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Privacy Policy

Our Privacy Policy safeguards your personal data, including its collection, use, protection, and your rights regarding your information.

Bluetree Group's Privacy Policy

Our Privacy Policy was recently updated on February 19, 2024, to align with data protection laws, such as GDPR, and ensure transparency in our data processing procedures. Please review our Privacy Policy thoroughly and reach out to us with any inquiries or issues.

About us and this Privacy Policy

The website www.bluetree.group is owned and managed by Blue Tree AM, S.L. (Bluetree Group).

We acknowledge the significance of privacy to you, and we are dedicated to protecting the privacy of all our visitors. Our Privacy Policy, outlined below, is designed to comply with the European Regulation 2016/679 concerning the safeguarding of personal data and the free movement of such data, while also repealing The Privacy and Electronic Communications (EC Directive) Regulations 2003.

Our aim is to clarify our procedures regarding the collection, safeguarding, disclosure, and utilization of any personal information you share with us or that we gather from you during your website visit. When we refer to "personal data," we mean any details that could be used to identify you. This term is further explained in article 4 of the European Regulation 2016/679, which you can access here. Rest assured, this Privacy Policy does not diminish your legal rights concerning your personal information.

By visiting the website or providing us with information, you are agreeing to our processing of your data in line with our Privacy Policy and Legal Information. If you do not agree with these terms, please refrain from using the website.

1. Who's The Data Controller?

Blue Tree Asset Management, S.L. located at Paseo de la Castellana 135, 12 28046 Madrid, Spain, is responsible for managing the personal data collected from the website www.bluetree.group.

2. What Information Do We Collect And Process From You?

2.1 When you provide us with personal information, including your name, email address, telephone number, and any other details you choose to share, it helps us better serve you. You may be prompted to share this information with us in various interactions, such as:

2.1.1 Reach out to us with any questions or concerns via phone, email, or the contact forms on our website (please note that we may monitor, record, and keep copies of these communications).

2.1.2 register to receive updates from us regarding our company, latest news, and upcoming events, or engage with our marketing communications; and/or


2.1.3 Please notify us of any issues with our website or services.

2.2 Details about you or your device that we automatically gather every time you visit the website:

2.2.1 We collect technical information for our internal records, such as the Internet Protocol (IP) address used to connect your device to the internet, software user-agent, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

2.2.2 This section provides details about your visit, including the complete Uniform Resource Locators (URLs), http responses, clickstream data to, through, and from our website (along with timestamps); location information, communication data, page loading times, download issues, duration of visits on specific pages, user interactions (like scrolling, clicking, and hovering), and navigation methods used to leave the page or to contact us.

2.3 We lawfully receive information from various sources, including business partners, analytics providers, search information providers, and webservers such as Apache or Nginx.

2.4 Kindly be aware that we do not purposely gather sensitive personal information (related to users' physical or mental health, race, ethnic origin, political opinions, religious beliefs, trade union activities, sexual life, or criminal offenses). We will always seek your explicit consent before collecting such data.

3. Do We Collect Data About Children?

We do not intentionally gather information from individuals under the age of 16. If you are under 16, kindly refrain from sharing any personal information with us. If you have already done so, please reach out to us.

4. Which Are The Purposes Of Collecting And Processing Your Data?

4.1 The information provided by you is utilized for the following purposes:

To provide you with the information you have requested from us; we are authorized to utilize your data to fulfill our contractual obligations stemming from your inquiry.

To keep you informed about our business, including quarterly financial updates and relevant news and events, we utilize your data to fulfill our contractual obligations based on your request.

To manage our website and handle internal operations, such as resolving issues, analyzing data, conducting tests, research, and surveys; we have the right to utilize your data for these purposes as it aligns with our legitimate interest in providing information society services through our website.

4.1.4 We are here to address any comments, questions, or feedback you may have about us or our website. It is our legitimate interest to use your data for this purpose in connection with the information society services we provide through our website.

4.1.5 To optimize the presentation of our website content for your browsing experience, we utilize your data as part of our commitment to enhancing the services provided through our website.

4.1.6 To keep you informed about our latest business updates, news, and events that we believe may be of interest to you, we may send you communications via post, telephone, and/or email. We will only send emails if you have given consent, such as opting in when signing up to receive information, or if the information pertains to products and services similar to those you have previously engaged with and have not opted out of receiving marketing messages. If you prefer not to receive such communications, please inform us using the contact details provided at the end of this Privacy Policy. We are committed to using your data for this purpose as it aligns with the legitimate interests of our company as recognized by current legislation. You have the right to object to the further processing of your data for this purpose at any time. For more information, please refer to section 5 "Opting out of marketing" below.

4.1.7 We will notify you of any updates or modifications to our website and/or services as part of our commitment to providing you with the best possible experience.

4.2 We use information about you that we collect automatically:

4.2.1 We use your data to manage our website and handle internal operations, such as troubleshooting, data analysis, testing, research, statistical analysis, and surveys, all in line with our legitimate interest in providing information society services through our website.

To enhance our website and optimize content presentation for a seamless browsing experience on your computer, we utilize your data as part of our commitment to providing top-notch information society services through our website.

