Data protection policy

Treatment of personal data

At Galaicus Fintech, S.L. (hereinafter INVERSA) we care about security and confidentiality in the treatment of information and data provided by our clients and in their financial transactions. For this reason, we share with you our Data Protection policy in accordance with the General Data Protection Regulation “Reglamento General de Protección de Datos (RGPD) UE 2016/679, de 27 de abril de 2016, aprobado por el Consejo y Parlamento Europeo”, to maintain at all times your data in a lawful, reliable and transparent manner in accordance with national and European legislation both in the collection and in any subsequent processing of your personal data.

In addition to the Principles of legitimacy, integrity and legality when processing personal data, this Data Protection Policy will pay special attention to the principles of minimisation, accuracy, limitation of the conservation period that necessary, as well as integrity and confidentiality and, in general, proactive responsibility.

INVERSA has developed this Data Protection Policy to help you obtain information about our privacy practices and to help you understand the options you have available when using our website and services. You can find more information in the Cookies policy and in the General Conditions of Use.

By providing us with your personal information and when using our websites, we understand that you have read and understood the terms related to the information on personal data protection that have been set out; we are in any case at your disposal for any clarification.

Who we are?

Galaicus Fintech, S.L. is a company that was born in 2017 with the brand name INVERSA, dedicated to intermediation, discounting promissory notes and invoices through a Platform that it made available to its clients. Inversa is registered in the Mercantile Register of A Coruña, “Registro Mercantil de A Coruña (Tomo 3631, Folio 20, Hoja C-56.394, inscripción 1ª)”; with registered address at C/Estrella, nº4, 15401, Ferrol (A Coruña) and TIN (CIF) B-70535414.

The services offered by INVERSA are subject to current legislation. INVERSA's activity is not subject to any prior administrative authorisation regime, nor are the projects included on the Platform subject to authorisation by the National Securities Market Commission (CNMV) or Spanish Central Bank (Banco de España). INVERSA presents the data on the Platform for informational purposes only and does not provide any financial advisory service. Investors themselves must assess and decide whether the investment meets their needs and risk profile, as they are solely responsible for the decision taken and its results. INVERSA enables the use of the Platform as a channel to put in contact investors and funding applicants or assignors; INVERSA is not responsible for the results of the investments, the INVESTOR is who takes on the entire risk of the investment made.

For what purpose do we collect your personal information?

The information you provide is used to offer you the best possible service with the levels of quality and guarantee that you expect from us both when managing your contracts on the Platform, and to maintain the commercial relationship and keep you informed, unless you object, regarding offers and financial services that we offer you.

Unless we expressly indicate otherwise at the time of collecting your personal data, all personal data that we collect through the Website or by any other means, is mandatory, essential for the formalisation, maintenance, development, compliance and / or control of the business relationship, and where appropriate, for the assessment of your request. Refusal to provide any personal data, consent to any of the requested authorisations or opposition to any of the reported treatments, could lead to the failure of providing the requested service, and where appropriate, to the automatic denial of the request, of which you would be appropriately informed.

In any case, the purpose of commercial prospecting is voluntary and as we have indicated, you can oppose to it at any time. With your consent, your personal data may also be used, to send or communicate, by any means including mail, telephone, Internet, SMS or other electronic means, information, advertising and offers of products and services of other companies related to the financial, distribution, insurance, health and beauty, housing, telecommunications, leisure, training, hotels, restaurants, travel, transportation, mass consumption, automotive, energy, water and NGO sectors.

INVERSA will check the advertising exclusion lists in order to avoid sending unwanted advertising. You can request at any time to stop receiving advertising from us or from third parties, if authorised. In this case, and to meet your request, you will be included in a list with the sole purpose of reducing or suppressing the advertising you receive.

In addition, in order to continue offering you products and services of your interest and to improve your experience as a client, we prepare a "client profile" based on the information provided. We do not make individual decisions based solely on automated processing. Likewise, we will carry out market studies and commercial prospecting, reports on consumption habits, statistical data and market trends in order to improve or expand those services that may be of interest to you.

On the other hand, we also use your data to control fraud by preparing credit rating profiles (scoring). This information will be used exclusively for this purpose, or to comply with legal obligations.

How have we obtained information about you? What personal data do we collect?

We collect personal information about you by different means, mainly when you have hired through our websites. In any case, at the time of data collection, you will be informed of the entity responsible, the purpose and justification, the recipients of the information, as well as the way to exercise the rights granted by the current legislation on data protection, information that is included in the conditions of your contract with INVERSA.

In general, the personal information that you provide us is: name, surname, address, ID, date of birth or age, email, contact telephone numbers, payment information, academic and professional information, employment, commercial information, social circumstances, economic, financial and insurance, and transfers of goods and services.

INVERSA's promotional offers and its website are not aimed at minors. If you are a minor, please do not attempt to register as a user of our websites, applications or products. If we discover that we have mistakenly obtained personal information from a minor, without proper authorisation, we will delete such information as soon as possible.

We collect personal data when you visit our websites and / or use our services, and specifically, when you carry out he subsequent-uses, we collect the following data:

What is the legitimacy for the processing of your data?

