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PRIVACY POLICY

The website www.caleradv.com (hereinafter, the “Website”) is owned by the company CALER ADVISORY & ASSET MANAGEMENT, S.L. ((hereinafter, “CALER”) having its registered office at General Arrando 1 - 3º 28010 Madrid, Tax ID No. (CIF) B87051462 and registered with the Mercantile Register of Madrid, Volume 32505, Sheet 63, Section 8, Page M585078. In accordance with Organic Law 15/1999, on Personal Data Protection (Protección de Datos de Carácter Personal – LOPD), and its implementing regulations, CALER informs users that the personal data that he/she provides via the Website will be included in a file registered before the Spanish Data Protection Agency (Agencia Española de Protección de Datos) and owned by CALER.

Hence, on providing personal details, the user expressly grants his/her consent for said details to be processed by CALER pursuant to that detailed in this Privacy Policy and for the purposes detailed below. The personal details provided by the user will be processed solely and exclusively in order for CALER to identify the user, resolve enquiries posed, provide its services and send the user, when requested, news and information related to its services.

CALER has adopted the measures and levels of personal data protection required by the LOPD and its regulations and undertakes to respect the confidentiality of this data.

The user may exercise his/her rights to access, correction, cancellation and objection, by written request to the postal address detailed in the first paragraph of this Privacy Policy. Said request, must be accompanied by the name and surnames of the user and a photocopy of his/her National ID and indicate the option required in the body text of the message.

The user must notify CALER of any modification to the details provided and will be liable for the veracity and accuracy of the details provided at all times.

CALER reserves the right to modify this Privacy Policy in accordance with the governing legislation at all times, with effect from the publication date of said modification. CALER recommends that the user regularly review this Privacy Policy in order to be informed of how CALER protects his/her information.

Legal Disclaimer – General Terms of Use

• Ownership of the Website

The website www.caleradv.com (hereinafter, the “Website”) is owned by the company CALER ADVISORY & ASSET MANAGEMENT, S.L. ((hereinafter, “CALER”) having its registered office at General Arrando 1 - 3º 28010 Madrid, Tax ID No. (CIF) B87051462 and registered with the Mercantile Register of Madrid, Volume 32505, Sheet 63, Section 8, Page M585078.

• Access to the Website

Accessing and using this Website implies that the user accepts these General Terms of Use, therefore, if the user is not in agreement with them, he/she should not access the Website.

• Exemption of Liability

• Exemption of Liability for the Contents of the Website:

CALER does not guarantee the timeliness, accuracy and completeness or quality of the information provided. CALER will not be liable for material or immaterial damages, derived from the use of the Website and/or the use or non-use of the information provided by the Website being the sole responsibility of the person that access or uses them. CALER expressly reserves the right to modify, add or delete publications temporarily or forever. CALER is under no obligation to control the use that the user makes of the Website, the Services and the Content. CALER shall not be liable for any losses or damages of any kind that may be due to the user’s use of the content. CALER may, when deem convenient, make corrections, improvements or modifications of the information included in the Website, in the services or in the contents. These changes will not give rise to any right, claim or indemnification to the user and will not imply CALER´s acknowledgement of any responsibility.

• Exemption of liability for the content supplied by the Users:

Any content, file, information, opinion, concept or image posted in the Website contrary the law, morality, bona fide or public order or contains any sort of computer virus or similar software routines will be immediately removed.

CALER will not be liable for the content, files, information, opinions, concepts or images that are not part of the Website content posted by CALER nor are managed by CALER.

CALER will not be liable, directly or indirectly, for the User´s misuse of the Website or its content, being the User, in any event, exclusively liable for the consequences, actions and damages of his/her use of the Website, of the content in it, and of he reproduction or communication of such content.

• Exemption of Liability for the operation of the Website:

CALER continuously provides services and content using all possible means in order to do so satisfactorily. Nonetheless, CALER does not guarantee the availability of the Website. CALER will not be liable for any damages that may arise from the lack of availability or the incorrect operation of the Website. In any event, CALER will perform all necessary acts in order to reestablish the services when there is a technical failure.

CALER does not control in advance, the absence of viruses or elements in the content that could cause alterations to the Software or Hardware of the users that visit the Website; therefore it will not be liable for any losses or damages of any kind that could result from these.

