Basic Information for the Investing Client

 

 

1. wecity Investors’ Nature

 

1.1. CITYPRIVE Investors Network will be integrated by individual Investors, Accredited and Non-Accredited, subject to the criteria set out by Law 5/2015 of 27 April, to promote business financing; both professionals (Business Angels) and amateurs (individuals seeking to diversify their investments based on non-financial alternatives), as well as various institutional investors, VCs (i.e. Venture Capital, i.e. Venture Capital Entities, or other types of institutions or legal entities), Family Offices, Companies and Corporations interested in investing in the real estate sector.

 

1.2. For these purposes, the following shall be considered Accredited Investors, in accordance with all applicable legal provisions:

 

a. Entrepreneurs who, individually, meet at least two of the following conditions:

 

I. All items in their assets must be equal to or higher than 1 million euros.

II. Annual turnover must be equal to or higher than 2 million euros.

III. Own resources must be equal to or higher than 300,000 euros

 

b. Individuals who meet the following conditions (all of them):

 

I. Annual income must exceed 50,000 euros or their financial assets must exceed 100,000 euros.

II. Request to be considered as Accredited Investors in advance, and expressly waive their treatment as a Non-Accredited Investor.

 

c. Individuals or legal entities that can provide proof that they have contracted a financial advisory service on wecity’s financing instruments by an authorised investment services company.

 

1.3. Any Investor who does not comply with the provisions of the previous section shall be considered, for all purposes, as a Non-Accredited Investor, and the additional information obligations of section three of this document shall apply.

 

 

 

 

2. Información general básica a Inversores

 

 

2.1. Without prejudice to the specific information regarding risks contained in section 7 of this document, it is hereby stated that there is a risk of total or partial loss of the invested capital, a risk of not obtaining the expected cash yield and a risk of lack of liquidity when recovering the investment.

Furthermore, because wecity includes the possibility of financing through the issue of shares, it is reported that there is a risk of shareholding dilution, a risk of not receiving dividends and a risk of not being able to influence the management of the company.

Finally, because wecity includes the possibility of financing through the issue of shares, or other equity, it is reported that there is a risk of dilution of the limited liability company, a risk of not receiving dividends, a risk of not being able to influence the management of the company and a risk of restrictions on free transferability.

 

2.2. wecity, as a crowdfunding platform, does not hold the status of an investment services company or a credit institution and it is not a member of any investment guarantee fund or deposit guarantee fund.

 

2.3. Participatory financing projects in wecity are not subject to authorization or supervision by the National Securities Market Commission or the Bank of Spain and, therefore, the information provided by the developers about the projects will not be reviewed said institutions; and in the case of the issuance of securities, it does not constitute a brochure approved by the National Securities Market Commission.

 

2.4. wecity has adopted organisational measures and resources to minimise the risk of fraud and operational risk. Wecity makes all this information available for the Investors, as well as all the measures adopted in sections 12 and 13 of this document.

 

2.5. wecity has adopted the relevant measures to avoid conflicts of interest, which are made available to the Investors in section 9 of this document: “Measures for the prevention, detection and resolution of conflicts of interest” .

 

2.6. wecity has adopted procedures and measures for the submission of complaints and claims by Investors, which may be consulted by accessing section 10 of this document.

 

2.7. wecity has adopted mechanisms to ensure that, in the event of the Platform ending its activity, it will continue to provide all or part of the services to which it has committed in relation to the crowdfunding projects that have obtained funding, and will continue to take responsibility for the consequences the lack of activation of those services may bring for both investors and developers. All this information can be reviewed in section 11 of this document.

 

2.8. wecity is subject to all due legal and financial auditing processes, having appointed as auditors: the company GIMENO AUDITORES, S.L.P. , with registered office at Calle Doce de Octubre 5, 28009 Madrid, Tax Identification Code B-85592343, registered in the Madrid Mercantile Registry and registered in the Official Registry of Accounting Auditors (ROAC) under number S1959.

 

2.9. The fees applicable to Investors and Developers, as well as the contracting procedure and the invoicing method may be consulted in the Particular Conditions and Fees.

 

2.10. Other information about how wecity works, the listing of Projects or the existence of payment intermediaries will be provided in the following sections of this document and may also be consulted in the General Conditions applicable to Equity Financing Services.

 

 

3. Prior legal information for Non-Accredited Investors

 

3.1. This crowdfunding platform does not hold the status of an investment services company or a credit institution and it is not a member of any investment guarantee fund or deposit guarantee fund.

