AZORA CAPITAL, S.L., makes this Privacy Policy available to the users of the website located in the URL www.azora.com (the “Website”), in order to provide information about how your personal data is processed and protect your privacy and information.

AZORA CAPITAL, S.L requests that users spend a few minutes carefully reading this Privacy Policy.

1. INTRODUCTION

AZORA CAPITAL, S.L., is an entity with registered office in calle Villanueva 2B, Escalera 1, Planta SM, 28001 Madrid, with Tax Identification Number B84777465, registered in the Madrid Company’s Registry, in Volume 23756, Page 224, Page M-415362 (hereinafter, together with its subsidiaries and managed companies, “Azora Group”).

This Privacy Policy applies to Azora Group’s Website, made available to the public in the URL www.azora.com, as well as to your interactions with Azora Group through that Website or through e-mail.

Azora Group may change whole or part of this Privacy Policy when necessary. If any changes are made, you will be notified through the Website or by other means, in order to find about the new Privacy terms and conditions. By continuing to make use of the functionalities made available by Azora Group after having been notified of these changes you will state your agreement with them, except for those cases in which your express consent is required.

2. WHO IS THE CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA

The controller for the processing of your personal data is Azora Group. To guarantee adequate management of the processing of your data, Azora Group has appointed a Data Protection Officer, whom you may address for any matter that might arise and who can be contacted at the email address rslopd@azora.com.

3. WHAT IS THE PURPOSE OF PROCESSING YOUR PERSONAL DATA

The personal data that you provide through the Website or by contacting Azora Group by other means, may be processed by Azora Group for the following purposes, depending on the interactions that you have with Azora Group.

1. Contacting, managing and processing enquiries and requests from Website users: The personal data of users who contact Azora Group through any of the contact channels made available through the Website in order to receive queries and/or requests from users will be processed to maintain contact between the parties, manage website users, provide customer or user service, and manage and process user requests or enquiries sent via the channels provided for this purpose by Azora Group.
2. Commercial, promotional or advertising communications: Users' personal data may be processed by Azora Group for the purpose of sending them personalised commercial and advertising information about activities, products, services, offers, and special promotions, as well as documentation of various kinds, by post, telephone or electronic means (e-mail, newsletter, SMS, messaging and other means of electronic communication). You may object at any time to the processing of your data for advertising or promotional purposes by Azora Group using the channels provided for this purpose by Azora Group, as detailed further on in this document.
3. Developing the selection process, which involves the analysis of your professional profile through the information contained in your CV, as well as the information provided during the development of the selection process through interviews, group dynamics and e-mails exchanged.

4. WHAT DATA ARE PROCESSED BY AZORA GROUP AND WHAT ARE THEIR SOURCES

The data that Azora Group processes as a result of the interactions that you make through the Website come from the following sources:

• Data you provide by filling in the spaces for managing communication with the users provided by Azora Group or by any other means by which you communicate with Azora Group.
• Data generated as a result of the development, processing, and maintenance of the relationship established between the user and Azora Group.

Azora Group may process personal data of the following types, depending on the relationship established with the user:

• Identification and contact data (e.g., name and surname, email, postal address, telephone, etc.).
• Academic or professional data and/or employment details (e.g., data contained in the curriculum vitae).
• Other data types. Exclusively in the event that you provide other types of data in your interactions with Azora Group, these data will be processed by Azora Group, only if their processing is required for the purpose sought. Otherwise, the data will be erased without having been previously processed or stored by Azora Group.

5. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA BY AZORA GROUP

The personal data provided by users of this Website or who contact Azora Group by other means may be processed by Azora Group for the following purposes, depending on the interactions that the user enters into with Azora Group.

1. The processing of your data for the purpose of "Contacting, managing and processing enquiries and requests from Website users" is based on the need to execute a contract between the user and Azora Group to which the interested party is a party or for the application of pre-contractual measures at the request of the latter; that is, in the management of your own request, in maintaining contact between the parties and, where appropriate, in the provision of the service that you requested.
2. Likewise, the processing of your data for the purpose of "Commercial, promotional or advertising communications” is based on Azora Group's legitimate interest in keeping you informed about the latest news of the business group. The sending of such communications will be exclusively related to Azora Group services and activities similar to those published on the Website and for which there is a prior legal relationship with the user. You may object to the processing of your data for the purpose of "Commercial, promotional or advertising communications" at any time, as well as in each of the communications for this purpose that you receive. In the event that there is no prior contractual relationship with Azora Group, you may only receive promotional information with prior express consent by ticking the box provided for this purpose.
3. Azora Group processes the personal data you provide for the purpose of “Developing the selection process” and carrying out the recruitment process on the basis of the application of pre-contractual measures or the intention to conclude a contract (art. 6.1.b of the GDPR).

