In accordance with Article 10 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce, we hereby inform you that Nauplia Capital S.L., with tax ID B85642841 and registered office at c/Goya 19 Madrid, is responsible for the management and operation of the website naupliacapital.com.
If you wish to contact us, you may do so by post at the address indicated above or by email at mehdi@naupliacapital.com.
Access to our domain may be made directly or via any existing redirection, and this Privacy Policy shall apply in all cases.
This Privacy Policy describes how we process your personal data (e.g., collection, use, disclosure, retention and protection of your personal information) and provides information about your rights as a data subject.
Nauplia Capital (hereinafter, THE OWNER) is the data controller, as well as being responsible for the collection, use, disclosure, retention and protection of your personal data, in accordance with the General Data Protection Regulation, internal rules and policies, and any applicable national legislation.
In compliance with Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD), as well as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, by means of this document, THE OWNER informs you as follows:
Our identification details:
Nauplia Capital, S.L.
You may contact us via:
We process the following categories of personal data:
We collect information about you from the following sources:
For more information about the different data collection mechanisms in the course of our Activity, you may consult our Record of Processing Activities.
Data will be retained for as long as there is a commercial, contractual or professional relationship with the data subject and thereafter for the years necessary to comply with the corresponding legal obligations in each case. Notwithstanding the foregoing, it will be retained for as long as it is necessary for processing and the data subject does not request its erasure.
With regard to employment-related data or data related to social security, documentation or the records or IT media through which the relevant data have been transmitted evidencing compliance with obligations regarding registration, enrolment, deregistration or changes that may occur in relation to such matters, as well as contribution documents and receipts evidencing payment of wages and delegated payment of benefits, pursuant to Article 21 of Royal Legislative Decree 5/2000 of 4 August approving the consolidated text of the Law on Offences and Sanctions in the Social Order, the retention period shall be 4 years.
With regard to accounting and tax documentation, for tax purposes, accounting books and other mandatory record books under the applicable tax regulations (Personal Income Tax, VAT, Corporate Tax, etc.), as well as the documentary evidence supporting the entries recorded in the books (including software and computer files and any other supporting document with tax relevance), must be kept at least for the period during which the Administration has the right to verify and investigate and, consequently, to assess tax debt, pursuant to Articles 66 to 70 of the General Tax Law, which shall be 4 years.
With regard to accounting and tax documentation, for commercial purposes, books, correspondence, documentation and supporting documents relating to your business, duly organised from the last entry made in the books, unless otherwise established by general or special provisions, this commercial obligation extends to both the mandatory books (income, expenses, investment assets and provisions), as well as the documentation and supporting documents on which the entries recorded in the books are based (issued and received invoices, receipts, corrective invoices, bank documents, etc.), pursuant to Article 30 of the Commercial Code, and shall be 6 years.
Data relating to employees’ time records will be retained for 4 years, as established by Royal Decree-Law 8/2019 of 8 March on urgent measures for social protection and to combat job insecurity in working hours.
For more information about data retention in the course of our Activity, you may consult our Record of Processing Activities, section “Erasure period”.
Depending on the purpose of the processing, your personal data may be disclosed or processed by different categories of recipients:
In any case, we disclose your data only to the extent strictly necessary and in the manner required to carry out the purposes described in this privacy policy, and only to entities with which we have signed agreements protecting your rights and freedoms in relation to your personal data. These entities and/or professionals, considered Data Processors, shall be governed by the provisions of Art. 28 of the GDPR, and this entity ensures that they take all necessary security measures in accordance with Art. 32 of this GDPR.
For more information about disclosure of data to third parties in the course of our Activity, you may consult our Record of Processing Activities, section “Category of Recipients”.
In order to carry out our activity and provide our services, we process your personal data in accordance with the conditions set out in this privacy policy within the European Union (EU).
For more information about where we process data in the course of our Activity, you may consult our Record of Processing Activities, section “International Transfer”.
