This privacy policy (the “Privacy Policy“) provides information on the processing of personal data of users through the website [valuingdia.com ] (the “Website“) by the data controller.
1. Data controller
The data controller of the processing of users’ personal data is:
- Western Gate Private Investments Limited
- Company number: 09365819.
- Address: 1 Bartholomew Lane, London, England, EC2N 2AX.
- Contact: .
2. Purposes and legal bases for the processing of Personal data on the website
The personal data of users collected by the controller on the Website will be processed for the following purposes and on the following legal bases.
| Purpose | Categories of personal data | Legal basis | Retention period for personal data |
| 1. Manage, maintain and control the relationship with you (for instance, to inform you of the possibility to jointly exercise your shareholder’s rights). | Identification data (name and surname) and contact details (e-mail address, phone number), number of shares. | User consent (art. 6.1.a) GDPR).
|
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for a period of 2 years, or until the user requests their erasure. |
| 2. To collect statistics on the use and operation of the Website in order to improve the quality, operation and navigation, including the use of cookies. | Identification data (name and surname), contact data (e-mail address, phone number) and data collected through the use of cookies.
For more information on the use of cookies, please visit the Cookie Policy [https://valuingdia.com/cookie-policy/]. |
User consent (art. 6.1.a) GDPR).
Legitimate interest of the controller in analysing the functioning of the Website (art. 6.1.f) GDPR). |
Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for a period of 2 years, or until the user requests their erasure. |
| 3. To anonymously share your comments and views to other minority shareholders | Identification data (name and surname), contact data (e-mail address), personal opinions and thoughts. | User consent (Article 6.1.a) GDPR). | Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for a period of 5 years, or until the user requests their erasure. |
| 4. IT security of the Website. | Identification data (name and surname), IP address. | Legitimate interest of the Website Operator in ensuring the security of the Website (art. 6.1.f) GDPR). | Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for a period of 5 years, or until the user requests their erasure. |
3. Withdrawal of Consent
You have the right to withdraw your consent at any time by sending an email to westerngate@apcoworldwide.com. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent shall not affect the use of the Website.
4. International transfers of data
Users’ personal data may be shared with Capital Market Communications Limited (Camarco) in the UK, a country that, albeit outside the European Economic Area, has been delcared by the European Commission to afford a level of personal data protection equivalent to that within the EU pursuant to Commission Implementing Decision (EU) 1772/2021 of 28 June 2021.
5. Retention of personal data
Personal data will be kept for the periods set out in the chart in section “PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA ON THE WEBSITE” and, thereafter, for the period of time necessary to meet any kind of legal or contractual liability (e.g. until the statute of limitations for any liability that may arise from data protection regulations).
6. Data protection rights
Users may exercise any of the rights recognised by data protection regulations, which consist of:
- right to access and obtain a copy of their personal data,
- right to rectify any inaccurate data,
- the right to have their personal data erased where permitted by law,
- right to object to the processing of their personal data,
- the right to restrict the processing of their personal data,
- the right to receive certain personal data in a structured, commonly used and machine-readable format (i.e. portability), and
- right to withdraw consent previously given.
In order to exercise these rights, users of the Website may send a written request by e-mail to the address westerngate@apcoworldwide.com, indicating which right they wish to exercise.
Users also have the right to lodge a complaint with the competent supervisory authority, in Spain, the Spanish Data Protection Authority (www.aepd.es) to request the exercise of their rights or any other matter related to the protection of their personal data.
7. Acceptance and changes to this Privacy Policy
It is necessary that the user has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy.
The Website Operator reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or change of criteria of the Spanish Data Protection Authority. Changes or updates to this Privacy Policy will be explicitly notified to the user.
This Privacy Policy was updated on 8 September 2024.
