SEKONDARY, S.L. (hereinafter "Sekondary") is the owner of the website https://sekondary.com/ (hereinafter the "Website") and is responsible for the processing of the personal data of the users thereof (hereinafter the "Users").
Through this Privacy Policy, and in compliance with Articles 12 and 13 of Regulation (EU) 2016/679 (hereinafter "GDPR") and Article 11 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights ("LOPDPGDD"), Sekondary informs Users who use the Website about the processing of their personal data that may be collected through this and processed by Sekondary.
In order to allow the User to access and use the Platform and Sekondary Services, Sekondary may process some personal data in the capacity of:
Data Controller: SEKONDARY, S.L.
VAT Number: B-72794613
Registered office: Diagonal, 359, 08037 Barcelona (Spain).
Contact: legal@sekondary.com
| Purposes | Data processed | Legal Basis | Retention period |
|---|---|---|---|
| Management of the functionality of the Website. Analysis of browsing behavior and statistics: The information collected through cookies and other similar tracking technologies allow an analysis of the navigation made by Users | The IP address of User's computer and the type of browser User is using. We use this information to analyze general trends and improve the service. This information is not shared with third parties without User's consent. | Consent of the User (Not necessary cookies). Legitimate Interest (Necessary Cookies). | The retention periods depend on each specific cookie. For more information on the information retention periods for each type of cookie, see the Cookie Policy. |
| To attend and respond to requests, comments, suggestions. As well as providing support to the User during the use of the Website. | User's name, email, phone number, company and the content of the message the User sends to Sekondary. | Consent | The personal data will be processed by Sekondary for the necessary period of time to answer the question and/or solve the incident indicated by the User. Such data will be blocked in order to comply with Sekondary' legal obligations and, after that time, will be definitively deleted. |
| Sign up on the Platform. Manage the registration of Users on the Platform | User´s identification data (name, surname, KYC when applicable), image (optional) | Execution of the Terms and Conditions | The personal data provided will be kept for as long as the User maintains his/her account. In the event that the User wishes to cancel his/her account Sekondary will proceed to delete the data*. |
Sekondary may also process the User's personal data during the period of time in which civil, commercial, administrative, criminal or tax liabilities may arise, in compliance with the applicable regulations in force. Once these periods have expired, Sekondary will delete this personal data.
Sekondary informs that, for the fulfillment of the purposes described above, it will not transfer the User's personal data to third parties. Notwithstanding the above, Sekondary may give access to such personal data to registered Users and technological service providers with which it has entered into a data processor contract, in particular to:
The aforementioned providers may be located in jurisdictions that generally do not provide adequate safeguards in relation to the processing of personal data. For all entities that are not part of the European Economic Area (EEA), Sekondary has entered into contracts with such entities that include such safeguards, including the European Commission's standard clauses.
Also, the data may be provided to:
Sekondary undertakes to adopt the necessary technical and organizational measures, in accordance with the provisions of the applicable regulations, to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data. The personal data will be processed confidentially by Sekondary, which undertakes to inform and enforce, by legal or contractual obligation, such confidentiality to its employees, partners and any person who should have access to the User's personal data.
The User may exercise the rights of access, rectification, deletion, opposition and, where appropriate, limitation of processing and portability of data by sending an email to legal@sekondary.com.
Likewise, the User may file a complaint with a supervisory authority and, in particular, with the Spanish Data Protection Agency (www.aepd.es) if he/she considers that the rights set forth above in this Privacy Policy have been violated or if he/she considers that the processing of personal data concerning him/her violates the applicable regulations.
Sekondary reserves the right to modify this Privacy Policy at any time. If the Changes or updates to the Privacy Policy will be explicitly notified to the User by means of a notice on the Website, together with the updated version of the Privacy Policy.
Latest version: November 2023
Introduction
This Annex is entered into pursuant to Art. 28.3 of GDPR and regulates the processing of personal data by Sekondary ("Sekondary" or "Data Processor") on behalf of the Institutional Investors, Business Angels, those acting as legal entities and natural persons, and Directors and Shareholders who complete the KYC registration form("Customer" or "Data Controller") in the course of providing its Services under the Terms. The duration of such processing shall be for the period during which the Parties perform their applicable obligations under the Terms.
During the provision of its Services under the Terms, Sekondary process certain personal data for and on behalf of the Business Angel in particular (but without limitation) the data set out below in Annex 1 ("Personal Data") relating to the indicated persons included in the same Annex below ("Data Subjects").
Under applicable privacy regulations, Customer is responsible for this Personal Data and is what is known under privacy regulation as the "Data Controller". Therefore, Customer appoints Sekondary as a "Data Processor" of this Personal Data, to process the Personal Data on Customer's behalf, for the purpose of providing the Service indicated in the Terms.
Personal Data accessed, type of processing and purposes.
For the provision of the Service, Sekondary may process on behalf of the Customers the Personal Data that will be indicated in Annex 1 paragraph A, and the type of processing as well as the purpose is indicated in Annex 1 paragraph B and C respectively.
Attribution of responsibility
Customer is made aware that for the purpose of providing the Service, Sekondary may access and process the aforementioned Personal Data on its behalf without the prior informed consent of the data subject. The Parties agree that the processing of the Personal Data on behalf of the Customer as part of the Services is legitimized by the acceptance of the Terms by the Customer in the signing up process.