Privacy Policy
Who we are
For the purpose of applicable data protection laws, the data controller is Main Office Santa Croce Capital Management.
Metro Office Park No. 7, Suite 204
Guaynabo, Puerto Rico 00968
Information covered by this Policy:
This policy covers all personal information collected and used by us.In this policy, "personal data" or "personal information" means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognized directly or indirectly.
This may include your name, date of birth, nationality, gender, postal address, email address, phone number, and technical information from the devices you use to access our website.
What information do we collect from you?
We may collect information about you from different sources as detailed below.
Information you give us:
You may give us information about yourself when you respond to a communication from us or by filling in forms (both online and offline), over the telephone and through written correspondence with us.
The information you give us may include your name, postal address, email address, date of birth, landline and/or mobile telephone number, as well as other personal information.
Information we receive and collect from other sources:
We may receive information about you from other websites operated by us or from the other services that we provide. We may also collect information about you from publicly available sources, including publicly available content on social media.
How do we use your personal information?
To comply with legal requirements and exercise or defend legal claims.
To process your personal information where this is necessary to keep our website safe and secure.
To keep an up-to-date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you.
How do we use personal information for this purpose?
We may sometimes need to process personal information to comply with legal requirements to which we are subjected.
We may need to process your personal information to keep our website safe, secure and protected against illegal or fraudulent activity such as cyber-attacks.
We understand that you may prefer for us not to contact you. We keep records of your preferences to ensure that we do not contact you if you have asked us not to.We may need to process certain pieces of your personal information (such as your name and email address) to do this.
What is the legal basis for us processing your information in this way?
It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with our legal obligations.
It is in our legitimate interests to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website.
This helps us to ensure that you can safely use our website.It is in our legitimate interests to process personal information in order to maintain an up-to-date suppression list and ensure that we do not contact you where you have asked us not to.
Where we store your personal information?
The personal information that we collect from you will be stored in Puerto Rico, although it could be transferred to any Company within the Santa Croce Capital Management, regardless of geographic location, in the process of our business operations. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy and applicable data protection laws.
Security of personal information
All information you provide to us via our website is stored on our secure servers.We have taken steps to safeguard the integrity of our communications and computing infrastructure, which includes implementing authentication, monitoring, auditing, and encryption technology. Security measures have been integrated into the design, implementation, and day-to-day operations of this website as part of our continued commitment to the security of electronic content and the electronic transmission of information. Despite our best efforts, unfortunately the transmission of information via the internet is not completely secure.Although we have strict procedures and security measures in place, we cannot guarantee the security of your data transmitted to our site.
Third Party website and apps
Our websites may contain links to and from third party websites.Please note that if you follow a link to any of these websites, these websites will have their own terms of use and privacy policies and that we do not accept any responsibility of liability for these policies.Please check these policies before you submit any personal data to these websites.
Your rights
You may have the following rights with respect to the personal information that we hold about you.
Your right to access the information we hold about you:
You have the right to object to us processing your personal information, even where that processing is necessary for our legitimate interests (for example, where the processing is necessary for the legitimate commercial objectives we pursue during the course of our business).
You also have the right to object to any results of a processing activity that prejudice your rights and that are conducted exclusively through automated systems.You also have the right to ask us to stop processing your personal information for direct marketing purposes, including any profiling we undertake for the purposes of direct marketing.We will in any case only send you marketing communications if you have previously agreed to this, but if you change your mind you can easily unsubscribe from our marketing communications at any time by following the instructions included in these marketing communications.
Please note that, if you have consented to receive offers from our partners, our partners are responsible for taking account of your rights, including your right to opt-out of receiving offers from them.
Your right to object to us processing your personal information:
You have the right to object to us processing your personal information, even where that processing is necessary for our legitimate interests (for example, where the processing is necessary for the legitimate commercial objectives we pursue in the course of our business). You also have the right to object to any results of a processing activity that prejudice your rights and that are conducted exclusively through automated systems.
You also have the right to ask us to stop processing your personal information for direct marketing purposes, including any profiling we undertake for the purposes of direct marketing. We will in any case only send you marketing communications if you have previously agreed to this, but if you change your mind you can easily unsubscribe from our marketing communications at any time by following the instructions included in these marketing communications.
Please note that, if you have consented to receive offers from our partners, our partners are responsible for taking account of your rights, including your right to opt-out of receiving offers from them
Your right to have your personal information transmitted to another organization:
Where we hold personal information about you with your consent or for the performance of a contract with you, you also have the right to ask us to provide you with the personal information we hold about you in a structured, commonly used and machine-readable format and, where technically feasible, to transmit that personal information to another organization.
Making a complaint
You may have the right to lodge a complaint with a local data protection authority if you believe that we have not complied with applicable data protection laws.
The local data protection authority will differ depending on the country you are in.
Contacting us
If you have any questions or concerns about how we treat your personal information, you wish to ask us to stop processing your personal information, or you would like to request a copy of the personal information we hold about you, please contact us here or by writing to us at:
Metro Office Park No. 7, Suite 204
Guaynabo, Puerto Rico 00968 San Juan, PR 00907
Please include your reply address when you write to us.
How long do we keep your personal information?
Your personal information is stored by us and/or our Service Providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws.
When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
Changes to this Policy
We may update this policy from time to time in response to changing legal, regulatory, or operational requirements. Any changes will be updated on our website.Your continued use of our website and/or services after any such updates take effect will constitute acceptance of those changes.
Updates
We keep this policy under regular review and may update it at any time. Please take a look at the "Last Updated" section at the bottom of this Policy to see when it was last changed. Any changes in this Policy will become effective when we make the revised Policy available on or through the Site. We also encourage you to check this Policy on a regular basis.
We will notify you of any changes (including when they will take effect) if we are required to do so by data protection or eprivacy laws.
Last update: March, 29, 2021