Tórtola Fondivo

ÍNDICE DE CONTENIDOS

  • 1. El alcance
  • 2. Qué datos personales tenemos sobre usted
  • 3. No es necesario revelar información personal
  • 4. Qué datos personales recopilamos
  • 5. Base jurídica y motivos del tratamiento de datos personales
  • 6. Transferencia de datos personales a terceros
  • 7. Cookies y servicios de terceros
  • 8. Conservación de los datos personales
  • 9. Transferencias internacionales
  • 10. Seguridad de los datos personales
  • 11. Hipervínculos a sitios web de terceros
  • 12. Modificaciones de esta Política
  • 13. Tus derechos

Política de Privacidad

Última actualización: 22.06.2026

We (also referred to as "We" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the Tórtola Fondivo website (the "Website").

We want you to make informed decisions about how Personal Data is used and processed. We use various methods and procedures to provide you with relevant information. When specific details are needed, we will share them at the appropriate time. We are glad to answer any questions you may have regarding the limitations imposed by law.

By using our website, you confirm that you have read and accept this Privacy Policy. For inquiries: support@tortolafondivo.com

1. El alcance

1.1 This policy describes the types of Personal Data the Company collects about individuals and how it processes that data, shares it with third parties, secures its processes, and more.

1.2 This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or by combining such information with additional information that we hold or can access.

1.3 The Policy defines «processing» as any operation involving the use or collection of Personal Data, including the management, structuring, and storage of Personal Data.

1.4 Our services are intended for a general audience and are not designed for use by anyone under 18. We do not knowingly seek or collect information from any person under 18, nor do we knowingly permit such individuals to use our services. If we become aware of any such information, we will delete it as soon as possible.

2. Qué datos personales tenemos sobre usted

2.1 Cuando accede al servicio y a los canales, o visita nuestro sitio web, recopilamos Datos Personales. En ciertos casos, podemos solicitarle sus Datos Personales.

2.2 In other cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by receiving your information from our third-party partners.

3. No es necesario revelar información personal

3.1 You are not obligated to provide us with any Personal Data. However, in certain circumstances, withholding Personal Data may prevent us from delivering our Services or granting you access to the website.

4. Qué datos personales recopilamos

4.1 This includes information about your online activity log and traffic data, such as:

  • Dirección IP
  • Fecha de acceso y hora de acceso
  • Idioma utilizado
  • Registros de fallos del software
  • Tipo de navegador utilizado
  • Información sobre el dispositivo que utilizaste

4.2 The information we collect is not private and cannot be used to identify you.

4.3 Personal data we receive from you: any personal data you provide voluntarily when connecting to a third-party online trading platform through Us.

4.4 Personal information you provide specifically to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.

5. Base jurídica y motivos del tratamiento de datos personales

5.1 The company processes your Personal Data for the purposes described in this section and in accordance with the applicable legal basis.

5.2 Without a legal basis, the Company cannot use the Personal Data concerning you. The legal bases that permit the Company to process the Personal Data relating to you are:

  • You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through the Website so that we may transfer it to a third-party trading platform.
  • The Company or a third party may process your personal data to pursue a legitimate interest. For example, this is necessary to improve Our Services or to defend legal claims.
  • El tratamiento debe cumplir una obligación legal.

5.3 Contáctenos por correo electrónico para obtener más información sobre el tratamiento necesario para proteger los intereses legítimos.

5.4 A continuación se detallan los motivos y fundamentos legales por los que podemos utilizar la información que nos proporciona:

Alcance

Fundamento Jurídico

To share your personal data with third parties upon request for access to digital trading
If you request it, we may collect Personal Data in order to forward it to external companies.

You have given consent to the processing of your Personal Data for one or more purposes.

2. To respond to your requests, questions, or concerns
Personal Data is necessary to help resolve any questions you may have about the Services.

We need to process this to serve the legitimate interests of the Company or those of a third party.

3. To meet any legal, administrative, judicial, or regulatory obligation, Personal Data is processed to satisfy applicable legal requirements.

Processing personal data is necessary to meet legal obligations.

4. To improve our Services
we may use Personal Data to enhance our Services. This includes, among other things, the fault or malfunction reports we collect in connection with the Services.

Es necesario tratar los intereses legítimos de la Empresa o los intereses de un tercero.

5. To prevent fraud and the misuse of Our Services.

Es necesario para atender los intereses legítimos de la Empresa o de un tercero.

6. To perform and manage activities required by Our Services
These include internal administrative functions, business development, strategic decision-making, oversight mechanisms, and related processes.

Processing the legitimate interests of the Company or those of a third party is necessary.

7. To perform analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to make decisions on different matters.

Es necesario tratar los intereses legítimos de la Empresa o los intereses de un tercero.

8. To protect our assets, rights, and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests, and assets, or those of third parties, in accordance with any applicable law, regulation, or agreement and any conditions, terms, or policies.

Processing the legitimate interests of the Company or those of a third party is necessary.

6. Transferencia de datos personales a terceros

6.1 The Company may also share Personal Data with third-party service providers, including hosting and storage providers, IP address information, and services that analyze user experience.

6.2 You may also request that we share specific Personal Data relating to you with third-party trading platforms. In such cases, we will provide those third-party platforms with the Personal Data you have given us. The use of your Personal Data is governed by their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with affiliated entities or business partners. This can provide the Company with the resources needed to improve and refine the products and services offered to its clients.

6.4 The Company may disclose Personal Data to regulatory, local, or other official authorities where necessary to protect the rights or assets of third parties.

6.5 We may also share Personal Data about you with prospective investors, buyers, or lenders of the Company or any other group company in the event of such a transaction (including the transfer or sale of assets belonging to the Company or any other group company) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other group business.

7. Cookies y servicios de terceros

7.1 We may use third-party services, such as those that display advertisements on our website or analytics providers. These companies may also use cookies or other technologies.

7.2 Cookies are small text files stored on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services that may interest you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are stored temporarily on your device and remain only for a short period, until you close your browser. Others are persistent cookies. Persistent cookies stay on your device for a set period after you close your browser. They help the Website recognize you as a returning user and allow you to return to the site more easily.

El tipo de cookie

Las cookies son absolutamente necesarias

Alcance

These cookies are required to access the features you have requested and to navigate our website. They are used to deliver the information, products, and services you have asked us to provide.
They are essential for your device to download and transmit data, allowing you to browse the website, use its features, and return to pages you have visited before.

Información adicional

Cookies collect personal data such as your username and the date of your last login to confirm that you have accessed the site. They are deleted once you close your web browser (session cookies).

El tipo de cookie

Cookies de funcionalidad

Alcance

Cookies allow us to recognize you each time you visit our site and to save your preferences.

Información adicional

They remain until their expiration date and are retained even after the browser is closed.

El tipo de cookie

Cookies de rendimiento

Alcance

Cookies help us collect statistical data on site performance and identify areas for improvement. They also enable us to run analytics across our website.

Información adicional

Cookies store anonymous data that is not linked to any identified or identifiable individual. They may be deleted when the browser is closed. Other cookies remain valid indefinitely.

7.4 Blocking or deleting cookies. To prevent or delete cookies, adjust your browser settings. The links below provide guidance on this process for some of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 Sin embargo, tenga en cuenta que, si esto ocurre, algunas o todas las funciones y características del Sitio Web podrían no funcionar como espera.

Online Tracking Notice: This service does not currently respond to Do Not Track signals.

8. Conservación de los datos personales

8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for an additional 12 months.

8.3 We periodically review the Personal Data we hold to ensure it is still necessary.

9. Transferencias internacionales

9.1 Your personal data may be transferred to other countries, including to a third country or to international organizations. The Company takes all necessary measures to protect the personal data you provide and to ensure that data subjects can exercise their rights and access effective legal remedies.

These protections and safeguards are available to all residents of the EEA (European Economic Area):

  • Transfer to a third country or an international organisation that the European Commission has determined provides an adequate level of protection for the Personal Data transferred, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
  • The transfer is made under a legally binding and enforceable agreement between public bodies or authorities, within the meaning of Article 46(2)(a)
  • The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR.

9.3 The Company can provide details of the safeguards it applies when transferring your Personal Data to third countries or international organizations. Please email: support@tortolafondivo.com

10. Seguridad de los datos personales

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee that the security of your Personal Data will remain free from errors. Nor can we be held liable for intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, any Personal Data disclosed due to transmission errors, unauthorized access by a third party, or any other cause beyond our control.

10.3 Legal or other obligations beyond our control may require us to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control how those third parties safeguard your Personal Data.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you transmit to us online.

11. Hipervínculos a sitios web de terceros

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's control. We are not responsible for how they collect or process Personal Data, and this Policy does not apply to any actions carried out through them.

11.2 Before accessing any third-party websites or applications, we recommend that you read their privacy policies before deciding to use them, particularly before providing them with any Personal Data.

12. Modificaciones de esta Política

12.1 We may update this Policy at any time. When we do, we will notify you of the changes by publishing the updated version on our website.

12.2 Cuando realicemos modificaciones significativas en esta Política, se lo notificaremos por los medios que consideremos adecuados y publicaremos un aviso en nuestro sitio web.

12.3 Unless expressly stated otherwise, any changes take effect once the revised Policy is published.

13. Tus derechos

13.1 You have the right to ask us to verify the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer need. You may also restrict the scope of how your personal information is processed.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide about your Personal Data. To exercise the rights available to you, send an email to the address indicated below.

13.3 Right of access The Company may verify the accuracy of the Personal Data being processed about you. Where such data exists, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If requested, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If the request harms the rights and freedoms of another person or your own rights, the Company may refuse the request or limit its ability to fulfil it.

13.4 Right to rectification The Company has the right to rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, taking into account the purpose of the processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data concerning you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data have been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or the law of a member state; or (b) to establish, exercise, or defend legal claims.

13.6 Restrictions on processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, your Personal Data may only be retained with your consent, to establish, exercise, or defend legal claims, to protect the rights of another natural person, or where there is a significant public interest reason within the European Union or a Member State.

13.7 Right to data portability Where processing is carried out by automated means and is based on consent or on a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company. You have the right to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not adversely affect the rights and freedoms of third parties.

13.8 Right to object You have the right to object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or by a third party. This includes profiling based solely on such legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing of Personal Data, we may continue to do so unless you can show that your rights, freedoms, or interests override those grounds, or that the processing is necessary for the exercise, establishment, or defense of legal claims. In relation to direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.

13.9 Right to withdraw consent You may withdraw the consent you have given us to process your Personal Data at any time. This does not affect the lawfulness of any processing based on your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may file an appeal with a supervisory authority established by a Member State to protect the fundamental rights of natural persons in relation to the processing of Personal Data within the European Union. The laws of the European Union and its Member States may limit your rights regarding the Personal Data that concerns you, as detailed in this section 13.

13.10 We will provide the information you request under the rights set out in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature of the request and the number of requests received. Within one month of receiving your request, we will notify you of any extension, together with the reasons for it.

13.11 Provided it does not conflict with Article 13 of the law, any information you request when exercising your rights under Article 13 will be provided free of charge. If a request is unfounded or excessive, particularly where requests are repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask the requester to provide reasonable means of identification.

This Privacy Policy should be read together with our Condiciones de uso and Divulgación de riesgos.

Tórtola Fondivo 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@tortolafondivo.com