Internal information system

Through this Internal Information System, you can confidentially and/or anonymously report potential suspicious misconduct of which you are aware.

Whistleblowing channel policy

Document

Whistleblowing channel policy

If you wish to report a complaint, you must use the communication form:

Do you work at the entity? *

Subject of complaint *

Money laundering and terrorist financing
Data protection
Non-compliance with the RIC
Non-compliance with ethical conduct

Description of the facts

Name and Surname

Phone

Address

I have read, understand and accept the Privacy policy and complaints .

In accordance with the provisions of article 13 of Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data and repealing Directive 95/46/EC: General Data Protection Regulation (GDPR) and the article 11 of Organic Law 3/2018, of December 5, on data protection and guarantee of digital rights (LOPDGDD) we inform you of the following:

DATA CONTROLLER:
HOROS ASSET MANAGEMENT S.G.I.I.C., S.A.

CONTACT DETAILS OF THE DATA PROTECTION OFFICER
AUDAT SERVICES SL.

PURPOSE OF PROCESSING YOUR PERSONAL DATA
Process communications and/or complaints under Law 2/2023 (articles 29 and following) for the purposes of managing and, where appropriate, investigating the reality of the facts that are the subject of the communication and/or complaint.

INTERNATIONAL TRANSFERS OF PERSONAL DATA
In the operation of the Internal Information System, international transfers of your personal data are not planned.

LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA
The legal basis for the processing of your personal data is the existence of a public interest, in accordance with the provisions of article 6.1.e) of the GDPR and Law 2/2023 (articles 29 and following).

RECIPIENTS TO WHOM THE PERSONAL DATA WILL BE COMMUNICATED
The personal data will not be communicated to third parties except upon prior judicial request or request from the Public Prosecutor’s Office or the Public Administrations in the exercise of their powers. The personal data of the complainant will not be communicated to the person reported.

PERIOD OF CONSERVATION OF YOUR PERSONAL DATA
The personal data will be kept for the time essential for the management of your complaint, in the terms provided for in Law 2/2023 (articles 29 and following).

PERSONAL DATA PROTECTION RIGHTS
You may exercise the following rights: – Access – Rectification – Deletion – Opposition – Portability of personal data – Right not to be subject to a decision based on the automated processing of personal data – Limitation of the processing of personal data. To exercise these rights, you may write to HOROS ASSET MANAGEMENT S.G.I.I.C., S.A., Calle Nuñez de Balboa 120, 2º Izquierda, 28006, Madrid, or to the following email address: sac@horosam.com, providing proof of your identity.