Privacy Policy

Who we are

Our website address is: https://succulentcapital.com/

Protection of personal data

SucculentCapital.com complies with Spanish legislation on the protection of personal data, and ensures full compliance with the obligations set forth in Law 15/1999 of December 13 on the Protection of Personal Data (LOPD), Royal Decree 1720/2007 of December 21, approving the Regulation of development of the LOPD and other regulations in force at all times, and ensures the correct use and processing of the user's personal data. It has also been updated to the new General Data Protection Regulation (RGPD EU 2016/679) that came into force on May 24, 2016, applicable mandatory from May 25, 2018, taking all necessary measures to do so. From now on in this document we will name the General Data Protection Regulation as GDPR.

In our privacy policy you will understand how we use any personal data or information you provide to us and what are the measures we have taken to protect them. That is why we are 100% committed to guaranteeing the protection of your privacy. If you fill out any of our forms to interact with our website, and thereby provide us with personal information, you can rest assured that we will only use it for the relevant purposes, which are set out in this privacy statement.

The amount and type of information we collect depends on the nature of your interaction with us, but none of the information we collect is considered sensitive, as you will see below. For example, we ask visitors who wish to leave a comment to provide a username and email address. Visitors can always refuse to provide personally identifiable information, but they may not be able to leave a comment or request a purchase invoice, for example. This entire introduction is explained in detail and clearly in the following paragraphs.

What obligations we have for storing your data

We comply with the principles required of us by the RGPD:

1. Legitimacy, loyalty and transparency in all our actions. We will never give, sell or do business with your personal information.
2. Personal data is only used for the specific, legitimate and explicit purpose for which it was collected, as stated on this page.
3. The personal data collected is adequate, relevant and limited to what is necessary.
4. The personal data we hold is accurate and up to date at all times.
5. We keep personal data only for the time necessary for the purpose for which it was collected, as explained on this page.
6. The personal data are processed guaranteeing its security, for this we have this service signed and subcontracted with the external company WEBEMPRESA EUROPA, S.L., specialized in this purpose, which acts as a delegate of the treatment of the database. To see the details of this company just follow the link. This is a leading Spanish company in the hosting service, whose servers are secure against brute force attacks, have protected all accounts against malware and offers our website with the security protocol of Hyper Text Transfer Protocol (HTTPS). Therefore, we have no qualms about showing our contract with this company to anyone who asks us, if they provide us with proof that their data is not secure with us. This company is the only recipient of the personal data we collect together with our financial advisor/manager in the case of any invoicing. If you need the data of the latter, you only have to ask us for it by sending us an email to contacto@succulentcapital.com.
7. The data controller of the data we keep is the owner indicated at the bottom of this page, who will respond and demonstrate when required by the competent authority, the measures taken and being carried out for compliance with the GDPR.
8. In the event of a breach of data security, we will, without undue delay and within 72 hours, notify the relevant supervisory authorities and prepare a full report, complying with all the conditions required of us under the GDPR.
9. We are obliged to transfer personal data in exceptional cases as a requirement by law, and we will do so. Also, and only if you give us permission to do so, we can transfer your personal data to third parties, but in this case not being a legal requirement, we will always ask for your consent.

Proactivity responsibility

This principle requires us to analyze what data we process, for what purpose we process it and what kind of processing operations we carry out. All of this is fully set out in this document.

Therefore, we are clear that the measures we have implemented are those provided by the GDPR for this case and we are confident that they are adequate to comply with it. Moreover, at any time, we can demonstrate this to any data subject upon request and to the supervisory authorities.

What personal data do we collect and why do we collect it?

First of all, we would like to point out that the data we hold are not considered, according to the RGPD (in its article 9) or the LOPD, as special category or sensitive data, since in none of our forms we ask for any data related to your health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, sex life, sexual orientation, genetic data, biometric data or data relating to the commission of criminal or administrative offenses. Furthermore, in our privacy policy we explicitly warn you not to include any of this information when filling in any of our forms.

