Privacybeleid

1. Identity of the data controller

Novicap Spain S.L., with registered office at Avenida de Diagonal 618, 7ºF, Barcelona (“Novicap”) is the owner and administrator of the domain name www.novicap.com (the “Web” or the “Web Site”).

Novicap has appointed a Data Protection Officer who can be contacted at the following e-mail address [email protected].

2. Accessing and browsing this website

By the mere fact of visiting and browsing this Website, no data is automatically recorded that would allow users (“Users”) to be identified by name.

However, certain information is collected and recorded in Novicap systems (e.g., type of Internet browser, operating system, IP address from which you access the pages of the Web) in order to improve user navigation and management of the Web itself. The Website may also use cookies and similar technologies whose use is subject to the consent of the Users in accordance with the Cookies Policy. For more information, please visit our cookies policy.

Novicap also processes your personal data for the following purposes:

• In the event that you act as an attorney-in-fact for a legal entity, Novicap has a legitimate interest in processing your contact details for the purpose of locating you professionally and maintaining commercial and other relationships with the legal entity in which you provide your services.
• Fulfilling legal obligations: Novicap may process your personal data in order to comply with any legal obligation incumbent upon it, specifically obligations related to financial sector regulation or money laundering regulations, among others. 

In particular, we may process your data in order to: 

• Prevention of money laundering and terrorist financing: 
• Among other processing, compliance with these legal obligations or the legitimate interest of the entity in preventing, investigating and uncovering fraud may involve the transfer of personal data to Novicap Group companies for these purposes. 
• Verify in external files, their relationship with companies and their position of control in the ownership structure of the same. 
• To carry out the identification of persons with whom a business relationship is established and all due diligence updates and continuous monitoring of the business relationship. 
• Notification to solvency and credit files and consultation of said files:
• Communication to solvency and credit files and consultation of such files:
  • In the event that you have a debt with Novicap that is certain, due and payable, but has not been paid within the period provided for this purpose, Novicap may report this non-payment to solvency and credit information files. 
  • In the event that it is necessary to assess your financial solvency, we will consult your data in the credit and financial solvency files for the sole purpose of analysing the financial viability of those files.

3. Acceptance and identification of the user

By accessing and browsing through this Website, the User acknowledges having read and accepted our Privacy Policy and expressly accepts the application of the same to the use made of the Website while browsing.

Novicap may offer, through the Website, services that may be subject to special conditions, on which users will be informed in each specific case.

The User guarantees both Novicap and third parties the quality of the information provided, ie, that the data and information provided are real, truthful, updated and also belong to the User and not to third parties. The User will be responsible for the veracity of the personal data provided and will hold Novicap harmless against third party claims or sanctions or damages that may be suffered in case of non-compliance.

In accordance with current legislation in Spain, in order to use the Website, the User must be over 18 years of age, or have the authorisation of their parents and/or legal guardians if they are over 14 and under 18. Therefore, by accepting this Privacy Policy, the User guarantees that they are over that age or that they have the aforementioned parental authorisation to register with Novicap, and takes full responsibility for this declaration.

Data protection regulations require us to keep your identification data and those that are necessary for the correct execution of the contract up to date, so that when necessary we can update your data with information from public sources (public records, land registry, etc.) and with those that you have made manifestly public (social networks).

4. Purpose of the treatments

Users’ personal data will be collected and processed for the main purpose of managing their relationship with Novicap as follows:

• (i) to resolve queries raised by the User through the Website in the “contact” section.
• (ii) to manage your candidacy in personnel selection processes.
• (iii) To comply with legal obligations (see section 2 above).
• (iv) execute the contract: your data will be processed for the purpose of managing the products and services you request or contract with Novicap.

5. Legitimation

The legitimacy for the processing of Users’ personal data shall be the fulfilment of applicable legal obligations and for the performance of a contract. Therefore, the collection of such data will be necessary to fulfil these purposes and the refusal to provide the personal data requested, or the provision of inaccurate or incomplete data, could result in the impossibility of providing the contracted services in an appropriate manner. 

Customers are responsible for the veracity of the data provided, as well as for notifying Novicap of any changes to them. The processing carried out for the purpose of sending commercial communications about products or services that may be of interest to you as they are similar to those you have contracted and that Novicap is interested in marketing will be based on the legal basis of the legitimate interest of the responsible party or a third party. For this reason, you may object to them at the time of providing the data or at any time thereafter. The processing carried out for the purpose of sending you commercial communications about other products or services that have no similarity with those you have contracted, offered by Novicap, any company of the Novicap Group or those third party entities with which the Novicap Group has signed collaboration agreements, will have as a legal basis the consent that you may have given. The transfer of your data to companies of the Novicap Group and its subsidiaries or affiliates, including the processing necessary to personalise the corresponding offers, shall be based on the consent you may have given. Processing relating to the profiling necessary to ensure that commercial communications are tailored as closely as possible to your needs, tastes and preferences, shall have as a legitimate basis those indicated in this policy. The fulfilment of obligations and the exercise of rights arising from your contractual relationship with Novicap will never be subject to you providing the requested consents. In any case, we remind you that if you have given your consent, you have the right to withdraw it at any time without this having any consequence on the services or products you have contracted or of which you are a beneficiary. Finally, we would like to inform you that the processing carried out will be carried out on the basis of the legitimate interest of the data controller. If you have any doubts regarding the purposes of the processing of your personal data or its legitimacy, you can contact the Data Protection Officer. You will find his contact details in section 1.

6. Duration

Novicap will collect and process user data according to the purpose for which they have been collected:

• For the management of our selection processes, we will process the data you provide for the duration of the selection process and, in the event that you expressly authorise us to include your data in our employment exchange, we will keep them for 2 years from the time you sent us your application.
• When we process your data for the performance of a contract or service, we will retain your data for up to ten years from the end of the contractual relationship with the User.
• When you make an enquiry via our website, we will process your data for as long as necessary to process and resolve the enquiry.

Once these periods of time have expired, we will keep your data duly blocked for the period of limitation of any liability that may arise as a result of the processing, making them available only to the competent public administrations, judges and courts.

7. Data communication

Novicap will not communicate the data collected to third parties, except when strictly necessary to manage and maintain the relationship with Novicap or with the prior authorisation of the User.

8. Security

In relation to the personal data collected, Novicap has adopted and will adopt the necessary technical and organisational measures to guarantee their protection and prevent their alteration, loss, unauthorised processing and/or access, taking into account the state of the art, the nature of the data stored and the risks to which they are exposed, complying at all times with the applicable regulations.

9. User rights

Users have the right to exercise at any time, under the terms provided by the regulations in force at any time, the rights of access, rectification or deletion of data, as well as to request the limitation or opposition of the processing or to request the portability of their data.

Likewise, Users may revoke the consent given at any time.

The aforementioned rights may be exercised by sending an e-mail to the address in section 1, providing a copy of your ID card or equivalent document.

Furthermore, we inform you that you can always turn to the Spanish Data Protection Agency (www.aepd.es) to request protection or lodge a complaint in relation to the processing of your personal data.

10. Applicable law and jurisdiction

The relationship between Novicap and the User shall be governed by Spanish law.

Any dispute shall be submitted to the Courts and Tribunals of Barcelona.