 

3.2. Participatory financing projects are not subject to authorization or supervision by the National Securities Market Commission or the Bank of Spain and, therefore, the information provided by the developers about the projects will not be reviewed said institutions.

 

3.3. In the case of the issuance of securities, it is not subject to authorization or supervision by the National Securities Market Commission and it does not constitute a brochure approved by the National Securities Market Commission.

 

3.4. Without prejudice to the specific information regarding risks contained in section 7 of this document, it is hereby stated that there is a risk of total or partial loss of the invested capital, a risk of not obtaining the expected cash yield and a risk of lack of liquidity when recovering the investment.

 

3.5. Capital invested through the Platform is not guaranteed by the Investment Guarantee Fund or the Deposit Guarantee Fund.

 

 

 

4. Investor registration and verification process

 

4.1. The process

 

The Investor registration process is structured in three stages: Reception Stage, Verification Stage and Investment Stage.

 

4.2. Reception Stage:

 

In the Reception Stage, all activities are entirely automatic.

The Investor will be able to sign up in the Platform using the registration button on the Website. When creating your account with your email and password the System will generate an Investor Profile with a personal and unique ID.

During the registration process, you will be asked to attach a photocopy of your National Identity Card / Tax Identification number (DNI/NIF/Passport) if the Investor is a natural person, or National Identity Card / Corporate Tax Identification number (NIF/CIF/Passport) and public deeds accrediting its incorporation, or a certificate from the competent Commercial Registry, accrediting these aspects as well as others relating to its current status, if the Investor is a legal entity. If the Investor is an Accredited Investor, said status must be justified by attaching a series of mandatory documents specified in Law 5/2015, of 27 April.

 

4.3. Verification Stage:

 

The Verification Stage will begin with the automatic assignment of a Transaction Manager (TM) to each Investor, with whom they will be able to communicate from their profile.

The TM will check that the personal information and documents provided by the Investor are correct. The TM will have to verify your identity by certifying that there are no reports of fraud or suspicious activity linked to your personal data (ID, name and surname, email and telephone number).

The TM will contact the Investor, within a maximum period of 5 days, to inform him/her that all the information provided is correct, or if necessary to request any pending documentation.

In the event that an Investor is considered to be fraudulent, the profile will be blocked in the CRM, leaving the Investor inactive and being added to the list of Blocked Investors.

 

4.4. Investment Stage:

 

Once the transaction and the Investor have been verified, the Investment Stage begins. In those cases in which the Investor intends to invest in any project published in wecity, he/she must open an account in the authorised payment entity, Lemon Way, and make a deposit of funds by bank transfer or credit card.

Once the amount has been deposited, it will be blocked until the project is financed or until it ends due to lack of financing. In the latter case, the amount invested shall remain in the Investor’s account so that it is available for the Investor’s use.

The Investor authorises and grants a mandate in favour of wecity or a third party designated by the latter so that, in accordance with the Financing Agreement signed with the Developer, it may carry out the operational management and issue payment orders against the funds deposited in the electronic wallet opened in the name of the Investor through the payment institution.

 

 

 

5. Type of financing

 

5.1. The purpose of the financing of an investor in a project through wecity shall be to enter into a share capital increase in the company developing the project in order to acquire, with the cash received, a single property – whether or not it is subject to a present or subsequent horizontal division.

 

5.2. Investors may invest in participatory financing projects through:

 

The issue or subscription of debentures, ordinary and preference shares or other securities representing capital, with the Developer being understood as the company issuing the securities.

The issue or subscription of shares in limited liability companies, in which case the developer shall be understood to be the company issuing the shares.

 

5.3. wecity shall not assume or cover the financing of projects that involve financing through loans.

 

5.4. The maximum amount of funds raised per participatory financing project through each of the participatory financing platforms may not exceed 2,000,000 euros, with the possibility of carrying out successive financing rounds that do not exceed the aforementioned amount on an annual basis. When the projects are aimed exclusively at accredited investors, the aforementioned maximum amount may be up to 5,000,000 euros.

 

 

 

6. Risks

 

6.1. General Investment Risks.

 

The main risk associated with any type of investment is the total or partial loss of the money invested, as well as the probability that the return obtained will be less than the expected or estimated one. You must proceed from the idea that the higher the estimated profitability of an investment, the higher the risk associated with it. By previously assessing this issue, you will have taken an important step towards becoming informed about an investment opportunity. In this regard, we strongly recommend that you go through the rest of the information in this document.