Whenever we need any of your data we will ask for your express consent, by checking a box indicated for this purpose, to allow us to store them. In our WEB we do not need to obtain your data from any source other than you directly, since we do not ask for personal data from anyone except you as the interested party. The sources from which we obtain the personal data that we keep in our database are:

1. Comments

When you as a visitor leave comments on the site, we collect the data displayed in the comment form, as well as the visitor's IP address and browser user agent string to assist in spam detection. This data collected is for the sole purpose of identifying the user for security, both yours and ours. They will not be put to any other use than that indicated and will be retained by us until you withdraw the consent you have given us by entering them. These data are stored in the Hosting contracted with WEBEMPRESA EUROPA, S.L.

An anonymous string created from your email address (also called a hash) can be provided to the Gravatar service to see if you are using it. The privacy policy of the Gravatar service is available here: https://automattic.com/privacy/. After approval of your comment, your profile image is visible to the public in the context of your comment.

2. Media

If you upload images to the web you should avoid uploading images with location data (GPS EXIF) included. Website visitors can download and extract any location data from the images on the website. But in our WEB, as a general rule, no images are uploaded because we will not ask you for them.

3. Cookies

If you leave a comment on our site you can choose to save your name, email address and website in cookies. This is for your convenience, so you don't have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is deleted when you close your browser.

When you log in, we will also set several cookies to store your login information and screen display options. The login cookies last for two days, and the display options cookies last for one year. If you select "Remember me", your login will last for two weeks. If you log out of your account, your login cookies will be deleted.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not include personal data and simply indicates the ID of the article you have just edited. It expires after 1 day.

You can refuse to accept cookies by activating the setting on your browser that allows you to refuse cookies. However, if you select this setting, you may not be able to access certain parts of the Website or take advantage of some of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will produce cookies when you log on to our site.

If you read our Cookie Policy you will understand in detail how and where cookies are stored and for how long.

4. Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in exactly the same way as if the visitor had visited the other website.

These websites may collect data about you, use cookies, place additional third party tracking on you and monitor your interaction and tracking when you click on that embedded content, if you have an account and are logged into that website as well.

5. Invoices

If the case arises and you need us to make you an invoice, we will ask you to send us only the necessary data to do it, your consent to store them of course and we will keep them for the legal period required for these cases of 6 years.

By sending your email data are stored both in our hosting WEBEMPRESA EUROPA, S.L. as a copy in our email account GMAIL, which as you know is owned by GOOGLE.

For the first case, WEBEMPRESA complies with all the requirements of the RGPD and is documented.

For the case of GOOGLE, they have their own Privacy Policy that you can fully consult the link and ask us about all the information you need. It goes without saying that GOOGLE is the first to comply with all the regulations and obligations required by the RGPD.

Third party links

On our website there may be links to other websites managed by third parties, which are obviously not under our control. If you follow a link and / or provide your personal data or any information to the website of a third party, please note that in our website we are not responsible for the data you have given to that third party. Our privacy policy only applies to SucculentCapital.com, so if you visit a website by clicking on a link that we have published, you must read and understand their own Privacy Policy.

What rights do you have over your data

All registered users, who have made comments or simply browsed this website, have the following rights over their data (which can be exercised at any time), which are explained below each of them, to be understood, in a simple and transparent way:

• Right to be informed.- As a user you have the right to be informed in a concise, transparent and timely manner, as I am doing now. Any request for information on your part will be dealt with diligently and transparently without any opposition. You can contact us through our email contacto@succulentcapital.com.
• Right of Access.- As a user you must know and obtain when required and free of charge, all the information about your personal data to be processed by our website. To do this you just have to ask us to our email contacto@succulentcapital.com.
• Right of Opposition.- As a user you have the right to oppose that our WEB makes a treatment of your data for a different service to which we ask your consent or that we have contracted. For example, we will not use the invoice data to send you advertising. If this were the case, you would first be informed and it would only be done if you give your written consent.
• Right of Rectification.- This is the right you have as a user to correct or modify your personal information that is erroneous, inaccurate or incomplete. You only have to make the request to our email contacto@succulentcapital.com and we will put everything in order.
• Right to Deletion ("Right to be Forgotten").- This is the right you have as a user to remove from our database, all the information you have provided us or those data that you understand that are inadequate or excessive (this does not include any data that we are obliged to keep for administrative, legal or security purposes, or what is the same as our duty to block under the Data Protection Act and the GDPR). As before you simply send us an email to contacto@succulentcapital.com, with your request for deletion of all or part of the data.
• Right of Portability.- As a user you have the right to ask us, free of charge, for all your data that is in our possession, which we will deliver to you in a standard and easily readable format, if you ask us to export or send this file to another company. You only have to ask us in our email contacto@succulentcapital.com to send you this file and we will do it without any impediment.
• Right to limit the processing of your data.- As a user you have the right to limit the processing of your data by our WEB, as a precautionary measure, for example if you are not sure of the data you gave us and you want to check them. So, in the period of time that you require, we will keep all your information in our database but we will not make any use of it. Once you have made the relevant checks you can either keep your data in our database, modifying them if you ask us to do so, or request their total deletion, if that is what you prefer. To limit the use of your data you only have to ask us to our email contacto@succulentcapital.com
• Right not to be subject to individualized or automated decisions.- As a user you have the right not to have the information we hold about you used to make a decision that may affect you directly, based solely on that information, not even for profiling purposes.

You may exercise your rights at any time by simply sending us an email to contacto@rsucculentcapital.com with what you want us to do; we will reply to your initial registration email so that you can identify yourself correctly with your national identity card or passport. Once this step is done we will do what you tell us about your personal data immediately.

If you are not clear about all your rights or you simply want more information, you only have to consult the legal document Guía para el ciudadano of the Agencia Española de Protección de Datos.

If you have exercised any of these rights and we have not answered you within the maximum legal period allowed by the RGPD, which is 1 month, or the answer you receive has been unsatisfactory, you can file a complaint with the Agencia Española de Protección de Datos, following the link. In addition, in the hypothetical case of receiving a request for complex rights or when we have at the same time many requests, we are entitled to an extension of 3 months to answer you, but in less than 1 less we will inform you that we need more time to answer you, that's for sure.

Where we send your data

Your comments as a visitor may be reviewed by an automatic spam detection service.

In compliance with the provisions of Law 15/1999, of December 13, Protection of Personal Data ('LOPD'), and the new General Data Protection Regulation (RGPD EU 2016/679) of May 24, 2016, we inform you that your personal data and information you provide by completing this electronic form, will be incorporated into a personal data file owned by the owner below.

In this sense, we inform you that the collection and processing of your data are intended to resolve the queries raised about the content of this website. The fields marked with an asterisk are mandatory, being impossible to perform the expressed purpose if you do not provide these data.

In order to use the consultation form, it is a prerequisite to check the box of acceptance of the use of your data, this implies that you express your consent for the data provided to be incorporated into an automated file owned by the owner below.

Also, please do not include in this consultation form, as they are not necessary in any case, data concerning your health, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, sex life, sexual orientation, genetic data, biometric data or data relating to the commission of criminal or administrative offenses. If you do so by mistake, please contact us immediately to remove them from our database.

In any case, you can exercise your rights of access, opposition, rectification, deletion, portability, limitation and not to be subject to individualized decisions, provided by law, by sending an email to the data controller at the address contacto@succulentcapital.com, indicating your name and surname, and including as subject of the email "RGPD Rights".

How long we keep your data

If you leave a comment, the comment and its metadata are kept indefinitely. This is so that we can recognize and approve successive comments automatically instead of keeping them in a moderation queue.

If you as a user register on our site (if applicable), we also store the personal information you provide in your user profile. As a user you can view, edit or delete your personal information at any time (except that you cannot change your user name). Site administrators can also view and edit that information.

Data collected to complete an invoice will be retained for 6 years after the close of the annual audit, per legal instructions from our financial advisors. If deletion is requested, we will anonymize your data and/or remove your information from publicly accessible sites.

Contact Information

If you have any questions regarding this privacy policy, you can contact us using the contact information below.

Owner: Luis Camacho
E-mail: contacto@succulentcapital.com

From our WEB we strongly ask you to read all our legal information pages, for your peace of mind and ours: Legal Notice and Cookie Policy.