This Privacy Policy regulates the collection and processing of the personal data provided by users accessing, browsing or using the website of Cobas Asset Management, SGIIC, S.A. (hereinafter, Cobas Asset Management or the Holder) available via its domain: https://www.cobasam.com/es/, in accordance with current regulations governing data protection, you are hereby informed that: the simple fact of visiting the website does not automatically involve recording the user’s data, but some of the information will be recorded (for example, the user’s internet browser, operating system and the IP address from which the website is accessed).

If personal data need to be provided to use or request a service, the user will be required to guarantee that these data are true, exact, correct and currently valid. With regard to this, users will be obliged to keep the data updated so that they are correct at all times.

Cobas Asset Management, SGIIC, S.A. with tax ID A-87722377 and registered offices at Paseo de la Castellana, 53, 2ª planta. 28046 Madrid (Spain), is responsible for processing the data as holder of the website and will process the data for the following purposes:

1. Contact: the User may contact the Holder via the form that appears on the website for this purpose, or via the other means of contact indicated on the website (telephone, e-mail, postal address). To do this, the data requested need to be provided, together with the message, query, suggestion or comment. Cobas Asset Management will process the data provided by the User to be able to provide a service and contact him/her for this purpose. Furthermore, the data provided by the user will be stored in the Cobas Asset Management data bases corresponding to possible clients.

The legal basis for processing this data is the User’s consent.

The data will be stored for this purpose for one year, unless a different period is applicable.

1. Registration: the data provided by the User via the forms included on the website will be processed by Cobas Asset Management for the purpose of creating a personal account on the website and managing it. If the User requests to contract the services of Cobas Asset Management via the corresponding section on the website, the data provided for the purpose of this contract will be processed under the terms and conditions established in the contract.

The legal basis for processing this data is the User’s consent.

The data will be stored as long as the User remains registered and maintains an active account. When a User’s personal account is cancelled, the data will be deleted and kept blocked for 6 years. Unless a different period is applicable.

1. Contracting services: when a User uses the website to contract services provided by the Holder, the corresponding forms need to be filled in. These will involve the User providing personal data, including particularly sensitive data such as degree of disability, and other information requested without which the User’s request could not be addressed. The data will be processed by Cobas Asset Management for the purpose of managing the contract requested by the User, drawing up the contract to be signed by both parties and sending it by e-mail or by post, as well as information relating to this contract and necessary for signing it. If the contract is not eventually completed, personal data other than that for identification and contact purposes will be deleted from our systems within 1 month of the contract request being made.

The legal basis for this processing will be the correct execution of a contract, so if it is not completed the data will be deleted within 1 month.

Data must be kept for 10 years after the final operation has been completed, unless a different period is applicable.

When the services of Cobas Asset Management have been contracted, you are hereby informed that in our own legitimate interest we may send you information regarding our products and services, and conduct surveys. You may object to this processing by sending an e-mail to protecciondedatos@cobasam.com or by stating it in the contract itself. Your data will be kept for this purpose as long as you maintain a contractual relationship with Cobas Asset Management.

1. Candidates: the User may contact Cobas Asset Management via the website in order to take part in the selection processes that the company is currently undertaking or may undertake in the future. This will require the provision of identity and contact details, as well as data referring to academic qualifications. This data will be used to take the User into account for job offers that are current and/or may become available in the future.

The legal basis for processing this data is the User’s consent.

This data will be kept for one year. Unless a different period were to be applicable.

1. Advertising: Users are free to provide identity details and their e-mail address to subscribe to Cobas Asset Management’s new products, promotions and news, so as to receive personalised messages which may be of interest to them.

The legal basis for processing this data is the User’s consent which may be withdrawn at any time.

1. Segmentation: with the User’s express consent, Cobas Asset Management will analyse the operations made with regard to his/her funds and activity on the Cobas Asset Management website for the purpose of establishing his/her investor profile and offering training and information which may be of interest.

The legal basis for processing this data is the User’s consent.

The data will be stored as long as the User remains registered, that is, maintains an active account.

1. Blog: a registered User may leave comments on Cobas Asset Management’s blog. In this case the User’s data will be processed for the purpose of managing the publication of comments and opinions on the holder’s blog on the basis of processing requirements for managing this request.