Azora Group informs you that it will only process personal data for the purposes of processing based on your consent in the cases in which you have consented to each of the processing operations, through the means of obtaining consent made available by Azora Group.

6. WHO ARE THE RECIPIENTS OF YOUR DATA

Your data may be disclosed to other companies of Azora Group that perform, among other functions, management, control, human resources management, compliance monitoring or auditing. The purpose of this communication of data is to enable the management and development of the appropriate procedures established by law, given that other companies of the corporate group may be the commercial entities that have to deal with the consultation or proceed with the employment contract. The legal basis for this communication of data is the legitimate interest of Azora Group in managing the human and technical resources of the business group, and the need for it to formalise a contract.

Your data will not be disclosed to other third parties unless expressly required by law or with your consent.

7. HOW LONG YOUR DATA ARE KEPT

Azora Group will keep your personal data for as long as required for the provision of the service requested and/or to achieve the purpose of the processing sought.

Later, provided that you have not exercised your right of removal, your data will be duly kept during the applicable legal periods, taking into account the type of the data as well as the purpose of their processing.

In any case, you may request detailed information about the data retention periods applied at Azora Group by contacting the Data Protection Officer, who can be contacted at rslopd@azora.com.

8. WHAT PERSONAL DATA YOU SHOULD PROVIDE

When personal data are obtained through a form made available on the Website, you must provide at least the data specified as mandatory, in the form in question. In the event of failure to provide at least such data, considered necessary, Azora Group will not be able to manage the service, or the query formulated by you.

9. WHAT SHOULD YOU WARRANT BY PROVIDING YOUR PERSONAL DATA

You warrant that the information provided is true, accurate, complete, and up-to-date, and are responsible for any harm or loss, direct or indirect, that may be caused as a result of a breach of this obligation.

If you provide third-party data, you warrant that you have informed that third party of all the aspects of this Privacy Policy and obtained their consent to provide their data for the purpose of their processing in question. All this prior to the supply of third-party data through the Website.

You must be older than 18 to provide your personal data in any way through the Website. Users who provide data to Azora Group through this Website represent and warrant that they are older than 18 and are entirely responsible for this statement.

10. WHAT MEASURES ARE TAKEN TO PROTECT YOUR PERSONAL DATA

Given Azora Group’s interest in ensuring the security and confidentiality of your data, the security measures required for personal data protection have been taken and the technical measures at its disposal have been implemented to prevent loss, misuse, alteration, unauthorized access, and theft of the personal data provided through the Website. In any case, it should be borne in mind that online security measures are not unassailable.

11. WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA

Azora Group informs you that you have the following rights over your personal data:

• Accessing your data: You have the right to receive the confirmation of whether personal data affecting you is being processed or not and the right to access your data to find which personal data concerning you is being processed.
• Requesting the rectification or removal of your data: Under certain circumstances, you have the right to rectify those personal data that you regard as inaccurate and concern you, and are processed by Azora Group, as well as the right to request the removal of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
• Requesting the limitation of the processing of your data: Under certain circumstances, you will have the right to request the restriction of the processing of your data, in which case only the data for which you have requested the restriction of processing will be retained for the exercise or defence of claims.
• To the portability of your data: Under certain circumstances, you will have the right to receive the personal data that concern you and that you have provided to Azora Group, in a commonly used structured format that is automatically read, as well as to their transfer by Azora Group to another controller.
• Objecting to the processing of your data: Under certain circumstances and for reasons connected to your specific situation, you will have the right to object to the processing of your data, in which case, it will no longer be processed unless it is necessary to continue to do so for compelling legitimate reasons or for the exercise or defence of possible claims.

You also have the right to withdraw any consent you have given for the processing of your data, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

You may exercise your rights in the form of a written document identified with the reference "Data Protection", which must be transmitted to calle Villanueva 2B, Escalera 1, Planta SM, 28001 Madrid or rslopd@azora.com.

In the event that the request is not complied with, a complaint may be lodged with the Data Protection Delegate at the following e-mail rslopd@azora.com or lodge a complaint with the competent supervisory authority.

12. CHANGES TO THE PRIVACY POLICY

The Website Privacy Policy may be updated from time to time. You are therefore advised to review this policy each time you access the Website so that you are adequately informed about how your personal data is processed and how your privacy and information are protected.

Last updated: October 2023.