1 Scope and Introduction
At Academy for Investors, part of Hugo Broker AV S.L., we are committed to protecting your privacy and we take our responsibility for the security of your personal information very seriously. We thrive to be clear and transparent about what information we are collecting and what we do with that information.
At Academy for Investors, part of Hugo Broker AV SL, we ensure that the data you provide to us is treated in accordance with the provisions of the Organic Law 3/2018 3/2018 of 5th December on the Protection of Personal Data and Guarantee of Digital Rights and Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
Academy for Investors takes responsibility for the processing of the personal data you provide to us and inform you that this data will be processed in accordance with the provisions of the Organic Law 3/2018 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights and Regulation (EU) 2016/679 of 27 April 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and you are therefore provided with the following processing information.
This policy contains the following:
– What personal data do we collect and process in relation to you and your use of our website, our mobile applications and our online services;
– Where we obtain that data from;
– What do we do with that data;
– How we store it;
– To whom we transfer/disclose that data;
– How we manage your data protection rights;
– How we comply with data protection regulations.
All personal data is collected and processed in accordance with Spanish and EU data protection laws.
2 Information about Academy for Investors
Academy for Investors is not regulated by the Comisión Nacional del Mercado de Valores (www.cnmv.es)
For any matter relating to personal data, we are responsible to the Spanish Data Protection Agency (Agencia Española de Protección de Datos).
3 Persons from whom we collect personal data
The individuals from whom we collect personal data include customers, employees, contractors, directors, shareholders, both current and prospective, as well as other parties with whom we do business (also referred to in this Policy as “you” or “your”). We are committed to protecting all personal information that we collect and process in accordance with local law, currently the Organic Law 15/1999 of 13 December 1999 on the protection of personal information.
Personal Data Protection Act, (the “GDPR”), and any subsequent legislation, including the General Data Protection Regulation (the “Legislation”).
By “personal data” we mean any information relating to you that allows us to identify you, such as your name, or your email address. We do not ask for more personal data than is actually necessary for such provision.
The personal data we collect includes:
– First name
– Last name
– E-mail address
In two of the courses at Academy for Investors there are some specific questions related to personal investment goals, for these specific pages, Academy for Investors refers to the disclaimer below the specific page which requires an opt-in on behalf of the user.
4 Why do we collect personal data?
We only collect data in order to carry out the following purposes:
We collect, process and manage your personal data to provide our services, contractual rights and obligations, fulfil our legal obligations, exercise our legitimate interests. Please see below the purposes for which we may process your personal data:
Providing you with information relating to the products and services we offer.
– To help you develop and understand the products and services you may be interested in obtaining from Academy for Investors, Hugo Broker S.L.
– Improve our services and the customer experience;
– To provide you with information or opportunities that we consider relevant to you;
– Create anonymized statistical data;
– Generate profiles in relation to your characteristics, preferences and interactions so that we can make automated decisions in relation to our services, marketing and advertising;
Where we need your consent to process your personal data, we will always ask for your consent before obtaining and processing your personal data and inform you of the purpose of the processing. You may withdraw your consent at any time. Where we may have If we share your data with third parties, we will also notify those parties if you choose to withdraw your consent.
6 How do we collect personal data?
Academy for Investors collects and processes personal data from our own website and the applications that we own, or that we run and manage directly, such as the registration form on our website, the purchase of one of the courses, or through one of the marketing actions to which you may subscribe. Academy for Investors may also collect personal data through third parties with whom we do business, such as third-party websites through which individuals contract or request information about Academy for Investors. When we collect personal data through third party websites, we ensure that such third parties seek your consent before sharing your data with us. Subsequently, we will always identify ourselves in our first communication with you and indicate the purpose for which we require such data. In addition, for regulatory purposes, we reserve the right to obtain information about you from other sources, such as credit rating agencies or
7 How long do we keep personal data?
We will only retain your personal data for as long as necessary to carry out the purpose for which it was collected, including the need to comply with legal, accounting or reporting requirements. In determining the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the harm that would be caused by unauthorised use or disclosure of your personal data, the purpose of the processing and whether we can achieve the same result by other means, as well as relevant legal requirements.
– Customers – current regulation requires us to keep records of our customers for a period of 5 years after termination/closure of their account unless we are required to keep them for a longer period (legitimate interest, legal obligation);
– Prospective clients – currently the company retains data for a maximum period of 5 years after application, provided that the prospective client has been inactive unless they have expressly requested that their data be removed from our database;
– Potential employees – currently Hugo Broker S.L. retains data for 2 years after rejecting an application for a position unless the potential employee has expressly requested that their data be removed from our database.
For tax reasons, we are required by law to retain basic customer information (identification, financial, contact, and transaction data) for six years after they cease to be customers.
At other times, we will anonymize your personal information (so that it cannot be associated with you) for analytical or statistical purposes. In this case, we may use the resulting information indefinitely and without notice.