• Exemption from liability for content hosted in the websites accessible from the Website:

CALER will not be liable for any content, file, information, opinion, concept or image shown, published or disclosed, directly and indirectly, through any website interconnected that is accessed through links in the Website, or any of the associated or related services of said interconnected website.

Likewise, CALER will not be liable for the services, goods or products that may be purchased from third parties when accessing through the CALER Website, specially in those cases where the online purchase or contract is performed directly from the third party´s website, even if distinguishing signs or a “frame” with the graphic elements of the website (Branding) appear.

No link, hyperlink, framing or similar will be inserted in the Website unless CALER has previously and expressly granted its authorizations.

• Users Obligations

The user is bound to make reasonable use of the Website and its content, in accordance with the possibilities and purposes for which they were conceived. In particular, the user undertakes to use the Website, as well as its content and services in a suitable and proper manner, in compliance with: (i) the governing legislation at all times; ( (ii) the generally accepted ethical conduct and good practice, (iv) public order (v) that which is detailed in these General Terms of Use.

The user undertakes to use the contents in a diligent, correct and lawful manner. The access and use of the Website and its content for unlawful or illegal purposes is strictly forbidden, and the consequences of this are therefore the exclusive responsibility of the user. In particular, without limitation, the User must refrain from:

• Making use of the Website for purposes against the law, morals and good habits generally considered acceptable to public order.

• Reproducing or copying, disclosing, allowing access from the public by any means of public communication, transforming or modifying any aspect of the website.

• Perform any act that may be deemed a violation of any intellectual property right belonging to CALER or to third parties.

• Using the content and information of any kind obtained through the Website to send ads, communication for direct sales purposes or for any other commercial purpose, unsolicited messages directed at a group of persons regardless of their purpose, also refraining from commercializing or disclosing that information in any manner or form.

• Using false identities or supplanting others when using the Website or any of its services

CALER will not be liable, either directly or indirectly, for the incorrect use of the Website or its content by the user and the user acknowledges and accepts, under his/her exclusive responsibility, the consequences, damages and actions that may occur from accessing or using the Website or the contents hosted there, as well as their reproduction or communication at all times.

CALER will be entitled to interrupt access to the Contents or restrict Users access to the Website at its complete discretion when CALER considers that the user´s behavior is contrary to this General Terms of Use or to any regulation implemented by CALER or its contributors or may interfere with the functioning, good name, credibility and/or reputation of CALER or its contributors.

• Intellectual and Industrial Property

CALER as the author f the collective work comprising the website, is the owner of all of the industrial and intellectual property rights of the Website.

It is forbidden to carry out any form of reproduction, distribution, public broadcast, modification and in general, any form of use of the whole or part of the contents (images, texts, design, indexes, forms, etc.) within the Website, as well as with regard to databases and the software required for the Website to be seen or operated, without the express and prior written authorisation of CALER.

Under no circumstances may the User exploit or make commercial use, directly or indirectly of any of the content (images, texts, designs, indexes, shapes, etc.) that the Website without the prior written permission of CALER is prohibited.

All content that form the Website including but not limited to information, articles, data, texts, logos, icons, designs and images in the Website (“look and feel”), video files, audio files, databases and computer applications are owned by CALER or are used under license of third parties owning the intellectual property rights of those contents. These contents are protected by the current intellectual and industrial property regulations.

All trademarks and logos owned by CALER referred to on this website are registered trademarks owned by CALER.

• Data Protection

CALER, in accordance with Organic Law 15/1999, dated 13 December, on Personal Data Protection (Protección de Datos de Carácter Personal – LODP), and its implementing regulations, guarantees the security and confidentiality of the personal data that the user provides via the Website. CALER will process the personal data pursuant to that set forth in its Privacy and Cookies Policy.

• Changes and Modifications in the General Terms of Use of the Website

CALER will be entitled to unilaterally modify, at any moment, the present General Terms of Use for legal or technical reasons or for changes in the provision of services or in the access to the Website content, as well as to make changes that may derive from the applicable codes of conduct or, where appropriate, from strategic corporate decisions, notifying the Users through the Website.

Additionally, CALER is entitled to change, suspend or delete any part of the Website, such as the access to certain functions, databases or contents in the Website whenever it considers it is necessary and without any obligation to give advance warning. CALER is entitled, as well, to restrict access to all or to certain parts of the Website, notifying the Users through the Website.

