PRIVACY POLICY AND DATA PROTECTION

(*) Privacy Policy and Data Protection must be incoporated as parto f Legal Policy (6º).

Aura, in accordance with the provisions of Organic Law 15/1999, its implementing regulations and the recent EU Regulation 2016/679 of the European Parliament and Council of 27 April 2016 (LOPD) and its implementing regulations, guarantees the security and confidentiality of personal data  provided  by  the  user  through  the  Website,  as  well  as  any  other  means  (computer,  telephone…). Aura is particularly sensitive to the protection of personal data of users of its services (hereinafter, the “Data Protection Policy”).

Aura informs the users of the Website, of the uses to which the personal data collected and provided to Aura are submitted, in order to decide, freely and voluntarily, if they wish to provide the requested information.

Aura  reserves  the  right  to  modify  this  Data  Protection  Policy  in  order  to  adapt  it  to  new  legislation, jurisprudential criteria, industry practices, or interests of the entity. Any modification in it will be announced with due notice, so that users have perfect knowledge of its content.

RESPONSIBLE: The person responsible for processing personal data is the company “AURA ASSET MANAGEMENT, S.L.”, a company of Spanish nationality, with registered office in Madrid, calle Almagro 3, 4º right, with C.I.F. number B‐87.056.123, whose contact details are: emmanuel@auraam.com / +34617836456

PURPOSE OF THE PROCESSING OF THE DATA: The data facilitated by the user will be treated with the purpose of managing and attending to requests of information, doubts, complaints, congratulations or suggestions to any services or activities or acts provided by Aura. Aura undertakes to keep secret with respect to them, guaranteeing the duty to keep them,  taking  all  necessary  measures  to  prevent  their  alteration,  loss,  treatment  or  unauthorized access, of in accordance with the legal obligations of the party responsible for processing your personal data.

CONSERVATION  OF  DATA:  The  personal  data  provided  will  be  kept  for  the corresponding period to comply with legal obligations, if any, or for as long as a judge or court may require them. Data based on consent will be retained as long as the user refuses consent or opposes processing.

LEGITIMACY OF VBARE FOR DATA PROCESSING: Aura is entitled to the processing of personal data provided by users on the basis of the consent given by the data subject for one or more specific purposes, as stated in Article 6.1. a) of the General Regulation on the Protection of Personal Data. In case the user provides personal data to Aura as a consequence of the use of telephone voicemail, the fact of having provided personal data imply the consent and knowledge by the user to the processing of their personal data. In  the  event  that  the  user  provides  personal  data  to  Aura  as  a  result  of  the  use  of  telephone voicemail, the fact of having provided personal data, implies the consent and knowledge by the user to the processing of their personal data.

ACCURACY OF  DATA  AND VERACITY  OF DATA:  The  user  will  be  responsible  for providing truthful and lawful information. In order that the data in the files, computer and/or paper, always correspond to reality, Aura will try to keep them updated. To this end, the user must communicate the change or update of data to Aura.

ASSIGNMENT OF DATA: Aura will not transfer the data to third parties, unless there is a legal obligation.

CHECKING OF DATA: The user will have the right at any time to be informed by Aura whether their data is being processed correctly, as well as to lodge a complaint with the Spanish Data Protection Agency in case of disagreement with the treatment carried out by Aura.

RIGHTS OF USERS: The user may at any time exercise their rights to: i) request access to their personal data, ii) rectification of their personal data iii) deletion and forgetting of their personal data, iv) limitation of the processing of their personal data, v) oppose the processing of their personal data and vi) request the portability of personal data.

To this end, the user must send a written request to Aura, to its registered office at Calle Almagro number 3, 4º floor right of Madrid through emmanuel@auraam.com / +34617836456. Aura must resolve the request made by the user within a maximum period of ONE (1) MONTH from receipt of the request, which may be extended to TWO (2) MONTHS taking into account the complexity of the request or the number of requests received.