This Privacy Policy explains how Family Enterprise Partners, S.L. processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights (LOPDGDD)
1. Data Controller
- Corporate Name: Family Enterprise Partners, S.L.
- Registered Address: C/ Recoletos nº 19, 2º Izda., 28001 Madrid
- Tax Identification Number (NIF): B01964402
- Telephone: 912 449 223
- Email: administracion@familyenterprisepartners.com
2. Purposes of Processing
Personal data collected through this website may be processed for the following purposes:
- Responding to inquiries, requests, or incidents.
- Managing relationships with current and prospective clients.
- Sending marketing communications where prior consent has been obtained.
- Distributing newsletters, surveys, and relevant industry information.
- Ensuring the security of the website and preventing fraud or misuse.
- Complying with applicable legal and regulatory obligations.
3. Legal Basis for Processing
The legal bases for processing personal data are:
- The data subject’s consent (Article 6(1)(a) GDPR).
- Compliance with legal obligations (art. 6.1.c RGPD)
- The legitimate interests of the Data Controller (Article 6(1)(f) GDPR), particularly with respect to website security, fraud prevention, and the establishment, exercise, or defense of legal claims.
4. Data Retention
Personal data will be retained for as long as necessary to fulfill the purposes for which it was collected and, thereafter, for the periods required under applicable law, including:
- Spanish Commercial Code: 6 years
- Spanish General Tax Law: 4 years.
- Spanish Civil Code: up to 5 years.
- Spanish Anti-Money Laundering Law (Law 10/2010): 10 years.
Upon expiration of these retention periods, personal data will be securely blocked and retained only where legally required.
5. Anti-Money Laundering Compliance
In accordance with Spanish Law 10/2010 on the Prevention of Money Laundering and Terrorist Financing, personal data may be processed for customer due diligence purposes and disclosed to competent authorities where required by law.
6. International Financial Services and Data Processing
6.1 Services Provided in the United States (RIA – SEC)
In connection with international financial advisory services, certain personal data may be processed by FEP Wealth, LLC, a company organized under the laws of the United States and registered as a Registered Investment Adviser (RIA) with the U.S. Securities and Exchange Commission (SEC). In this context:
- Personal data may be processed in accordance with applicable U.S. laws and regulations.
- Regulatory requirements specific to U.S. investment advisers, including disclosure obligations such as Form ADV, may apply.
- Personal data may be processed for the purpose of providing investment advisory services under the Investment Advisers Act of 1940.
6.2 Services Provided in Spain (Diaphanum – CNMV)
With respect to investment services provided in Spain:
- Family Enterprise Partners collaborates with Diaphanum Valores, S.V., S.A.U., an investment services firm authorized and supervised by the Spanish National Securities Market Commission (CNMV).
- Personal data may be shared with such entity where necessary to provide regulated investment services.
- Such processing shall be carried out in accordance with MiFID II and applicable Spanish financial regulations.
Family Enterprise Partners does not directly provide regulated investment services in Spain unless duly authorized to do so under applicable law.
7. Recipients of Personal Data
Personal data may be disclosed to:
- Administrative, judicial, or regulatory authorities.
- Law enforcement agencies where legally required.
- Service providers and business partners necessary for the provision of services, including Diaphanum Valores, S.V., S.A.U. or FEP Wealth, LLC, where applicable.
8. International Data Transfers
Due to the international nature of certain services:
- Personal data may be transferred to the United States, including to FEP Wealth, LLC.
- Such transfers shall be carried out using appropriate safeguards under the GDPR, including the European Commission’s Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms.
9. Source of Personal Data
Personal data may be obtained from:
- The data subject.
- Publicly available sources.
- Professional databases or authorized third-party providers.
10. Social Media
Family Enterprise Partners maintains a presence on social media platforms, including LinkedIn. The processing of personal data through such platforms is governed by their respective privacy policies.
11. Data Subject Rights
Data subjects may exercise the following rights at any time:
- Right of access.
- Right to rectification.
- Right to erasure.
- Right to restriction of processing
- Right to object.
- Right to data portability.
- Right to withdraw consent at any time.
Requests may be submitted to: administracion@familyenterprisepartners.com
Data subjects also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD) at www.aepd.es.
12. Marketing Communications
In accordance with the Spanish Law on Information Society Services and Electronic Commerce (LSSICE), recipients may unsubscribe from marketing communications at any time by sending an email with the subject line “UNSUBSCRIBE” to: administracion@familyenterprisepartners.com
13. Accuracy of Personal Data
Users represent and warrant that the personal data they provide is accurate, complete, and up to date, and shall be responsible for any damages arising from inaccurate or outdated information.
14. Changes to this Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in applicable laws, regulations, or operational practices. Users are encouraged to review this Policy periodically to remain informed of any updates.