If you have opted out of receiving marketing communications, we will keep your details on our suppression list so that we know that you do not wish to receive communications relating to our marketing activities.
8 Your rights
Academy for Investors is obliged by law to reply to any inquiry regarding personal data within 30 days unless the type of inquiry requires more time for study and evaluation. These are the privacy rights applicable in our sector:
– Right of access: this means that you can request a copy of your personal data held by the Academy for Investors. The initial request is free of charge; however, depending on the volume and complexity of the matter, we may charge a reasonable administration fee for subsequent requests;
– You have the right to update your profile so that the personal data we hold is accurate and up to date. We will subsequently notify any third parties with whom we may have shared it, including processors, and ask them to update their records as well;
– You may request that your personal data be removed from our records. In order for us to comply with the requirements of our regulatory authorities, this may not be done immediately (see section “Data retention”). If it can be deleted, we will also inform any third parties with whom we may have shared your personal data and ask them to remove it from their records;
– You may request that we do not contact you for any marketing purposes. This can be done via our e-mail address firstname.lastname@example.org.
– You may object at any time to any decision we may take that is based purely on automated processing (including profiling). Profiling involves the use of technology that helps us to make decisions automatically based on the personal data we collect from you or from third parties;
– You have the right to file a complaint. If you are not satisfied with the way in which Academy for Investors has handled your complaint, you may address it to the Spanish Data Protection Agency, C/ Jorge Juan, 6, 28001-Madrid, or via the website www.agpd.es.
9 Disclosure of personal data
Academy for Investors and Hugo Broker S.L. do not sell personal data to third parties.
We may share your personal data with third parties for specific purposes related to the provision of our services, our legal obligations, or for a public interest purpose. The third parties with whom we may share your personal data are:
– Product and service providers with whom we have contracted for administrative, technology, payment processing, and fraud prevention services, postal and courier or other services;
– Companies within the Hugo Broker S.L. Group
– Any third party with whom you may authorize us to share your personal data.
We also share data with other companies involved in advertising, retargeting, and data analysis. If you would like to find out more about the companies we work with, please see the Cookies section.
We require all third parties with whom we do business to respect the security of your personal information and to handle it in accordance with applicable law. We also do not allow third-party service providers to use your personal data for their own benefit, and we ensure that they only process it for the specified purposes and in accordance with our instructions.
We have appropriate security measures in place to prevent your personal data from accidental loss, disclosure or unauthorized modification, use, or access. Furthermore, access to your personal data is limited to those employees, contractors and third parties who need to know your personal data in order to fulfil their contractual obligation. These persons/entities, who are bound by confidentiality, will only process your personal data in accordance with our instructions.
We have put in place procedures to manage potential leaks of personal data and are committed to notifying you and the relevant regulator of any leaks that the applicable law deems appropriate to notify.
11 Advertising, marketing and your communication preferences
We reserve the right to use your identifying, technical and contact, tracking, usage and profile data to create a picture of what we think you may want or need, or what may be of interest to you. This use allows us to decide what products, services and offers may be relevant to you in order to tell you about them. This process is called “direct marketing”.
We carry out our direct marketing actions by email, post, telephone calls and SMS.
We always try to make it very clear on our website what we do and what communications we will send you, both when you decide to try a demo account or sign up for a webinar, and when the mailing is part of the process of setting up an account or purchasing a product/service. Of course, you have the right to change your mind at any time and unsubscribe from these services. The easiest way to unsubscribe is to send an email to email@example.com
We also work with our partners to optimize the reach of our ads, which leads us to use data analytics and retargeting technologies. We use tracking data to deliver relevant online advertising, both on websites and on social media.
Tracking data, and in particular, cookies, help us to deliver advertising on websites and social media that we believe may be of interest to you and potential Academy for Investors customers.
The cookies used for this purpose are often set on our website by specialist organizations. The use of these cookies includes retargeting.
Cookies can also tell us whether you have seen a certain advertisement or how long it has been since you saw it. This is quite useful because it allows us to evaluate the effectiveness of our ads and to control the number of times an individual will be shown our ads. Cookies help us to know whether you open the marketing emails we send.
Almost all advertising-related cookies are part of third-party online advertising networks. If you would like to learn more about how to control the ads you see online, please see the opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies set by advertising networks.
Cookies are data that a website transmits to your browser to store and sometimes track your information.
You have the option to disable this feature through your browser settings. However, this may affect your ability to view parts of our website or access certain applications.
13 Staff training and awareness
All Academy for Investors staff receive ongoing training regarding the management of personal data and confidential information.
14 Entry into force
This policy comes into force on 03/05/2021 and may be amended from time to time. Modifications will be notified by e-mail or via the website.
15 Contact Information
Academy for Investors
Urb. La Carolina Local-N
29602 Marbella – Spain
www.academy-for-investors.com / +34 952 924 011 / firstname.lastname@example.org