 

6.2. Operational risks.

 

Failures or inadequacies in processes, people or systems may have a substantial impact on an investment. This is the operational risk inherent to every activity in the market. In wecity we have the appropriate technical and organizational security measures in place to minimize the operational risk of our activity and, therefore, also the level of risk for the investors and developers who use our platform. In addition, we have our Customer Protection Regulations, which govern the requirements and procedures of our Customer Service Department to duly address all complaints and claims that you may wish to raise, in order to solve them in a legal and effective manner.

 

6.3. Risk of inflation.

 

In a real situation of inflation, with the continued and generalized rise in the prices of products and services in the market, the value loss of money is unavoidable and, therefore, your consumption and purchasing capacity are also reduced. The impact of inflation on any investment is precisely that: the real return on the investment decreases.

 

6.4. Risks associated to the availability of the invested capital

 

Before making any investment you should consider the need for availability of the money you plan to invest; will you need it in the short term? Investing entails the possibility that you may not be able to withdraw the invested money whenever you need it, and you will have to be aware of the estimated term for obtaining liquidity from your investment and obtaining the corresponding yield. For further information, please see our General Conditions applicable to Participatory Financing Services.

 

6.5. Risks associated with investment concentration.

 

We are not going to tell you whether you should concentrate or diversify your investments – that is your decision – but we do want you to understand the basic rule of diversification in finance. Diversifying, as opposed to concentrating, means multiplying and varying. In the investment world, diversification means spreading out investments, spreading them over a variety of projects and options, thus taking smaller risks, as opposed to concentrating investments in a single project, thus taking a higher risk.

 

6.6. Systemic market risks.

 

The real estate market itself, as a specific market, presents a number of systemic risks that you as a real estate investor must be aware of, understand and assume. For example, the evolution of interest rates and credit spreads by financial institutions with regard to the real estate market is a systematic market risk that the investor assumes, with the possibility that changes in rates and spreads may have a negative impact on the value of real estate. Generally speaking, falling rates mean rising yields, and vice versa. Another example of systematic risk in the real estate market is its particular cyclical nature: the real estate market is susceptible to cyclicality, which leads to fluctuations in property values. Previous experience confirms this.

 

6.7. Risks associated with the political, economic, social and regulatory context.

 

Risks associated with the political, economic, social and regulatory context.
Changes of government inevitably occur, so you should not fail to pay attention to the evolution of the economic, political, social and regulatory context in which we operate in the market: national and European legislation reforms, criteria of public administrations, the environment, etc. In short, these are factors that can affect the value of the property, the costs of acquiring it and, ultimately, the return that you as an investor can obtain from it.

 

6.8. Risk of not reaching the financing target.

 

What happens if the financing target is not reached within the deadline established for this purpose? The Spanish Law for the Promotion of Business Financing allows the established deadline to be exceeded by up to 25%, provided that prior to the investment, the possibility and the circumstances giving rise to such an extension are disclosed. Moreover, if even with the extension of the deadline the financing target is not achieved, the amounts deposited by the investors will be returned. In this case, the Law for the Promotion of Business Financing allows the project to receive financing when at least 90% of the target has been reached, after deducting the participation in the project that the Platform itself may have, and provided that prior to the investment, the possibility and the circumstances giving rise to such a decision are disclosed.

 

6.9. Corporate risks when issuing securities.

 

You should always bear in mind the risks and restrictions that your company’s own legal framework entails, as well as any limitations that may have been established in the company’s agreements or bylaws. In addition, if you have acquired securities, it may happen that your shareholding in the financed company will decrease as a result of successive capital increases.

 

6.10. Risk of not receiving dividends or other remuneration inherent to trading companies.

 

The investment does not guarantee that the company financed through the acquisition of shares or participations will obtain dividends or that it will redistribute them among its partners.

 

 

7. Standards of Conduct

In wecity we have set out a series of systematic and codified standards of conduct in our Internal Code of Conduct, in which Investors can find information on the control bodies, general duties, conflicts of interest, communication and information obligations and transaction disclosure

 

 

 

8. Measures for the prevention, identification and settlement of conflicts of interest

 

8.1. Definition

 

Conflicts of interest shall be understood as all those circumstances that constitute or may give rise to a conflict with a potential adverse effect on a client or a group of clients. Conflicts of interest may arise between:

I. The interests of CITYPRIVE or Subject Persons and CITYPRIVE’s obligations to one or more clients; and

II. The interests of two or more CITYPRIVE clients with respect to each other.

 

8.2. Managing conflicts of interest

 

In compliance with Article 62 of the Law on the Promotion of Business Financing, Subject Persons may not:

 

I. Perform activities that may give rise to a conflict of interest, make improper use of confidential information or unduly disclose it, nor

II. Make personalized recommendations to Investors on the projects published on the crowdfunding platform.

 

In particular, CITYPRIVE partners may only advise Investors on the projects published on the platform when they are authorized to provide the financial advisory service referred to in Article 140.g) of Royal Legislative Decree 4/2015 of 23 October, approving the current Consolidated Text of the Securities Market Act, (replacing the previous 63.1.g) of Law 24/1988 of 28 July on the Securities Market) and only if they implement an effective policy on conflicts of interest.