We do not make decisions that could impact you solely based on automated data processing.

5. Opting Out Of Marketing

You have the option to request that we do not utilize your personal data for marketing purposes. If you wish to opt-out, please inform us using the contact information provided at the end of this Privacy Policy. Please note that if you choose to opt-out of receiving marketing messages, you may still receive important non-marketing communications from us. This could include notifications about significant changes to our services or website that may impact you, or updates about any agreements we have with you.

6. How Do We Process And Store Your Data?

Your data is securely stored on Microsoft Azure Cloud’s servers, which are situated in the European Economic Area. For more details on their privacy standards, please visit: https://www.microsoft.com/en-us/TrustCenter/Privacy/default.aspx

We do not have to transfer your personal data internationally to countries that do not have regulations equivalent to those in Europe.

7. How Do We Disclose Your Information To Third Parties?

7.1 Our information may be shared with carefully chosen third parties, such as analytics and search engine providers, who help us enhance and optimize the website.

7.2 Our company reserves the right to share your personal information with third parties:

In the event that we engage in the sale or acquisition of any business or assets, we may disclose your personal data to the potential buyer or seller of said business or assets.

7.2.2 In the event that the website is acquired by a third party, any personal data we hold about our customers will be among the transferred assets.

If we are required by law to disclose or share your personal data, or if necessary to enforce our terms and policies, we will do so to protect the rights, property, and safety of ourselves, our customers, and others. This may involve sharing information with companies and organizations for fraud prevention and credit risk mitigation.

7.3 We may share your information with other companies within the Bluetree Group, as listed in the most recent Consolidated Annual Report on our website www.bluetree.group. This is done to ensure that your Bluetree Group investor status is accurately maintained and for internal organizational purposes, such as providing you with the necessary support as an investor of Bluetree Group, in line with the legitimate corporate interests of the company.

If we do disclose any of your personal data to third parties, rest assured that they will be bound by strict confidentiality obligations and other requirements outlined by data protection regulations.

8. International Data Transfers

Because the Bluetree Group operates internationally, your personal data may be transferred to and shared with Bluetree Group entities in offices located outside of the European Union. Rest assured, Bluetree Group ensures that such transfers comply with international data transfer agreements, incorporating the Standard Data Protection Clauses approved by the European Commission. For a copy of the Standard Contractual Clauses applicable to Bluetree Group in the EU, please reach out to our Data Protection Manager.

Bluetree Group does not engage in international transfers of its data to countries that lack regulations equivalent to those in Europe ("Third Countries"). If our entity needs to engage suppliers located in Third Countries for data processing, we ensure that all requirements set by data protection regulations are met, and necessary guarantees and safeguards are implemented to protect your privacy. For more information on guarantees regarding international data transfers, please reach out to our Data Protection Manager.

9. Which Are The Rights You Can Exercise?

You have the right to access, correct, delete, and transfer your data, as well as limit and/or object to its processing. To exercise these rights, please contact us via the postal address or email provided in this Privacy Policy, with "Data Protection" as the subject line of your email.

Please be aware that a fee of EUR 10.00 may be charged to cover costs associated with providing you the requested information. If you wish to receive a copy of this information, please contact us at the provided address. You have the right to withdraw your consent at any time without affecting the legality of processing based on your prior consent.

If you believe that your personal data processing violates regulations, you have the option to file a complaint by contacting the postal address provided in this Privacy Policy or sending an email to info@bluetree.group.

10. How Long Do We Retain Personal Data?

We will securely retain the personal data you provide for as long as you are engaged with us. Even after the end of our relationship, we will adhere to statutory limitation periods relevant to the legitimate processing of your personal information.

After our partnership ends, we will continue to process your data only to ensure compliance with our legal and contractual obligations. Once these periods have passed, we will either delete your data or anonymize it.

11. Update Of This Policy

Kindly be aware that periodic updates to this Privacy Policy may be necessary to align with evolving practices and legal requirements. We encourage you to revisit this page regularly to review the most current version and ensure your satisfaction with any modifications.

12. Security Measures

While we take every possible measure to ensure the security of your data, it's important to note that the internet is not completely secure. There is a slight risk of information interception when sending data electronically. Therefore, we cannot guarantee the absolute security of any data you choose to share with us online. Please be aware that sending such information is done at your own discretion.

13. Links To Third Party Websites

This Privacy Policy solely pertains to this website. Occasionally, we may include links to third-party websites for informative resources or services that we believe may interest you. Please be aware that these external websites have their own privacy policies, and their operators will handle your information in accordance with their policies, not ours. These operators may contact you or allow third parties to contact you for marketing purposes based on their own policies, unless you opt out of such communications. Providing a link does not signify our endorsement or approval of the website's privacy policy or the goods/services offered. We do not bear responsibility or liability for third-party privacy policies, so we strongly recommend reviewing their policies and reputation before sharing your information or engaging in transactions on their websites.

14. Contacting Us

If you have any inquiries or feedback regarding this Privacy Policy, feel free to reach out to us via email at info@bluetree.group. Alternatively, you can send us a letter to Bluetree Group, located at Paseo de la Castellana 135, 12, 28046 Madrid, Spain.