CALER shall not in any way be liable for any claim resulting from the actions exposed in the represent clause, so long as the modifications are published in the Website.

• Applicable Law and Jurisdiction

The use of this Website shall be governed by Spanish legislation. Any dispute that arises in relation to its use shall be subject to the non-exclusive jurisdiction of the Spanish courts and tribunals.

COOKIES POLICY

This Cookies Policy forms part of the Privacy Policy of the Website hosted under the domain name www.caleradv.com (the “Website”), which is owned by the company CALER ADVISORY & ASSET MANAGEMENT, S.L. ((hereinafter, “CALER”) having its registered office at General Arrando 1 - 3º 28010 Madrid, Tax ID No. (CIF) B87051462 and registered with the Mercantile Register of Madrid, Volume 32505, Sheet 63, Section 8, Page M585078.

What is a cookie?

A cookie is a small information file that is created by the Website that you visit and that saves information on the User’s computer in order to provide access to the various functions.

Why do we cookies?

The Website uses cookies in order to obtain more information on the way in which visitors to the Website interact with the content. The cookies help CALER s to improve the user experience when they visit the Website by providing them a personalized experience for example.

What information do our cookies provide us?

In particular the Website cookies provide the following information:

  • a) The domain name of the Internet Service Provider (ISP) that provides access to the net. For example, if the users provider is XXX, it will only be identified with the domain xxx.es. This allows CALER to compile statistics on countries and servers that most frequently visit the Website.
  • b) The date and time of access to the Website and the amount of time that each user spends on it. This allows us to determine the hours with the heaviest traffic and make the necessary adjustments to avoid saturation problems at peak hours.
  • c) The internet address of the site linking to our Website. Thanks to this data, CALER can judge the effectiveness of the different banners and links pointing to its server, with the aim of enhancing those that provide the best results, in order to meet the information needs of the visitors.
  • d) The number of daily visitors to each section of content. This allows CALER to determine the most successful areas and expand and improve its content, in order for users to have more satisfying information. The information obtained is completely anonymous and cannot be associated with any specific and identifiable user.
  • e) The language selected by each user on his/her first visit to the Website and the restricted area.
  • f) Security elements involved in controlling access to the restricted areas.
  • g) The user’s activity within the Website: links and places that are clicked on, pages visited, their searches, etc. This allows CALER to improve the functionality of the Website and make it more appealing and useful for the user.

The information that CALER has access to via this cookies, enables the company to customise the Services, based on user’s interests, however, at no point, do the cookies allow CALER to obtain personal information, nor can they read data or other cookies on your computer.

Types of cookies

The Website uses the following types of cookies:

  • Technical Cookies: Allows the user to browse the Website and use the different options and services.
  • Third Party Analytical Cookies (Google Analytics):
    1. Google Analytics: Enable CALER to ascertain the number of users and the length of time spent on the Website and thereby measure and analyse statistics related to the use of the services offered, in order to improve the offer provided to users. The type of information stored includes language, localization (city), the frequency and recurrence of the visits, duration of the visit, browser and operating system, the origin of the visit, etc. CALER uses this information to continuously improve the Website. The __utma cookies, __utmb, __utmc and __utmz that users can see on the configuration of your browser on of Google Analytics. The company which provides these cookies is Google.
    2. Google Adwords: Google Adwords is the tool that allows Google to post adds in its search tool. Google Adwords cookies allow CALER to find out the success of their advertising campaigns by calculating the amount of sales generated by each campaign. The _ar_v4 cookie can be seen in the browser settings is Google Adwords. The provider of these cookies is Google.
    3. Google Adsense: Google Adsense is a tool that allows the websites to show Google´s network advertising banners to users. The provider of these cookies is Google.

The information obtained relates to the number of websites visited, the language, the social network where news are published, the city to which the IP address from which users who access to the Website is linked to, the number of users who visit the website, the frequency and redundancy of the visits, the duration of the visits, the browser used, the carrier and type of device from which the user access to the website, the products and categories which are most visited.

Identification and Customisation Cookies: Allow the user to identify and authenticate himself/herself automatically in future visits to the Website and access the authorised content.

How does one reject cookies?

You have the option to block the use of our cookies on your computer, by selecting the corresponding option in your browser (help function), but by doing so, you will not be able to enjoy the smooth functioning and personalisation of our Services that cookies permit and we also point out that some of the aforementioned functions may not work.