 

Subject Persons must be aware of and comply with the provisions of CITYPRIVE P.F.P., S.L.’s Internal Code of Conduct, the main objectives of which are:

 

I.The prior identification of potential conflicts of interest that may arise in the provision of services to customers by CITYPRIVE, and

II. The implementation of measures to manage such conflicts of interest, in order to avoid any harm to CITYPRIVE clients.

 

8.3. Identification of conflicts of interest

 

To identify conflicts of interest that may arise, we shall take into account whether CITYPRIVE or the Subject Persons:

 

I. May obtain a financial gain or avoid a financial loss, at the expense of the client.

II. Have an interest in the outcome of the service provided to the client or the transaction carried out on its behalf, other than the interest of the client.

III. Are engaged in the same trade or business as the client; and/or

IV. Any other interests exist that could cause potential detriment to a client or group of clients in the Platform.

 

For the purposes described, it will be necessary that the benefit that CITYPRIVE or any of the Subject Persons may obtain leads, (not necessarily simultaneously), to a potential disadvantage for the client; or that the gain to be obtained or the loss to be avoided by a client leads to a lower profit or loss for another client.

 

CITYPRIVE continuously monitors its policies and procedures. In the event that any conflict of interest not specifically contemplated is identified, the Controlling Body will adapt its policies and procedures to ensure its adequate management.

 

8.4. Family, economic or professional affiliation

 

Subject Persons may be affected by potential conflicts of interest by virtue of their family, economic or professional ties or for any other reason, with respect to a specific action, service or transaction. For such purposes:

 

I. Direct or indirect ownership, or ownership through a controlling position, of 34% or more of the voting rights or capital of a company, provided that it is a company that supplies some kind of service or carries out some kind of work for one of wecity’s clients, shall be considered to be an economic relationship.

II. Spouses or individuals with whom they live in an analogous relationship of affectivity, as well as their relatives up to the second degree of consanguinity or affinity, shall be considered as family members with respect to the projects of which they are developers and which are published on the web sites of their respective platforms.

III. Professional relationships refer to any type of relationship for the provision of services or other contractual relationships other than those generated by their positions or jobs in CITYPRIVE; service provision or contractual relationships made by or through the individuals mentioned in the preceding paragraph will be considered as the Subject Person’s own services or contractual relationships.

IV. Other relationships will include those of individuals whose relationship with the Subject Person is such that they have a direct or indirect, significant interest in the outcome of the transaction.

Likewise, any relationships other than those expressed above may be subject to potential conflicts of interest if, in the opinion of an external and impartial observer, they could compromise the impartial performance of any of the Subject Persons. In case of reasonable doubt in this regard, the subject persons should contact the Controlling Body in charge of the Internal Rules of Conduct of CITYPRIVE P.F.P., S.L.,

 

8.5. Reporting potential conflicts to the Controlling Body

 

Subject Persons must inform the Controlling Body of any situation, with respect to a specific action, service or transaction, that may lead to a conflict of interest. Notifications must be submitted as promptly as possible and, in any case, before the decision that could be affected by the possible conflict of interest is made. Subject Persons must keep the above information updated, notifying any modification or termination of the reported situations.

In the event that they were personally affected by a conflict of interest, Subject Persons shall refrain from interfering in the preliminary acts and decide or, where appropriate, cast their vote, in situations related to the object of such conflict arising, and warn of this to those who will make the corresponding decision.

Subject Persons violate their duty of loyalty to CITYPRIVE if they allow or do not disclose the existence of operations carried out by those individuals with whom there is any link that may breach the rules contained in this Internal Code of Conduct CITYPRIVE P.F.P., S.L..

Also, in case of doubt about the existence of a conflict of interest, Subject Persons are required to bring such a case to the attention of the Controlling Body, as well as the specific circumstances of the transaction subject to a potential conflict, for the determination by the Controlling Body of an appropriate action in this regard.

