance with the legal obligations applicable to us.

In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards.

Furthermore, SAMAIPATA guarantees that the necessary safeguards are in place to ensure that the data can be transferred securely, either because the provider offers adequate guarantees, through the signing of Standard Contractual Clauses of the European Commission, or any of the exceptions contained in the regulations.

6. Exercising your rights.

We inform you that you will be able to exercise the following rights:

1. Rights of access to your personal data to know which ones are being processed and the processing operations carried out with them.
2. Right to rectify any inaccurate personal data.
3. Right to delete your personal data, where possible.
4. Right to request limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may retain the data for exercise or defence of claims.
5. Right to object to automated decision making, including profiling.
6. Right to object to the processing of your personal data when the legal basis that enables us to process them is the legitimate interest.
7. The right to the portability of your data, when the legal basis that enables us to process them is the existence of a contractual relationship or your consent.
8. Right to revoke the consent granted to SAMAIPATA.

You can exercise your rights at any time and for free in the following ways:

1. By sending an e-mail to dataprotection@samaipata.vc email address indicating the right you wish to exercise and your identification data.
2. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you can unsubscribe from all previously accepted commercial communications.

We also inform you that you have the right to file a complaint at the Spanish Data Protection Agency, Spanish Data Protection Authority, if you believe that we have breached the applicable data protection legislation regarding the processing of your personal data.

In addition, we inform you that you can sign up for the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Association for the Digital economy (ADIGITAL), where you can register in order to show your opposition to your data being used for the purpose of sending you commercial communications.

7. Retention periods and Cookies.

We will only keep your data for as long as the commercial relationship is maintained. Any of the data you provide us through the channels will be blocked if they are no longer necessary to manage the service and will only be available if there is a legal obligation and when you exercise your rights.

Regarding the personal data obtained through the SAMAIPATA channels, SAMAIPATA uses Cookies according to the Cookies Policy that you can consult here.

8. Security and confidentiality.

We are dedicated to the security of your information. In order to prevent unauthorized access or unauthorized disclosure of personal data, we have undertaken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.

9. Minors

Minors under 14 years of age may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the Website by the minors in their care, including the filling of forms with the personal data of such minors and the marking, where appropriate, of the boxes accompanying them. In this regard, and to the extent that SAMAIPATA is not able to control whether or not users are minors, it shall be the parents and guardians who shall enable the necessary mechanisms to prevent minors from accessing the Website and/or providing personal data without their supervision, and SAMAIPATA shall not accept any liability in this regard.

This Privacy Policy has been published in September 2023.