In accordance with the principle of transparency established in the applicable regulations on data protection (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data; and Organic Law 3/2018 of 5 December, on the protection of personal data and guarantee of digital rights), we hereby provide you with information regarding the processing of your personal data in the “Espai Client” platform hosted on the www.espaiclient.icf.cat website (hereinafter, the "Platform").
Please note that when you purchase one of our products, the privacy policy applicable to that particular product will also apply, so you should refer to the applicable privacy policy for the product in question.
Who is the data controller for your personal data?
The data controller for your data is the INSTITUT CATALÀ DE FINANCES, with Tax ID Number (CIF) Q5855055I, domiciled at Gran Via de les Corts Catalanes, 635, 6ena planta, 08010 Barcelona and with the contact email address protecciodedades@icf.cat. You can contact our Data Protection Officer at the following email address: dpolCF@icf.cat.
What type of data can we process, for what purpose and on what legal basis?
Purpose | Type of data | Legal basis |
---|---|---|
To facilitate your registration on the Platform so you can operate as a registered user. To assess requests for new products and monitor the products or services that have been requested o pucharsed. | Identifying data and economic and financialdata. | Contractual relationship or application of pre-contractual measures requested by the User. Legitimate interest (to comply properly and effectively with solvency assessment obligations with regard to granting funding applications). |
To create risk profiles and segments in relation to the ICF Group's own products or services. | Identifying data and economic and financial data. | Legitimate interest (to better meet your expectations and improve the business relationship with the interested party) |
To comply with the applicable regulations on money laundering | Identifying data | Compliance with the legal obligations pursuant to Law 10/2010 on the prevention of money laundering |
To send commercial communications electronically or by conventional means to users registered on the Platform | Contact details and record of requested and purchased ICF products | Article 21.2 of the LSSI [Spanish Law on Information Society Services and Electronic Commerce] or legitimate interest (to promote our products and services) |
To create a commercial profile that will be used to send commercial communications to the user. Please note that no automated decisions, which may produce legal effects concerning the user or similarly significantly affect him or her, shall be made on the basis of this commercial profile. | Identifying data and record of requested and purchased ICF products | Legitimate interest (to improve the impact of our commercial communications and build customer loyalty). Where legitimate interest does not apply, we will seek your consent. |
Carrying out customer satisfaction surveys in relation to ICF products and services | Identifying data | Legitimate interest (to improve our products and services) |
To prevent commercial communications being sent when the User has refused consent. | Identifying data | Legitimate interest pursuant to article 23.1 of Organic Law 3/2018 of 5 December on the protection of personal data and the guarantee of digital rights |
To guarantee the security of the Platform and prevent fraudulent access and attacks. | Identifying and location data and data regarding the devices from which the Platform is accessed | Legitimate interest (to protect our assets and interests and those of our customers) |
To transfer data to public bodies and/or mutual guarantee companies to process requests. | Identifying data and economic and financial data. | Contractual relationship or application of pre-contractual measures requested by the User |
To incorporate data into the Platform for Administrative Integration and Collaboration (PICA), which is held by the Ministry of Public Administration of the Department of Governance and Institutional Relations of the Government of Catalonia | Identifying data | Consent of the interested party |
How long will we keep your data?
We will generally retain your personal data for the duration of the contractual relationship binding us and as long as you do not ask to unsubscribe as a registered user on the Platform.
Notwithstanding the above, please be advised that we may retain your data if we are obliged to do so or when necessary until the statute of limitations lapses, in which case your data will be duly blocked and made exclusively available to the competent judges, courts and public administrations.
Who are the recipients of your data?
When you request information and/or the purchase of products offered by other companies in our group through the Platform, we may transfer your personal data to the group company in question in order to provide it with the required information and/or to handle and manage your request. This transfer is pursuant to the application of the pre-contractual measures requested by you and will be limited to the transfer of data strictly necessary to fulfil the aforementioned purpose.
Below we identify the companies that, together with the INSTITUT CATALÀ DE FINANCES, make up the ICF Group (hereinafter, the "ICF Group"):
Company | Financial Instruments for Innovative companies | Institut Català de Finances Capital SGEIC SAU |
---|---|---|
NIF | B65007494 | A65288037 |
Address | Gran Via de les Corts Catalanes, 635 – 08010 Barcelona |
Except for the transfer set out in the previous paragraph, your personal data will not be disclosed to other third parties, unless we are legally bound to do so, i.e. if we receive an administrative or judicial request that obliges us to disclose your data to an administrative or judicial authority. In such a case we would only disclose the data that we are strictly bound to disclose.
This is without prejudice to the suppliers we may use to provide the services requested and who, in any case, will process the data in their capacity as processors solely and exclusively for the provision of the services. If they are located outside the European Economic Area (EEA), we will endeavour to use suppliers located in territories that offer a sufficient level of data protection. If these suppliers are located outside the EEA, we will offer sufficient guarantees through the implementation of standard data protection clauses adopted by the Commission, guaranteeing your enforceable rights and effective legal actions. You can obtain further information about these sufficient guarantees by contacting us or our Data Protection Officer through one of the contact methods stated above.
Where have we obtained your data?
The personal data that we process within the framework of the Platform is generally obtained when you register and subsequently use the Platform.
However, please note that you can register on the Platform as an employee in the event that a representative of the company for which you work has invited you to register. In this instance, the personal data required to invite you to register on the Platform — such as your name, surname and e-mail address — will be obtained from the representative of the company for which you work.
Finally, please note that if you are a customer of one of the other companies that make up the ICF Group (please refer to the previous section for these companies, along with INSTITUT CATALÀ DE FINANCES), registering on the Platform will involve transferring data regarding the products you have purchased with them to INSTITUT CATALÀ DE FINANCES for the sole and exclusive purposes of being able to view and manage your products purchased through the Platform. The legal basis covering this transfer by these entities to INSTITUT CATALÀ DE FINANCES is the maintenance and fulfilment of the contractual relationship between you and INSTITUT CATALÀ DE FINANCES, with the transfer being strictly necessary for operating and managing the purchased products through the Platform.
What are your rights when you provide us with your data?
You have the right to exercise the following rights at any time:
Rights of access, rectification and erasure: Access your personal data, request the rectification of inaccurate data and request its erasure.
Right to object to receiving commercial communications: You have the right to object to receiving commercial communications about our products by emailing protecciodedades@icf.cat, including all commercial communications that you may receive or via the Privacy section in your user account on the Platform. In this instance, we will retain your data for the purpose of no longer sending you such commercial communications.
Whether you object at the time of registering on the Platform or at any time after receiving commercial communications from us, please be advised of the advertising opt-out schemes to which you may subscribe if you do not wish to receive general commercial communications. You can find more information on the opt-out schemes currently in place through the following link: https://www.aepd.es/areas/publicidad/index.html
Restriction and portability: In some instances, you may have the right to request the restriction of the processing of your data, in which case we will only retain your data to exercise or defend legal claims, and the right to request the portability of your data.
You may exercise the aforementioned rights either by providing written notification to INSTITUT CATALÀ DE FINANCES (Gran Via de les Corts Catalanes, 635, 6ena planta, 08010 Barcelona); by emailing protecciodedades@icf.cat and indicating the right you wish to exercise and by identifying yourself with a photocopy of your national ID card (DNI) or equivalent document.
Please be advised that we will respond to your request within the legally prescribed time frames and that, in any case, you have the right to file a complaint with the Catalan Data Protection Authority (www.apdcat.cat) or with the Spanish Data Protection Agency (www.aepd.es).