Privacy policy

Privacy Policy

This policy applies to all companies listed in the section “WHO IS THE DATA CONTROLLER RESPONSIBLE FOR PERSONAL DATA?”, (collectively referred to as “BESTINVER”). BESTINVER undertakes to process personal data in accordance with data protection regulations, in particular as set out in Regulation (EU) 2016/679 of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as well as any other applicable Data Protection legislation in force.

This Privacy Policy applies to all Users, understood to mean visitors to the website, as well as any other person who provides us with personal information through our various channels (hereinafter, the “User” or “Users”).

In this context, “Channels” refers to the various means or services that we make available to you in order to interact with us, whether or not they require registration. These may include websites, applications, platforms, mailboxes, telephone numbers or addresses for information or customer service, social media profiles, forms, events, etc.

Some of our online Channels may contain links to other websites or third-party applications accessible through our Channels, or, more generally, to any other services provided by third parties unrelated to BESTINVER. This Privacy Policy does not apply to such third-party sites or services. We recommend you also read the Privacy Policies of those third parties in order to familiarise yourself with their practices. If using any of these other resources, services or systems, the User agrees to be bound by the corresponding terms of use and privacy policies. BESTINVER provides such links and information and/or services solely for the User’s convenience. It is the User’s responsibility to read and accept the terms of use and privacy policies published on such linked websites and applications. The inclusion of such links within our Channels does not imply approval by BESTINVER.

On compatible devices, you may use biometric verification systems for authentication purposes. The only information received by BESTINVER is confirmation that authentication has been successful. BESTINVER cannot access the biometric verification data associated with your information. Such information remains stored on your device and is never saved in BESTINVER’s backup files or in any other locations.

Our Channels may also contain third-party cookies that are not owned or controlled by BESTINVER. In such cases, you may choose your third-party cookie settings using our Cookie Configuration Tool, where you can manage your preferences, accessible by clicking on Cookies.

Each of the entities and companies within BESTINVER takes the necessary technical and organisational measures to ensure the security of personal data and to prevent its alteration, loss, unauthorised processing or access, taking into account the state of the art, the nature of the data, and the risks to which it is exposed. You may also verify the presence of the SSL certificate by checking the properties of the website in your browser. A connection is deemed secure when “https://” appears in the browser’s address bar instead of “http://”, together with a padlock symbol. Further information about the SSL certificate may be found in the Legal Notice section.

BESTINVER informs Users of the Website that their personal data may only be collected for processing when it is adequate, relevant, and not excessive in relation to the scope and specific, explicit, and legitimate purposes for which it has been obtained. BESTINVER declares its commitment to comply at all times with the data protection legislation in force.

The User expressly consents to BESTINVER processing the personal data provided by the former for the purposes stated herein, under the terms set out in this Privacy Policy. In this regard, Users should be aware that, in order to subscribe to or register for certain products or services offered through the Website, they will be required to provide personal data.

WHO IS THE DATA CONTROLLER RESPONSIBLE FOR PERSONAL DATA?

The data controller for your personal data will be the entity or company that processes your data due to the existence of a contract, where applicable.

When you request information or register for an event, the data controller will depend on the product or service in question.

Each time personal data are collected and processed, we will inform the User as to which BESTINVER entity or company is acting as data controller, as well as providing the corresponding identification details:

1.- BESTINVER GESTIÓN, S.A. S.G.I.I.C.

Tax ID No: A78930005;

Registered in the Commercial Registry of Madrid: Volume 9,027; Page 159; Sheet M-85,655; Entry 1.

Address: C/ Juan de Mena nº 8, planta 3, 28014 Madrid (Spain),

Telephone: 900 878 280 (freephone in Spain) / 915 95 91 00

Activity: management of collective investment institutions.

2.- BESTINVER PENSIONES E.G.F.P. S.A.

Tax ID No: A81331720;

Registered in the Commercial Registry of Madrid: Volume 10,279; Page 170; Sheet M-163,748;

Entry 1.

Address: C/ Juan de Mena nº 8, planta 3, 28014 Madrid (Spain),

Telephone: 900 878 280 (freephone in Spain) / 915 95 91 00

Activity: management of pension funds.

3.- BESTINVER INDIVIDUAL E.P.S.V.

Tax ID No: V95670717

Registered with the Registry of Voluntary Social Security Entities of the Basque Country under

number 276-B.