We specify below the legal basis that justifies in each case the different processing of your personal data:

  1. As a consequence of the contract to be entered into, to ensure the Websites work and provide services: the offering of financing and investment opportunities in INVERSA's proposals, as well as invoicing, accounting, execution and management of payment operations, in its case, services and declaration for tax purposes when it comes from said operations. We also use your personal data to authenticate your access to your account, communicate with you regarding your account, the websites, create a connection between your account and an account at an external payment entity.
    The Client consents and authorises INVERSA to keep their data, even when the request has not been accepted by INVERSA, in order to comply with legal obligations and avoid duplication in the assessment of new requests.
  2. As a consequence of the legitimate interest of INVERSA, the following treatments are based, which are necessary to be able to provide you with the service:
    1. Evaluate the requests received and compare information to check its accuracy and verify it, carry out a correct evaluation of the information sent to make an adequate risk assessment, provide greater security in the activity and improve the commercialisation of the products and services offered by INVERSA .
    2. Carry out solvency checks, consult the existing financial solvency files and notify them of any payment incident, provided that the requirements established by the applicable Personal Data Protection regulations are met.
    3. Evaluate the credit capacity for the purpose of studying the pre-grant, approval or denial of the application, request information regarding credit history for the analysis and decision of your financing request from any person recognised in law that INVERSA considers relevant and, in case of concession, for its follow-up. INVERSA may use scoring or scoring valuation models, including exclusively automated processing or not.
    4. Use the data derived from their relationship with the Client in a dissociated way to be able to carry out statistical or market analysis and studies that can be used and exploited for own benefit or that of third parties.
    5. Manage our business needs, such as monitoring, analysis or improvement of services and websites, as well as their operation and tools.
    6. Manage risks, services and prevention of fraud or abuse.
    7. Comply with the conditions of our websites and services, manage our day-to-day business needs and comply with regulatory obligations and current legislation at all times.

      In the case of Advertising and Commercial Actions, also on the basis of legitimate interest, unless you have already granted us your consent:

      The prospective offer of products and services by any means including mail, telephone, Internet, SMS or any electronic means is based on the legitimate interest of the company to offer its products and services by any of the means described to its contacts, authorising said communications of products and services of Galaicus Fintech, SL (INVERSA) related to the financial sector. According to law on Information Society Services, “Ley 34/2002, de Servicios de la Sociedad de la Información”, if you are our client and maintain a contractual relationship with us, we are legally authorised to send you commercial communications, via email or other equivalent electronic means (for example SMS), related to products or services similar to those that you have hired with us, in all other cases, we will obtain your express consent.

    8. Prepare client profiles for commercial purposes, to offer them INVERSA and / or third parties products and / or financial services, associated with the activity of the Entity, and belonging to the financial activity sectors.

      On the basis of your consent:

      • The prospective offer of products and services by any means including mail, telephone, Internet, the Platform itself or SMS, or any other electronic means in order to provide you information, advertising, newsletters and INVERSA offers, also authorising said product communications and third-party services related to the financial, distribution, insurance, health and beauty, housing, telecommunications, leisure, training, hotels, restaurants, travel, transport, mass consumption, automotive, energy, water and NGO sectors. We may also process your personal data to personalise certain services or websites, with the intention of responding better to your interests.
      • Provide personalised services, offers or samples offered by INVERSA on third party websites and internet services. We may use cookies and other tracking technologies to provide these services online or work with third parties, such as data analytics or advertising companies, to provide such services.
      • Provide you with options, offers and specific functions for your location, whenever you decide to share your Geolocation Information in the services. We will use this information to improve the security of the Websites and services, and to provide you with services based on your location, such as advertising, search results, and other personalised content.
      • To respond to your requests, for example those related to Customer Service.

The information provided may be communicated to service providers with the purpose and treatments described. However, regarding commercial prospecting treatments, you can contact the Customer Service Department at any time if you consider it appropriate to exercise your right to object to the processing and / or communication of data for this purpose of offering you products and services, since this data processing is optional and independent of the hiring of services requested. To exercise these rights you can do so through the email address hola@inversa.es or through our mail address: C/Estrella nº4, 15401, Ferrol (A Coruña).

To which recipients will your data be communicated?

When there is an enabling cause for this, we may communicate the information you provide to other companies.

At INVERSA we are committed to protecting your personal information and your privacy using the appropriate technical and organisational measures, taking care of both the physical security of our facilities and servers as well as logical security. Therefore, if in order to provide you with the best service with the best professionals, we need to communicate to other companies which we entrust functions such as communication, logistics, computer services, security services, financial, etc. the personal information they need to carry them out, we require them to apply the same degree of information protection as we do. These third-party companies act as data processors and only have access to the personal information they need to carry out those services. They are required to keep your personal information confidential and may not use it in any other way than what we have requested.

We may share your personal data or other information for the following reasons:

In addition, INVERSA may provide aggregated statistical data to third parties, including other companies and individuals, on how, when and why users visit our websites and use our services. This data will not identify you personally or provide information about your use of the websites or services.

