Introduction

Bewater Asset Management S.G.E.I.C closed-end funds S.A. (hereinafter Bewater Funds) is responsible for the website bewaterfunds.com, hereinafter the “website”.

The user must be aware that the information he offers about himself on the web will be identified by Bewater Asset Management.

We are most interested in protecting the personal data of our users and would like to inform them, through our privacy policy, of how we insure their protection.

Applicable Legislation

Bewater Asset Management is in compliance with current legislation in Spain and the European Union on the treatment of personal data of its users. Particularly, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR). To this end, Bewater Funds adopts the necessary technical and organizational measures to guarantee the security of personal data and to prevent the loss, misuse, alteration, unauthorized access and theft of personal data provided, taking into account the state of technology, the nature of the data and the risks to which they are exposed, all in accordance with current regulations.

Who is responsible for the processing of your data?

Bewater Asset Management S.G.E.I.C de tipo cerrado S.A. -Fiscal ID:A-88020649

Postal Address: c/ Serrano, 213, planta 1, A4, 28016 Madrid (España).
Email: info@bewaterfunds.com
Phone: (+34) 91 220 72 53

Data Protection Officer:
Alejandro D. Caneda
Email: dpo@bewaterfunds.com
Phone: (+34) 91 220 72 53

What security measures does Bewater Asset Managemetn implement for the protection of personal data?

Bewater Asset Management has adopted the necessary technical and organizational measures to ensure that the GDPR is applied to the different processes carried out within the company in order to protect the rights of the user.

However, any transfer of data over the Internet has the risk of being intercepted. Bewater Asset Management has implemented the necessary measures to minimize the risk of this happening. The user must be aware that it is a risk over which Bewater Asset Management has no control, and therefore, will not be responsible.

For web services requiring registration as a user, a password must be chosen. The user is responsible for maintaining the confidentiality of this password, as well as all activities during the session initiated with the username and password. The user commits to notifying Bewater Asset Management, without delay, of the unauthorized use of their username and password or any other security breach. Bewater Asset Management will not be responsible for any damages or losses that may arise due to the breach of this obligation by the user.

How do we collect your data?

To access some of the web services, you need to register, depending on the service you wish to access you will need to provide the requested personal information. The user must provide all requested information in order for Bewater Funds to adequately supply the requested services.

Bewater Asset Management will use your personal data solely to provide the services requested by you.

Bewater Asset Management will not transfer the user’s information to third parties without prior consent, informing the user of such transfers and their purpose.

In order to access our services, personal data provided by the user must, in all cases, be true and current.

The user is responsible for the accuracy of the data provided to Bewater Asset Management, expressly prohibiting the appropriation of personality or the provision of personal data of third parties without their express consent.

Reasons for processing your data

Bewater Asset Management will only process personal data of users that are eligible, pertinent, and limited to what is necessary in relation to the services for which they are being processed. In this sense, the user may provide personal data to Bewater Asset Management, through the various processes established on the website. This data will be processed for the following purposes with the expressed consent from the user in a specific unequivocal manner:

  • Attend to requests for information and communication made by the user. Bewater Asset Management will use identification and contact data for this purpose.
  • To provide services related to the management and incorporation of the different funds and its shareholders, for this purpose Bewater Asset Management will identify contact data, economic and banking data, and data related to its financial situation. We will create a user profile, based on the information provided, in order to provide our service.
  • To provide services related to the management of the user’s subscription to the Bewater Funds Blog, informing the user of updates. For this purpose, Bewater Asset Management will process identification and contact data.
  • To put the User in contact with other entities of the same group as Bewater Asset Management that could offer another investment service (for example Indexa Capital AV, SA or Bewa7er Market SL, among others). For this purpose Bewater Asset Management will process identification data, contact information and, where applicable, economic and banking data related to its financial situation.
  • To inform the user about news regarding Bewater Asset Management and its services. For this purpose, Bewater Asset Management will process identification and contact data.
  • To ask the user for their opinion of the service provided by Bewater Asset Management. For this purpose, Bewater Asset Management will process identification and contact data.

How long do we keep your data?

The personal data provided to Bewater Asset Management by the user will be kept as long as its deletion is not requested or, as the case may be, while the commercial relationship between the parties is maintained or during the legal term required by existing regulations. When the legitimacy of processing data depends on the consent of the user, we inform them of their right to remove it at any time through a procedure outline in the Privacy Policy.

What is the legal basis for processing your data?

The legal basis for the processing of personal data is the consent of the user or, in this case, the provision of the services requested.

To whom will your data be communicated?

Bewater Asset Management may surrender personal data when required by a legal obligation, to respond to claims referring to the violation of announcements or other content relating to third party rights or the protection of their interests, provided that they outweigh the rights of the user.

Besides cases previously stated Bewater Asset Management may only release personal data with the specific, informed and unambiguous consent of the user.

Third parties may process personal user data on behalf of Bewater Asset management for the provision of the services requested. These third parties will be considered responsible for the processing of the data and offer guarantees to apply appropriate technical and organizational measures for compliance to the GDPR.

What are your rights when you provide us your data?

  • Right of access: the user has the right to be informed of whether Bewater Asset Management processes personal data concerning them and, in this case, to access and obtain a copy of said data.
  • Right of rectification: the user has the right to request the correction of inaccurate personal data concerning them.
  • Right to be forgotten: the user has the right to request the deletion of their data, among other reasons, when the data is no longer correct, necessary or relevant for the purposes for which they were collected.
  • Right to object: the user has the right to oppose the processing of their personal data, for reasons relating to their particular situation. In such cases, Bewater Asset Management will cease to process said data, unless there are legitimate compelling reasons, or for the formulation, exercise or defense of claims.
  • Right to restriction of processing: the user, depending on certain conditions, may request the limitation of the processing of their data, in which case Bewater Asset Management may only process them for the exercise or defense of claims, for the protection of third party rights or for reasons of public interest.
  • Right to data portability: the user has the right to receive or, where appropriate, to have Bewater Asset Management provide data to third parties in a structured, machine-readable format, provided that such processes are based on the consent of the user and carried out automatically.

The User may exercise their rights of access, rectification, erasure, objection, restriction and portability through mail at Serrano 213, floor 1, A4, 28016 Madrid (Spain) or via email to info@bewaterfunds.com, providing a photocopy of a national ID or other identity document.

Bewater Asset Management is committed to respond to all requests within the period established by current regulations.

Likewise, the User can submit a claim to the Spanish Agency for Data Protection (AEPD), whose contact information is available through the website www.aepd.es

IP addresses and cookies

Due to the communication protocols existing on the Internet, when the user visits the website, Bewater Asset Management automatically receives the IP (Internet Protocol) address that has been assigned to their computer by their provider.The registration of this IP address serves only for internal purposes, such as website statistics. As a general rule, the IP address for the same user is different from one Internet connection to another, making it difficult to track browsing habits of a specific user.

Bewater Asset Management can use cookies when a user browses their website and web pages for statistical purposes and to optimise navigation through it. Find more information on cookies in our cookies policy.