 

8.6. Resolving conflicts of interest

 

Conflicts of interest shall be resolved by the Controlling Body, after meeting and discussing such conflicts with the head of the department where the conflict of interest is located or with the person who directly reports to the Controlling Body, subject to this ICC (Internal Code of Conduct). If it affects several departments, it shall also be settled by the Controlling Body.

The resolution of conflicts of interest shall always be carried out in accordance with the following principles:

I. The obtaining of a financial benefit by CITYPRIVE or the Subject Persons shall not be placed ahead of the clients’ interests;

II. Priority must be given at all times to the legitimate interests of clients, acting with diligence, loyalty, neutrality and discretion; and

III. No client, or category of client or other categories, shall be privileged over another or others.

Should a conflict of interest arise and cannot be properly managed in accordance with the above criteria, the situation giving rise to the conflict of interest shall be avoided, or the general nature or source of the conflict of interest shall be disclosed to clients in a fair, clear and non-deceptive manner before acting on the client’s behalf so that the client can make an informed decision on the Project or investment.

 

8.7. Disclosure of potential conflicts of interest

 

When it is considered that the measures taken are not enough to avoid the risk of a client or group of clients being adversely affected, the client or group of clients must be informed, in a durable medium, of the nature of such conflict and of the other circumstances that will enable them to make a rational decision about the products or services to be hired through wecity.

 

 

9. Settlement of complaints, claims and suggestions

9.1. Initiation of the procedure

 

a. The WECITY complaints and/or claims procedure may be carried out in person or by duly accredited representation by Clients, whether Developers or Investors, by electronic means, provided that they allow the documents to be read, printed and stored, and sent to the following email address: atencionalcliente@wecity.io

 

b. The submitted brief shall contain the following information:

 

I. Identification of the client (National Identity Card/Tax Id. number/Foreigner Id. number/Passport/Certification of the competent Trade Register, name or surnames or company name, and address) or, where appropriate, of the client’s representative (duly accrediting such representation).

 

II. Reason for the complaint or claim, indicating the department or service of “CITYPRIVE P.F.P, S.L.” from which the complaint or claim arises and providing any available documents as evidence.

 

III. Indication of the email address at which the Client wishes to be contacted with the resolution of the complaint or claim. If nothing is specified, the resolution will be sent to the e-mail address from which the complaint or claim was submitted.

 

IV. Statement declaring that the Client is not aware that the subject matter object of the complaint or claim is being addressed through an administrative, arbitration or litigation procedure in court.

 

V. Place, date and signature of the Client, or, if applicable, of the Client’s representative.

 

 

9.2. Deadline for submission

 

a. Clients shall have a period of two years to submit their complaints or claims from the date on which the Client becomes aware of the facts giving rise to said complaint or claim.

 

b. Clients should only submit the complaint or claim once, without requiring its repetition to different bodies in CITYPRIVE.

 

c. Any complaint or claim that is received by the Client Service after the deadline set out in the preceding paragraph, will not be admitted by it for processing and so will be communicated to the client by email in due course.

 

9.3. Filing of complaints or claims to the National Securities Market Commission (CNMV)

 

a. Under no circumstances, the submission of a complaint or claim to CITYPRIVE through the procedures provided herein implies a waiver of the Client’s right to file such complaint or claim to the National Securities Market Commission.

 

b. Clients may only appeal to said supervisory body in the event that CITYPRIVE does not resolve their complaint within the time limit set for this purpose in the following section, or resolving it, do so against them.

 

9.4. Deadline for the resolution of complaints or claims

 

a. Complaints and claims received by the Client Service Department must be settled by said Department within a maximum period of two months, from the moment the written complaint or claim is received together, where appropriate, with the corresponding evidence supporting documents.

 

b. For further information about the requirements and procedures of CITYPRIVE Client Service, we recommend you to read the Regulation for the Defence of the Client of CITYPRIVE P.F.P, SL.

 

 

 

 

10. Mechanisms in the event of termination of wecity’s activity

 

10.1. CITYPRIVE offers a solid administrative and accounting organization as well as adequate internal control procedures and means to ensure the security, confidentiality, reliability and capacity of the service provided through electronic channels.

 

10.2. In the event of termination of its activity, wecity has mechanisms to continue to provide all or part of the services to which it committed for projects that had been financed.