Address: Calle Gran Vía Don Diego López de Haro, núm. 58, 4º – D, CP 48011

BILBAO

Telephone: 900 878 280 (freephone in Spain) / 946 42 77 61

Activity: voluntary social security entity.

Website: www.bestinver.es

Email: clientes@bestinver.es

A Data Protection Officer is a point of contact with the data controller for matters related to the processing of personal data. If you wish, you may contact the Data Protection Officer at protecciondedatos@bestinver.es.

The entity acting as data controller will depend on the product or service in respect of which information is requested.

WHAT PERSONAL DATA DO WE COLLECT THROUGH THE WEBSITE?

The data provided by Users are collected when they visit the Website or as a result of their interaction with us through the following means:

1.- In some cases, personal data are obtained indirectly from the User for purely statistical purposes, in order to analyse how the Website is used by means of cookies, or to provide value-added services such as a map showing the location of our offices (you may consult our Cookies Policy here).

2.- In other cases, personal data are provided directly by the User through data collection forms for the purposes specified in each of those forms and upon receiving consent from the User when subscribing to our Newsletter, webinars, Observatorio BESTINVER– IESE, or news bulletin, when contacting us through the channels made available, responding to surveys, subscribing to our social media profiles, or interacting with us through those profiles by posting comments, opinions or sharing the content published on each profile.

In cases where personal data are collected through our Channels for specific purposes, the User will be provided, in advance, with clear and unambiguous information regarding: (i) the data controller and its contact details; (ii) the specific purposes of the processing and the legal basis for such processing; (iii) the recipients or categories of recipients, where applicable, as well as the existence or otherwise of international data transfers; (iv) the retention criteria or periods; and (v) the rights of the User in their capacity as a data subject.

The User is solely responsible for the information they provide, as well as for its veracity and lawfulness.

In addition to the data you provide to us directly when completing forms or surveys, submitting requests or reporting incidents, we may also receive metadata associated with the documents you provide during the provision of the service. Such metadata may include, among other things, the name of the file creator, the date and time of creation, the document format, etc. We recommend reviewing and removing metadata before sharing files with us.

3.- In cases where financial or investment products are contracted on behalf of a minor, the processing of the minor’s personal data will be carried out solely with the explicit consent of their parents or legal guardians, who will manage the accounts on behalf of the minor until the latter reaches legal age.

Once the minor reaches legal age, they will be notified of this change in status and will assume control of their account. From that moment onwards, the processing of their personal data will be based on their own consent, in accordance with the applicable legal provisions.

Likewise, they will be recognised as having the right to manage their own personal data directly, in accordance with the applicable regulations, and will be informed about the processing of their personal data, including the updating of their profile to reflect their status as an adult in our systems.

Until updated contact details for the account holder who has reached legal age are obtained, communications relating to the financial or investment product will continue to be sent to the registered legal guardian. Once such contact details have been received and verified, communications will then be addressed directly to the account holder.

Each of the entities and companies within BESTINVER processes your personal data with absolute confidentiality and undertakes to keep such data secret, ensuring they are safeguarded by adopting all necessary measures to prevent any alteration, loss, unauthorised processing, or access, in accordance with the legal obligations applicable to it as the data controller of your personal data.

FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS PERSONAL DATA?

Each of the entities and companies within BESTINVER collects and processes Users’ personal data from the digital platforms referred to above for the following purposes:

– “Become an Investor” and Client Registration forms

These processing activities are necessary for the execution of a contract or the provision of a service and include, among others: user registration via the website www.bestinver.es; user management and maintenance and monitoring of browsing activity; management of the contracting of products or services offered by any of the entities or companies within BESTINVER; completion of the onboarding process; execution of subscriptions, redemptions, transfers and contributions; provision of alternative investment advisory services, etc.; as well as, in general, the operations inherent to each of the entities or companies within BESTINVER in their dealings with clients.

The legal basis for the processing of these data is the maintenance of the contractual relationships established between the users, clients, and suppliers of BESTINVER.

The data will be retained for as long as the contractual relationship remains in force, in compliance with statutory time limits, and, once terminated, for the applicable limitation periods covering liabilities arising from that relationship.

– Contact forms

The purpose of the processing will be to respond to Users’ enquiries and to send them the information requested.

Here, we will also process the data provided to respond to Users’ requests for services and information received through any of our Channels, as well as, where applicable, to process suggestions, claims or complaints. In such cases, we will collect your data in order to carry out the pre-contractual or contractual relationship necessary to provide our products and services efficiently.

