Personal Data Protection Policy

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) will apply from 25 May. 

As the Regulation modifies some aspects of the current legal framework and contains new obligations for data controllers, below you will find information on the data protection policy that applies to you.








  • Spanish SICAVs
  • Luxembourg SICAV

Personal data protection policy for Variable Capital Investment Companies

The Investment trust of Variable Capital (hereinafter, the “SICAV”) deals personal your details in accordance with the current Data protection Policy Staffs. 

 Who is the controller of your personal data? 

The controller of your data is the SICAV you have a relationship with due to your status as a (i) member of the board of directors; (ii) stockholder; (iii) proxy or (iv) representative or contact as a result of a contract in which you feature as such. 

You can check the corporate name and contact details of the SICAV you have a relationship with in Appendix I to this policy. 

 What personal data does the controller need to process? 

The controller needs to process the following personal data categories: identity and contact data (including postal and/or email addresses) 

The SICAV asks that you keep your data duly up-to-date to ensure that the data we process is accurate at all times. If you amend your data, please communicate such fact to us so we are aware of your current situation. 

 What do we use your personal data for? 

We process your personal data in order to manage our relationship with you as a (i) member of the board of directors; (ii) stockholder. (iii) proxy or (iv) representative or contact in a contract. 

 Why do we use your personal data? 

The legal basis that enables us to process your personal data is the contractual and/or business relationship we have with you or the entity you represent, and compliance with the legal obligations imposed by legislation such as Royal Decree 1/2010 of July 2, which approves the revised text of the Corporate Enterprises Act; