Privacy Policy

The purpose of this privacy policy is to provide information regarding the processing of personal data by CITYPRIVE PSFP, S.L.U. (hereinafter, wecity) and to describe the rights of data subjects, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

Identity and contact details of the Data Controller

Owner: CITYPRIVE PSFP, S.L.U.

Tax ID number: B88317003

Telephone: +34 919 49 03 73

It is responsible for the data processing listed below. To contact it, you can use the following channels:

Via email: comunicacion@wecity.com

Purpose of the processing of your personal data

Within the wecity digital platform and media, the collection and processing of users’ personal data will be carried out according to the context and nature, for the following purposes:

• The management of queries and requests for information received through the contact form on the website.

• Investor Registration: To manage the simultaneous registration of investor users on the wecity platform and Lemonway, which includes identification and contact details required to comply with legal obligations relating to investments.
• Contact form for Promoters: To respond to and manage specific requests from promoters interested in offering projects, including the establishment of a contractual or pre-contractual relationship.
• Standard contact form: Manage general enquiries and requests for information submitted by interested users via the forms provided on the website.
• Investment management: Manage and record information relating to investments made by investor users when an investment opportunity arises.
• Complaints form: Process and respond to complaints or claims submitted by users of the platform.

Legal basis for the processing of your data

Consent of the data subject (Art. 6.1.a GDPR): For general enquiries, requests for information, registration of investor users and sending of commercial communications where appropriate.

Performance of a contract or pre-contractual measures (Art. 6.1.b GDPR): Processing of data necessary for the management of investors, promoters, customers and suppliers.

Legitimate interest (Art. 6.1.f GDPR and Art. 19 LOPDGDD): Management of professional contact details and sending of commercial communications to current customers in accordance with Article 21.2 LSSI.

Data retention

In each case of processing, the data will be retained for the duration of the established relationship and, subsequently, for the applicable legal periods and the time necessary to fulfil the purpose for which it was collected and to determine any possible liabilities that may arise from that purpose and from the processing of the data. Only the data necessary for each type of processing is requested. Failure to provide the data in our online forms will mean that we will not be able to respond to your requests.

Recipients

Your personal data may be communicated to Lemonway for the simultaneous registration of investors, as well as to commercial agents if the requested service so requires, to notaries and registries when necessary for the formalisation or registration of documents, to financial institutions or service providers for the proper provision of the service, and to competent public bodies when required by law. Outside of these cases, data will not be transferred unless legally required. For more information, please visit: https://www.lemonway.com/en/terms-and-conditions.

Exercising your rights

We inform you that you may exercise the following rights:

1. Right of access to your personal data to know which data is being processed;
2. Right to rectify any inaccurate personal data;
3. Right to erasure of your personal data, where possible;
4. Right to request the restriction of the processing of your personal data when the accuracy, legality or necessity of the processing of the data is in doubt, in which case we may retain the data for the exercise or defence of claims.
5. Right to object to the processing of your personal data when the legal basis that enables us to process it is legitimate interest. wecity will stop processing your data unless it has a compelling legitimate interest or for the formulation, exercise or defence of claims.
6. Right to the portability of your data when the legal basis that enables us to process it is your consent.

These rights may be exercised free of charge by the data subject, and where applicable, by their representative, by sending a written request to comunicacion@wecity.com

In addition to the above rights, the data subject shall have the right to withdraw the consent given at any time without such withdrawal affecting the lawfulness of the processing prior to the withdrawal. wecity may continue to process the data subject’s data to the extent permitted by applicable law.

wecity reminds the data subject that they have the right to lodge a complaint with the competent Supervisory Authority in the country where they are located.

What security measures do we have in place?

wecity undertakes to comply with its obligation of secrecy regarding personal data and its duty to store it, and will take the necessary measures to prevent its alteration, loss, unauthorised processing or access, in accordance with the provisions of applicable regulations.

wecity has implemented the necessary technical and organisational security measures to guarantee the security of your personal data and prevent its alteration, loss and unauthorised processing and/or access, taking into account the state of technology, the nature of the data stored and the risks to which it is exposed, whether from human action or from the physical or natural environment, in accordance with the provisions of applicable regulations.

Transfer of your data

We inform you that in the event of using third-party providers who process your personal data outside the European Economic Area, an international transfer will take place, which will always be carried out on the basis of an adequacy decision by the Commission, standard data protection clauses, an approved code of conduct or another transfer mechanism provided for by data protection regulations.

Specifically, wecity uses the following provider located in the United States to send communications to its customers: HubSpot, Inc., with registered office at Two Canal Park, Cambridge, MA 02141, USA, which involves international data transfers outside the European Economic Area. Therefore, we recommend that you refer to their privacy policy to find out how they process your personal data.

Confidentiality

Any personal data we may collect through the website or through the various communications we have with you will be treated confidentially, and we undertake to keep it secret in accordance with the provisions of the applicable legislation.

Links to other websites

This website may include hyperlinks to other sites that are not operated or controlled by wecity. Therefore, wecity does not guarantee, nor is it responsible for, the legality, reliability, usefulness, veracity and timeliness of the contents of such websites or their privacy practices. Before providing your personal information to these websites outside of wecity, please note that their compliance with data protection may differ from ours.

Updating the privacy policy

The content of the data protection policy may be subject to change in order to adapt to any legislative changes that may occur, as well as to criteria and positions issued by the supervisory authorities.

In any case, any modification of the Privacy Policy will be duly notified to the Data Subject so that they are informed of the changes made in the processing of their personal data and, if required by applicable regulations, the Data Subject can give their consent.