The data will be retained for as long as necessary to deal with your enquiries, unless you request their erasure. The email address provided by the User may be used to send them advertisements and other commercial communications relating to services offered by the companies within BESTINVER, provided that the User expressly authorised this by ticking the corresponding consent box.

In this regard, the legal basis for processing the data is the consent given by the User when completing the information and ticking the relevant consent boxes.

Data used for the purpose of sending communications will be retained until their erasure is requested.

– Sending you commercial information about products or services similar to those contracted with the data controller with which you have contracted a product

Such actions may be carried out by any means, including electronic means (email, SMS, social media, mobile applications, etc.).

The legal basis for this processing is the maintenance of the contractual and/or commercial relationship between the parties and the legitimate interest of the data controller.

If you do not wish to receive such commercial communications, you may object at any time to the processing of your data for this purpose by replying to the email you receive with the subject line UNSUBSCRIBE, including your full name and address, or by sending an email to bestinver@bestinver.es, with the subject line UNSUBSCRIBE, including your full name and address.

Processing a withdrawal or opt-out from this type of communication will result in the cessation of all types of commercial communications, even when these were previously authorised by you.

– Browsing data

Such data will be processed in accordance with the Cookies Policy.

– Social media buttons

BESTINVER uses the social networks Twitter, Facebook, LinkedIn, SlideShare and YouTube. You may also share our content via the enabled social media channels: Interaction with Users through the use of such profiles or tools involves international data transfers of an analytical and technical nature in relation to the website and social media profiles, as the data provided by Users via those profiles are processed on the servers of the respective social media platforms.

The legal basis for processing the data is the consent granted by the User by ticking the corresponding consent box and voluntarily submitting their data.

If the data necessary for these purposes are not provided, the requested services cannot be rendered.

The User shall be solely responsible for the veracity of the data provided to BESTINVER. The User may object at any time to the processing of their personal data.

– Voice recordings and retention of telephone conversations, for the purpose of providing a record of certain actions by the client.

The legal basis that enables this processing is the compliance with legal obligations.

Recordings may be processed using artificial intelligence technologies exclusively for control purposes.

Likewise, such recordings may be processed for the purpose of providing a record of certain actions and evidencing the quality of the service provided, as well as for training purposes for BESTINVER staff.

In these cases, the processing will be based on the legitimate interest of BESTINVER, and the User may object to the processing of their data for this purpose.

– Compliance with applicable legal obligations

Including legal obligations of a commercial, tax, accounting or administrative nature.

The legal basis that enables this processing is the compliance with legal obligations.

– Prevention of money laundering

The processing of data for the purposes of preventing money laundering and terrorist financing is carried out solely and exclusively in order to take appropriate due diligence measures with regard to clients. The recipients of these data will be the internal control and compliance bodies of the entities and companies within BESTINVER, and they will not be used for any purpose other than those outlined above, except where necessary for the ordinary management of the business relationship. No disclosures of data to third parties are envisaged, except where legally required. The rights of access, rectification or erasure of personal data, restriction of processing, objection to processing and data portability shall not apply to this processing.

The data will be retained for a period of ten years from the termination of the business relationship or the execution of the transaction, after which they will be deleted.

These obligations shall continue to apply even after the contractual relationship has ended, where required.

The legal basis for such processing is compliance with applicable legal obligations, in this case Law 10/2010 of 28 April on the Prevention of Money Laundering and the Financing of Terrorism.

– Security and surveillance of premises

Our premises are equipped with cameras and video surveillance systems for the purpose of safeguarding the security of both people and property.

The legal basis for processing is the legitimate interest of BESTINVER in ensuring security at its premises, as well as compliance with public interest requirements.

– Management of visitors and third parties

For the purpose of controlling access to premises by visitors, collaborators or other third parties, identification data may be collected at some of our facilities.

In this case, the legal basis for processing is consent, as well as the legitimate interest of BESTINVER in ensuring the security of both people and property at its premises.

– Direct marketing

As a general rule, BESTINVER does not use Users’ personal data for direct marketing purposes, unless prior consent has been obtained.

BESTINVER may send you information and other commercial communications relating to services offered by the companies within BESTINVER, without this implying the disclosure of your personal data. At the time your consent is obtained, you will be provided with information regarding the relevant entities within the BESTINVER Group.

