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1. Data Controller details
    • Corporate name:BTD CAPITAL 12, S.L., hereinafter, the «provider».
    • Registered data: The provider is registered at the Commercial Registry of Madrid, on Volume 20123, Folio 141, Section 8, Hoja M-355281 1st entry.
    • Trade name:
    • Registered office:Calle Arturo Soria 99 1ª planta; 28027– Madrid
    • VAT number:B83999367.
    • Telephone:+34 914 318 244.
    • Email:

1.1 Applicable law

Our Privacy Policy has been designed in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), and with Spanish Framework Act 3/2018 of 5 December on the Protection of Personal Data and the Safeguard of Digital Rights. On providing us with your data, You declare to have read and understood this Privacy Policy and give your unequivocal and express consent to the processing of your personal data for the purposes and on the terms stated herein. The Company may amend this Privacy Policy to adapt it to new laws, case law or rules of construction of the Spanish Data Protection Agency. The terms of this privacy  policy may be supplemented by the Disclaimer, the Cookies Policy and the General and Particular Terms and Conditions which may be established for certain products or services, if such access is subject to any special personal data protection provision.

2. Purpose of Processing

Our processing of your personal data has the following purposes:

The provider, through a contact form, collects and processes the information provided by users to meet their miscellaneous requests. If the provider proposes to use your data subsequently for any other purpose, the provider shall inform you, before such subsequent processing, of such other purpose and provide you with any additional relevant information.

Your data may also have been collected and processed due to an exchange of emails. The personal information that you have provided will be managed only to communicate with you and meet your requests.

In general, personal data are obtained from the data subjects themselves; however, in certain cases we may obtain your data through a lawful transfer of data from another company. In such case, you will be informed to such effect of the origin of your personal data.

The provider has a legitimate interest in using the information collected or generated to improve the Website, its management and its security, to carry out surveys to analyse the relevance and use of the Website, including through anonymised information and, where so permitted by applicable law, to provide users with news on the provider through publications and other actions.

2.1. Data storage time

We will keep your personal data for the time necessary to meet users’ requests or applications for the purposes set out in section 2. The provider shall process the data for the time strictly necessary for the respective purpose. The data will subsequently be stored, kept and protected for the time during which liability may arise from their processing, in compliance with legislation in force from time to time. Once any potential action is time barred, your personal data will be deleted.

2.2. Data recipients

The provider may disclose users’ data only for the purposes mentioned above, to other BTD Group companies, consortiums, joint ventures, subsidiaries and associates, where this is necessary for the sought purpose.

3. Legal basis and data collected

The legal basis for the processing of your data is your express consent given through a positive and affirmative act (by completing the relevant form and marking the box accepting this policy) when you provide us with your personal data.

3.1. Consent to process your data

When completing the forms, on marking the box “I accept the Privacy Policy” and click to send the data, or when sending e-mails to the Company through the accounts enabled for the purpose, the User declares to have read and expressly accepted this privacy policy and grants his/her unequivocal and express consent to the processing of his/her personal data for the stated purposes.

3.2. Categories of data

The data that we collect through our form are identifier data, professional information and/or employment details, transactional information and connection and browsing data within the meaning of the General Data Protection Regulation.

4. Security measures

In our commitment to ensure the security and confidentiality of your personal data, we inform you that we have in place the necessary technical and organisational measures to ensure the security of your personal data and prevent any unauthorised access, processing, loss or alteration, taking into account the  state of the art, the nature of the stored data and the risks to which they are exposed, pursuant to Article 32 of GDPR EU 679/2016.

5. Data transfers

Your data may be transferred to and processed in whole or in part by the provider companies engaged by the provider for the provision of the services for the  purposes mentioned.

The provider may make international transfers of personal data to third countries or international organisations, outside the European Union. In any case, the provider warrants the confidentiality of the data and the application of the appropriate measures to ensure compliance with personal data protection laws and regulations.

6. Data subject rights

Any data subject shall have the right to obtain confirmation of whether or not we are processing personal data concerning him/her. Data subjects have the right to access their personal data, and to request the rectification of inaccurate data or, as the case may be, their deletion where, among other reasons, the data are no longer necessary for the purposes for which they were collected.

In certain events, the data subjects may request that the processing of their data be limited, in which case, we will keep them only for the filing or defence of claims. For reasons related to their particular situation, the data subjects may object to the processing of their data. The Controller shall cease to process the data unless otherwise required by imperative of the law or for the filing or defence of potential claims.

6.1. User rights

Users shall have the following rights: to access and rectify their personal data, to object to the processing of their personal data, to have their personal data deleted (“to be forgotten “), to limit the processing of their personal data, to the portability of their personal data, to not be the subject of automated individual decisions and to information.

Users may exercise their rights free of charge (other than in events of abuse or excess) by getting in touch with us by:


Postal mail: Att. BTD CAPITAL 12, S.L. Calle Arturo Soria 99 1ª planta; 28027– Madrid

Please attach a copy of a document enabling us to identify you.

If you consider that the provider has not processed your personal data in compliance with applicable legislation or that you have not obtained satisfaction in the exercise of your rights, you may file a claim before the Spanish Personal Data Agency (

7. Consent to Electronic Communications

In addition, in compliance with Spanish Act 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce, on completing the data collection form and marking the box “I accept the sending of electronic communications”, you are giving your express consent to be sent information on the provider and BTD Group companies to your e-mail address, telephone, fax or other electronic device.