 

The Platform is based on software and hardware systems, so it is possible that at certain times during the provision of the service, access to and use of the website may be interrupted due to force majeure causes such as technical failures or problems and other contingencies beyond wecity’s control. In such circumstances, wecity works to ensure that the services and functions of the website are always available, and will seek to re-establish the service as soon as possible.

In this regard, within the scope of wecity, the following security measures are taken to prevent the loss of information in situations of unavailability of the service due to causes beyond the control of our Platform:

 

– Periodic backup copies of databases and servers.

– Back-up copies of the transactions carried out through the platform, with the intervention of the person responsible for the payment gateway.

 

In the event of permanent termination of wecity’s activity due to reasons such as a court order, legal obligation or any other, the contractual relationship between Investors and wecity will be terminated. In any case, with regard to financing projects and Developers, especially for those whose financing target has been reached, the agreements signed by Investors and Developers shall remain in force, and the relationship between both parties shall be governed by the provisions therein. Since wecity provides an intermediation service through its platform, Investors and Developers will have to agree to set up an inter-party communication system to replace the system that the wecity platform had been providing until the interruption of its activity, and wecity cannot be held liable in any way whatsoever.

 

10.3. wecity works to ensure that the services and functions on the Web Site are always available. However, when you access it, it will be shown to you based on the availability and limitations that apply at any given time.

 

10.4. Despite wecity’s continuous effort to protect the systems and contents included on the Website, to which end it applies the security standards and regulatory compliance inherent to Participatory Financing Platforms, it is not possible to offer full guarantees in relation to any intrusions or loss of information that may occur. Likewise, the absence of viruses or other harmful elements on the Website or on third-party websites that may cause alterations to the User’s computer system, both software and hardware, cannot be guaranteed. Therefore, the Client assumes and understands that there are situations that may be beyond wecity’s control.

 

10.5. Equally, wecity is exempt from any responsibility derived from the misuse by the Clients, as well as for the non-fulfilment of the obligations or commitments assumed by virtue of these conditions or any other applicable ones.

 

 

11. Technical and security measures

 

11.1. All documents that “CITYPRIVE P.F.P., SL” receives through digital media from its users and clients is digitized and automatically stored on the servers of our two infrastructure providers of computer systems: Amazon Inc. through its A.W.S. service. (Amazon Web Services) and Google Inc. through its Google Cloud service.

 

In addition, all information is replicated through backup copies and encrypted by highly secure computer algorithms. Access to this information is restricted to authorised personnel only by means of accreditations and validations known only to those people who have previously agreed to safeguard such information.

 

11.2. All documents that “CITYPRIVE P.F.P., SL” receives physically, on paper or any other material form, will be immediately digitalised by the Department of Information Technology and destroyed within 24 hours, which will guarantee that they are not lost, duplicated or stolen. Once digitalised, information is processed in the same way as the one received directly in a digital form.

 

11.3. wecity has an independent supplier in charge of verifying the sufficiency of the equipment and computer applications and their proper functioning, as well as guaranteeing the security, confidentiality, reliability and capacity of the service provided by electronic means.

 

 

12. Organisational and anti-fraud measures

 

 

12.1. wecity shall adopt the necessary measures to separate the heads of the company from the other commercial or operational services of the organisation, in order to ensure that they make independent decisions regarding the handling of complaints and claims from the Platform’s Clients and to avoid conflicts of interest.

 

12.2. Neither CITYPRIVE nor its administrators, or its directors, under any circumstances may take any sort of retaliation, sanctions, threats or pressure measures on the holder of the Client Service in order to influence, directly or indirectly, in the direction of the decisions made by the Service in the exercise of their duties.

 

12.3. In the Project Management stage, the Transaction Manager (TM) will review the Developer’s personal or private information. The TM will have to verify his/her identity by certifying that there are no reports of fraud or suspicious activity linked to your personal data (National Identity Card/Tax Id. number/Corporate Tax Id. number/Foreigner Id. number, Name and surname of the administrators, and Corporate Tax Id. number/Tax Id.number, company name, email and telephone number of the Developer)

 

12.4. The TM will check that the personal information and documents provided by the Investor are correct. The TM will have to verify your identity by certifying that there are no reports of fraud or suspicious activity linked to your personal data (ID, name and surname, email and telephone number).

 

 

 

13. International data transfers

 

13.1. We use MailChimp and Lemonway, so international transfers of your personal data may take place to the United States and London, respectively.
13.2. MailChimp complies with the Privacy Shield, so your data is protected at a level approved by the European Union. Although, in some cases we may be required by law to share your personal data with third parties and we have limited control over how those third parties protect such data.

 

 

 

 

 

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