BESTINVER may also process your data in order to send commercial information via any channel (email, SMS, push notifications, etc.) relating to products and services marketed by other businesses within the ACCIONA Group, without this implying the disclosure of your personal data. At the time your consent is obtained, you will be provided with information regarding the relevant entities within the ACCIONA Group.

The legal basis for processing the data is the consent of the data subject, granted by ticking the corresponding box below the form through which the data are collected for a specific processing activity.

As a User, you may revoke your consent at any time, unsubscribe from these communications and object to the future processing of your personal data for these purposes by sending an email to bestinver@bestinver.es with the subject line UNSUBSCRIBE, including your full name and address, or by clicking the relevant “unsubscribe” option where included in emails.

– Automated decision-making

BESTINVER does not carry out automated decision-making based on profiling, except in cases where this is expressly indicated and the User’s explicit consent is required.

Fields in forms marked with an asterisk (*) on the Website are mandatory in order to process your request or assess the information you wish to provide.

HOW LONG DOES BESTINVER RETAIN USERS’ PERSONAL DATA?

As a general rule, personal data will be retained for as long as necessary for the purposes for which they were collected, provided that the User does not exercise their rights of erasure and/or cancellation. Additionally, data will be retained in compliance with statutory retention periods as per the applicable regulations in each case.

TO WHOM WILL USERS’ PERSONAL DATA BE DISCLOSED?

Depending on the activity carried out by each of the entities or companies acting as data controllers, the following data disclosures are envisaged:

Service providers, whether these are companies within BESTINVER or third parties, in some cases hired to perform services on our behalf (e.g. IT services, administrative functions, financing, audits, etc.). In such cases, where required, the corresponding data processing agreements are entered into in accordance with data protection law.

Business partners, independent agents, intermediaries or brokers, financial institutions, counterparties and transaction registries with whom we have a relationship, where such disclosure is required to provide services and products or to comply with contractual obligations and execute our operations (e.g., depositary entities, banks, custodians, securities issuers, paying agents, trading platforms, etc.).

Regulatory bodies, public authorities and administrative bodies, private entities, courts and tribunals, law enforcement authorities, third-party fraud prevention entities and trusted service providers.

We may disclose your personal information: (1) where permitted or required by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other public officials in order to comply with a lawful and legitimate request; (3) where we believe it is necessary to prevent physical harm or financial loss; (4) to establish, exercise or defend our legal rights; (5) in connection with the investigation of a suspected or confirmed case of fraud or unlawful activity; or (6) with the User’s express and informed consent.

We reserve the right to transfer to a third party any information we hold about Users in the event of an actual or potential transfer or sale of all or part of our business or assets (including mergers, acquisitions, joint ventures, restructurings, assignments, dissolution or liquidation) or any other corporate or commercial transaction. In such cases, the relevant third parties will be required to guarantee levels of protection comparable to those provided by BESTINVER with respect to the information to be shared.

Web analytics service providers: The Website has enabled Adobe Analytics services provided by Adobe Systems Software Ireland Limited. Interaction with users through the use of this tool may involve the international transfer of personal data to Adobe entities located outside the European Economic Area, such as Adobe Inc. (Adobe USA). In such cases, Adobe relies on Standard Contractual Clauses (SCCs) and, where applicable, adequacy decisions, and has entered into SCCs between its relevant entities to cover such transfers.

Social media platform operators: BESTINVER uses social media platforms to share its content: Interaction with Users through the use of such profiles or tools involves international data transfers of an analytical and technical nature in relation to the Website and social media profiles, as the data provided by Users via those profiles are processed on the servers of the respective social media platforms.

WHAT RIGHTS DO USERS HAVE WHEN THEY PROVIDE US WITH THEIR PERSONAL DATA?

Data subjects may exercise their rights of access, rectification, erasure, portability, and restriction or objection to processing by submitting a request to the Data Controller, either by letter to the BESTINVER Data Protection Department (“Data Protection”, C/ Juan de Mena nº 8, planta 3, 28014 Madrid, Spain) or by email to the following address: protecciondedatos@bestinver.es. Furthermore, data subjects can withdraw their consent at any time by writing to the aforementioned address, as well as by making a claim before the supervisory authority (Spanish Data Protection Agency).

VALIDITY

Any changes made to this Privacy Policy and to the way we handle information will be reflected in a timely manner. BESTINVER may add to, amend, or replace this Policy whenever it deems necessary.

This Privacy Policy is published in Spanish and English. In the event of any discrepancy between the two versions, the Spanish version shall prevail.

Last updated: 1 December 2025