International data transfer

The personal information we collect resides in Spain. In the event that services are contracted in Cloud Computing mode making international transfers, the appropriate guarantees will be adopted to protect your information regarding which you can obtain additional information by writing to hola@inversa.es.

Links to third party websites

In the event that we provide links to websites that are not operated or controlled by INVERSA, you will be duly informed since INVERSA does not have any control over said sites nor are we responsible for their content, nor do we have control over the way in which those third parties collect and use your personal information, nor are we responsible or make any declarations about third party websites.

Normally these websites have their own privacy or data protection policies, through which they will explain how they use and share your personal information. We recommend that you carefully review these policies before using these websites to ensure that you are satisfied with the way your personal information is collected and shared.

Period of conservation of your personal information

We only store your personal information to the extent that we need in order to be able to use it according to the purpose for which it was collected, and according to the legal basis for its treatment in accordance with applicable law. This way, we will only keep your personal information as long as you do not exercise your right to suppress, cancel and / or limit the processing of your data, or in case of exercising any of these rights that does not proceed according to the legal basis of the treatment.

In these cases, we will keep the information duly blocked, without giving it any use, as long as it may be necessary for the exercise or defence of claims or any type of judicial, legal or contractual responsibility that may arise from its treatment that must be attended and for which its recovery is necessary.

In general, the personal data that you have provided will be kept and processed as long as the commercial relationship is maintained, without prejudice to the possibility of exercising your right of deletion, in which case we will block your data for as long as legal obligations persist.

In any case, your personal data may be kept until:

We may keep personal data for a period longer than required by law, if it is in our own legitimate and business interest, for the following reasons, as long as it is not prohibited by law:

In the event that the request has not been accepted by INVERSA, your personal data will be kept in order to comply with legal obligations and avoid duplication in the study of new requests, unless after 6 months from the denial you request your opposition.

The cookies we use have defined expiration times. The User can revoke their consent for the use of cookies in their browser through the options of the manufacturer of the browser he is using. You should bear in mind that some characteristics of the contents of the INVERSA website are only available if the installation of Cookies is allowed in your browser. If you decide not to accept or block certain Cookies (depending on their purpose), this may affect, totally or partially, the normal operation of the Web page or prevent access to some services of the same. You can get more information by visiting our Cookies policy.

How can you exercise your rights?

As the owner of the rights to your personal information, you have control over this data. This way, we also ensure that the information is accurate and truthful.

In cases where you have given us your consent for any of the treatments, you can withdraw it, without affecting the legality of the treatment based on said consent when signing your contract and the legal consequences thereof. You will be able to exercise your rights at no cost, and you will have the right to receive a response within the deadlines established by current legislation on data protection, being able to choose between the following means:

You can file a claim with the Spanish Agency for Data Protection, especially when you are not satisfied with the response of the exercise of your rights, for more details you can consult the website www.agpd.es

What privacy options do you have available?

You have several options regarding the communications and privacy practices described in this Data Protection Policy. Many of these options are explained at the time you create an account or register for the use of a service or directly when using one of our websites. Instructions may be provided to you within your own experiences when navigating the Services.

How do we protect your personal information?

At INVERSA we are committed to protecting your personal information and your privacy using the appropriate technical and organisational measures, and we review these measures periodically. For an adequate protection of your information we take care of both the physical security of our facilities and servers as well as the logical security, even implementing access controls that restrict and manage the way in which your personal information and your personal data are processed, administered and managed. We also make sure that our staff is properly trained to protect your information and treat it only as necessary. In this sense, and for the sake of privacy, we may not provide you with your own data until we do not have sufficient proof of identity that we are indeed contacting you or someone duly authorised by you.

In accordance with our guarantee of security and confidentiality, we use firewalls, data encryption, physical access controls to our data centres and authorisation controls to access information. Although we strive to maintain the security of our systems and services, it is your responsibility to maintain the privacy of your passwords and your profile or account registration information. In addition, you must ensure that the personal data we store about you is accurate and up-to-date.

All payment operations are protected by Paymatico and BBVA Api Market security systems, which protect data against attempted breaches by third parties, among others. It is possible that access to our Websites may be slowed down or encounter problems depending on the model or version of your browser or the configuration of the options you have configured. We are at your disposal to help you in whatever way we can. Like you, we want Internet browsing to be safe and for this, in every Electronic Commerce transaction we make sure that our operations comply with the principles of:

Modifications to this data protection information

We will review and update the data protection information periodically and especially when there are changes in legislation or in any of the procedures for processing your personal information, indicating the date of the last update, content and date. The data protection policy will take effect on the published effective date.

If we have your email address or mobile phone, we may also inform you of such changes by email or SMS with information about such changes, apart from on the Platform itself. If necessary, we may ask you to renew your consent to confirm that you agree to these changes.

This data protection information was last reviewed and updated in September 2018.

Contact

If you have any type of query, comment or concern, or if you want to make a suggestion about how we treat personal information, you can contact the Customer Service Department at INVERSA address, C / Estrella nº 4, 15401, Ferrol (A Coruña), or by email to hola@inversa.es.