Privacy Policy

1. Data Controller

Freeholdbn S.L., with Tax ID (CIF) B-87654321 and registered office at Calle Gran Vía 28, Floor 5, 28013 Madrid, Spain, is responsible for the processing of your personal data. For any data protection inquiries, you may contact us at privacidad@freeholdbn.com.

2. Data We Collect

We collect data you provide directly: full name, email address, phone number, postal address, identity document and financial data necessary for investment operations.

We also automatically collect browsing data such as your IP address, browser type, pages visited and time spent on the platform through cookies and similar technologies.

3. Purpose of Processing

We use your data to manage your user account, process investments, comply with legal and regulatory obligations, send communications about your active investments, improve our services, and prevent fraudulent activities. We do not use your data for automated decisions without human oversight.

4. Legal Basis

Data processing is based on: execution of the investment services contract, compliance with legal obligations (anti-money laundering regulations and CNMV financial regulation), your explicit consent for commercial communications, and our legitimate interest in improving the platform and ensuring service security.

5. Recipients and Transfers

Your data may be shared with regulatory entities such as the CNMV and Bank of Spain when legally required, technology service providers under confidentiality agreements, and banking entities for payment management. We do not make international data transfers outside the European Economic Area without adequate GDPR safeguards.

6. Data Retention

We retain your data for the duration of the contractual relationship and subsequently for legally established periods. Financial operation data is retained for a minimum of 10 years in accordance with current Spanish tax and anti-money laundering regulations.

7. Your Rights

You have the right to access, rectify, delete, restrict processing, object to processing, and request portability of your personal data. You may exercise these rights by emailing privacidad@freeholdbn.com with a copy of your identity document.

You also have the right to file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es if you believe the processing of your data violates current regulations.

8. Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure or destruction. This includes data encryption in transit and at rest, role-based access controls, periodic security audits, and continuous staff training on data protection.

9. Amendments

We reserve the right to modify this policy to adapt to legislative changes or new platform practices. Any substantial modification will be notified to registered users by email at least 30 days before taking effect.