PRIVACY POLICY

1. INTRODUCTION

The General Data Protection Regulation (“GDPR”), published in May 2016 and applicable from 25 May 2018, is directly applicable across the European Union and requires, pursuant to the principle of transparency, that data subjects are informed about the circumstances and conditions governing the processing of their personal data.

2. IDENTIFICATION AND CONTACT DETAILS OF THE PERSON IN CHARGE

HWK TECHINVESTMENT S.G.E.I.C., S.A., a company with registered office at Carretera de La Coruña, km 17.800, Edificio Madroños, 3, 28231 Las Rozas de Madrid, Madrid, Spain, and VAT No. A19939438 (hereinafter, “HWK” or the “Company”), is the data controller of your personal data.
This Privacy Policy provides information on how the Company will use your personal data as a user of this Website.

The purpose of this Privacy Policy is to provide information about your rights under the General Data Protection Regulation. Should you have any questions regarding the processing of your personal data, please contact the Company at: protecciondedatos@hwk.es

3. NECESSARY AND UPDATED INFORMATION

All fields marked with an asterisk (*) on the Website’s forms are mandatory. Failure to complete any of these fields may result in the inability to provide the requested services or information.

You must provide truthful information, ensuring that the information provided is always up to date and free from errors. You must notify the Company as soon as possible of any changes or corrections to your personal data by sending an email to: protecciondedatos@hwk.es

Furthermore, by clicking the “Accept”, “Send”, or equivalent button included on the forms, you declare that the information and data you have provided are accurate and truthful.

4. GENERAL INFORMATION: DESCRIPTION OF THE INFORMATION CONTAINED IN THE PRIVACY POLICY

In this Privacy Policy, and in relation to each of the different data processing operations carried out by the Company, you will find the following information:

A. The purposes for which your personal data are processed.
B. The legal bases that allow the Company to process your data for each of the specified purposes.
C. Potential communication of your data to third parties and the grounds for such communication. We inform you that your personal data will not be disclosed to third parties except where there is a legal obligation to do so.

Additionally, processors acting on behalf of the Company may access your personal data — i.e. service providers who require access to your data in order to perform their duties. We further inform you that some of the systems used by HWK in its operations are located in other countries, whether or not within the European Union, which may involve an international transfer of personal data. For these purposes, HWK has adopted appropriate measures to ensure protection equivalent to the standards set out in the GDPR. In all cases, data transfers shall only be made where the rights, freedoms, and legitimate interests of the data subjects do not prevail. You may request further information about the recipients of your data by sending an email to protecciondedatos@hwk.es, indicating the specific processing activity for which you would like further details.

D. The retention period for the personal data provided. We also inform you that your data will be blocked for the handling of potential judicial, administrative or tax claims for the periods required under the applicable legislation.

5. DETAILED INFORMATION ON THE TREATMENTS PERFORMED BY HWK  

As a general rule, personal data are processed for the following purposes:

6. INFORMATION SECURITY

In accordance with Article 32 of the GDPR, HWK undertakes to adopt the necessary technical and organisational security measures to ensure that the processing of personal data is carried out in accordance with the applicable national and European legislation on privacy and data protection.

7. EXERCISE OF YOUR RIGHTS

We inform you that you may exercise the following rights:

• Right of access to your personal data, to know which data are being processed and the processing operations carried out.

• Right to rectification of inaccurate personal data.

• Right to erasure of your personal data, where legally possible.

• Right to request the limitation of the processing where the accuracy, legality, or necessity of the data processing is doubtful — in which case data may be retained for the establishment, exercise, or defence of legal claims.

• Right to the data portability where the legal basis for processing, as indicated above, is contractual performance or consent.

• The right to object to the processing of your personal data where the legal basis is the Company’s legitimate interest. In such cases, we will cease processing your data unless we have compelling legitimate grounds or need to do so for the establishment, exercise, or defence of legal claims.

• Right to revoke your consent at any time.

You may exercise your rights at any time and free of charge by sending an e-mail to protecciondedatos@hwk.es or by writing to:

HWK TECHINVESTMENT S.G.E.I.C., S.A.
Carretera de La Coruña, km 17.800
Edificio Madroños, 3
28231 Las Rozas de Madrid – Madrid, Spain

clearly indicate the right you wish to exercise and include your identification details.

HWK will respond to your request as soon as possible, and in any case within one month of receipt. This period may be extended for an additional month if necessary, depending on the complexity and number of requests. HWK will inform you within the first month if an extension is required.

If you are not satisfied with the response received in relation to the exercise of your rights, you may lodge a complaint with the competent Data Protection Supervisory Authority, without prejudice to any legal action you deem appropriate. The contact details of the Spanish Data Protection Agency are as follows:

• Online portal: https://sedeagpd.gob.es/sede-electronica-web/
• Postal address: Agencia Española de Protección de Datos
  C/ Jorge Juan, 6, 28001 Madrid, Spain

8. MODIFICATION AND UPDATING OF THE PRIVACY POLICY

HWK reserves the right to modify and update this Privacy Policy in line with applicable legislation at any given time. Any changes will be published on this Website, and therefore we recommend revisiting the terms periodically.

Last updated: December 2025.