Privacy Policy

Last updated: 20 April 2026

In accordance with the principles of legality, loyalty, and transparency, we provide you with this Privacy Policy.

Who is responsible for processing your data?

RESPONSIBLE PARTY: Butterfly Investment Management, S.L.
VAT NUMBER: B16354607
REGISTERED OFFICE: C/ Calendula 95, Building 0-1st Floor Office 7 / 28109 / Madrid / Alcobendas
CONTACT: EMAIL - info@investbutterfly.com | PHONE - 910070985

For what purpose do we process your personal data?

At Butterfly Investment Management, S.L., depending on the category of the data subject, we process the information you provide for the following purposes:

POTENTIAL CLIENTS: Manage potential commercial and/or professional relationships, send requested information and/or respond to inquiries, provide offers of our services and/or products of interest.
CLIENTS: Manage commercial and/or professional relationships, provide offers of our services and/or products of interest.
SUPPLIERS: Manage commercial and/or professional relationships.
CANDIDATES: Manage the personnel selection process.
WEB USERS: Manage the analysis of your browsing data.

What is the legal basis for processing your data?

The legal basis for processing your personal data, depending on the category of data subject, may be:

POTENTIAL CLIENTS:

Art. 6.1.b GDPR: application, at the request of the data subject, of pre-contractual measures (quotes, engagement letters, service offers...).
Art. 6.1.f GDPR: Legitimate interest (sending requested information, responding to inquiries...).
Art. 6.1.a GDPR: consent of the data subject (providing offers of our services and/or products).

OTHER CATEGORIES:

CLIENTS: Art. 6.1.b GDPR: execution of a contract to which the data subject is a party.
SUPPLIERS: Art. 6.1.b GDPR: execution of a contract to which the data subject is a party.
CANDIDATES: Art. 6.1.a GDPR: consent of the data subject.
WEB USERS: Art. 6.1.a GDPR: consent of the data subject.

The data we request are adequate, relevant, and strictly necessary, and you are not obliged to provide them; however, failure to do so may affect the purpose of the service or make it impossible to provide.

How long will we keep your personal data?

Your data will be kept for the minimum time necessary to properly provide the service offered and to meet any responsibilities arising from it or any other legal requirement.

To whom will your data be disclosed?

Butterfly Investment Management, S.L., to properly provide services, may disclose your data to:

Notaries.

Additionally, we inform you that certain data, under current regulations or the contractual relationship with Butterfly Investment Management, S.L., may be disclosed to:

Banks and financial institutions for payment of contracted services and/or purchased products.
Public administrations competent in the sectors of Butterfly Investment Management, S.L.'s activity, when required by current regulations.

Are international data transfers carried out?

Data may be transferred to Microsoft INC. for cloud services. However, to guarantee data security and confidentiality, appropriate measures have been adopted through the Adequacy Decision. You may request these measures via email at info@investbutterfly.com.

What are your rights when you provide us with your data?

The data protection rights that data subjects may exercise, when applicable, are:

Right to request access to personal data concerning the data subject.
Right to rectification or deletion.
Right to object.
Right to request restriction of processing.
Right to data portability.
Right not to be subject to decisions based solely on automated data processing.

Data subjects may exercise their data protection rights by sending a written communication to Butterfly Investment Management, S.L.'s registered office or to the designated email, info@investbutterfly.com. Models, forms, and more information about your rights are available on the website of the national supervisory authority, the Spanish Data Protection Agency (AEPD), www.aepd.es.

Can I withdraw my consent?

You have the possibility and the right to withdraw consent for any specific purpose previously granted, without affecting the lawfulness of processing based on consent before its withdrawal.

Where can I file a complaint if I believe my data is not being handled correctly?

If any data subject believes their data is not being properly processed by Butterfly Investment Management, S.L. or that requests to exercise rights have not been satisfactorily addressed, they may file a complaint with the relevant data protection authority, with the AEPD being the competent authority nationally, www.aepd.es.

Security and updating of your personal data

To safeguard the security of your personal data, we inform you that all necessary technical and organizational measures have been adopted to ensure the security of the personal data provided. This is to prevent alteration, loss, and/or unauthorized processing or access, as required by regulations, although absolute security does not exist. It is important that you inform us of any changes to keep your personal data updated.

Confidentiality

Butterfly Investment Management, S.L. informs you that your data will be treated with the utmost care and confidentiality by all personnel involved in any phase of processing. We will not disclose or communicate your data to any third party except in cases legally provided for or if you have expressly authorized us.