The data will be stored as long as the User remains registered. Once the account has been cancelled, the comments may remain as anonymous (without identifying the former User).

1. Cookies: the website has the technology for installing cookies on your equipment that are used for access to and browsing on the website. Cookies may be blocked or disabled at any time via the browser’s set-up options. For more information, go to our Cookies policy.

The legal basis for processing this data is the User’s consent.

Transfer of data

With the User’s express consent, Cobas Asset Management may transfer identity and contact details to other companies within its group for the purpose of sending you information on their activities, products and services by e-mail or by post.

Exercising your rights

Users may withdraw their consent to processing and exercise their rights to access, rectification, deletion, portability, opposition and restriction to processing at any time by informing Cobas Asset Management via e-mail to proteccióndedatos@cobasam.com or by post to the address indicated above, confirming the subject matter as “Data Protection”. In both cases, the communication should be accompanied by an official identity document so as to avoid access to the data by third parties. Finally, a User may request modification or cancellation of the account in writing to any of the addresses provided.

Users are free to present a complaint to the control authority at any time.

Modification to the Privacy Policy

Cobas Asset Management reserves the right to modify its privacy policy at any time, always in accordance with current legislation in matters of data protection and with prior notification to all interested parties.

Language applicable to this privacy policy

The language applicable to this Privacy Policy is Spanish. Versions of this policy are provided in other languages for the User’s convenience and to make it easier to understand. However, this Privacy Policy will be governed by the Spanish version.

Additional Information on Data Protection

Who is responsible for processing your personal data?

Cobas Asset Management, SGIIC, S.A. with tax ID A-87722377 and registered offices at Paseo de la Castellana, 53, 2ª planta. 28046 Madrid (Spain), is responsible for processing your personal data.

For what purpose do we process your personal data?

We process your personal data for the purpose of managing the contractual relationship between both parties, providing the services directly or indirectly related to this and specifically to subscribe and manage participations in Cobas Asset Management funds.

We also have a legitimate interest in processing your contact details so as to send you information on our products and services similar to those contracted, as well as to make studies and conduct surveys.

Also, with your consent:

• We can send you e-mails with information on products and services provided by ourselves or third parties related to the financial sector.
• We can transfer your contact details to Value School, S.L. to provide you with information on activities, products, and services.
• We can analyse the operations made with regard to your funds and activity on the Cobas Asset Management website for the purpose of establishing your investor profile and offering training and information activities that may be of interest to you.

Were you not to authorise the processing of your personal data for the above purposes, this would not affect the maintenance and compliance of our contractual relationship.

What data do we process and from what sources are they obtained?

The data we process are provided by you or your representative as a result of your relationship with Cobas Asset Management, as well as any you may provide in the future during our contractual relationship.

If you provide data corresponding to another natural person before you include it, you should get their permission and advise them of the contents of this clause.

The data we process refer to:

• Identity and contact details.
• Personal characteristics.
• Social circumstances.
• Employment details.
• Economic and financial.
• Transactions of goods and services.
• Data relating to replies given in surveys.

To whom do we transfer your personal data?

Your personal data may be transferred to the appropriate authorities or administrations when required or for the purpose of complying with Cobas Asset Management’s legal obligations.

Also, where you have given us your consent, we will transfer your information to Value School, S.L. to provide you with information on activities, products, and services.

For how long do we keep your personal data?

The processed personal data will be kept for a maximum of ten years in compliance with the regulations governing money-laundering and financing of terrorism.

What are your rights?

Users may withdraw their consent to processing and exercise their rights to access, rectification, deletion, portability, opposition and restriction to processing at any time by informing Cobas Asset Management via e-mail to proteccióndedatos@cobasam.com or by post to the address indicated above, confirming the subject matter as “Data Protection”. In both cases, the communication should be accompanied by an official identity document to avoid access to the data by third parties. Finally, a User may request modification or cancellation of the account in writing to any of the addresses provided.

Users are free to present a complaint to the control authority at any time.

Where there is any contradiction between the version of this Privacy Policy in Spanish and in any other language, the Spanish version will prevail.