Your data will be collected for processing operations relevant to the following purposes:
For more information about the purposes of data processing in the course of our Activity, you may consult our Record of Processing Activities, section “Purposes of Processing”.
You may withdraw your consent at any time free of charge by exercising your rights, by sending your request in writing and duly identifying yourself by means of an identification document, to our address C/ Travesía de los naranjos, 8- 46004 Valencia or by email to hola@naupliacapital.com. For more detailed information on exercising your rights, you may consult our Record of Processing Activities, section “Exercise of Rights”.
The use of your data under the conditions described above is permitted by European and Spanish data protection regulations in accordance with the following legal bases:
Art. 6 GDPR
For more information about the legal basis for data processing in the course of our Activity, you may consult our Record of Processing Activities, section “Lawful basis for processing”.
Data protection regulations allow you to exercise your rights of access, rectification, objection, erasure (“right to be forgotten”), restriction of processing, portability, and not to be subject to individualised decisions before the Controller.
Any data subject has the right to be provided, BEFORE their data are collected, with basic information at a first level, in summary form, at the same time and through the same means by which their personal data are collected, and, on the other hand, to be provided with the rest of the information through a more appropriate means for its presentation and understanding.
The information to be provided in layers or levels would be as follows:
1st layer information
2nd layer information
(The following table indicates what your rights are).
| Right of access | To know what data about you are being processed, for what purpose, where the data were obtained, and whether they will be or have been disclosed to someone |
| Right to rectification | To amend any of your data that are inaccurate or incomplete |
| Right to cancellation | To cancel data that are inappropriate or excessive |
| Right to object | To prevent your data from being processed or to stop it from being processed, but only in the cases established by law |
| Right to restriction of processing | To request that data processing be suspended in the cases established by law. |
| Right to data portability | To receive the data you have provided in a structured, commonly used electronic format and to transmit it to another Controller. |
| Right not to be subject to individualised decisions | So that a decision is not made about you that produces legal effects or affects you, based solely on the processing of your data. |
These rights are characterised by the following:
If requests are manifestly unfounded or excessive (e.g., repetitive), the controller may:
If you wish to exercise any of the rights described, you may contact us through our Internal Data Protection Officer:
Nauplia Capital, S.L.
Attn. Data Protection Officer
c/Goya 19, 3ºC
28001 Madrid
If you wish to lodge a complaint in relation to the processing of your data by THE OWNER, we inform you that you may contact the Spanish Data Protection Agency, C/ Jorge Juan, 6 28001-Madrid http://www.agpd.es
Cookies are files that are downloaded to your computer to collect standard Internet log information and information about browsing habits. This information is used, for example, to track website visitor usage and compile statistical reports on website activity.
You can set your browser not to accept cookies. However, some first-party cookies are necessary to allow the website user session to use our services.
For more information, please visit the website’s Cookie Policy.
The User certifies that they are over 14 years of age and therefore have the legal capacity necessary to give consent regarding the processing of their personal data, all in accordance with the provisions of this Privacy Policy.
If you wish to use our services through the website and you are 14 years old or younger, we will need the consent of your legal guardian to store your data; if we do not have it, we may proceed to block or delete it.
You may request an up-to-date copy of our Record of Processing Activities via our email address mehdi@naupliacapital.com.
THE OWNER adopts organisational and technical measures in order to guarantee the security of personal data and prevent its alteration, loss, processing or unauthorised access, taking into account the state of the art, the nature of the stored data and the risks to which they are exposed.
We keep our privacy policy under review and may change it from time to time (mainly to comply with legal and data protection practices).
Updated versions will be published on our website.
The terms and conditions governing this website, as well as any relationships that may arise, are protected and subject to Spanish law. For the resolution of any dispute, litigation or discrepancy that may arise between the user and Nauplia Capital S.L. as a result of the use of this website, it is agreed that they shall be submitted to the Courts and Tribunals of Madrid, Spain.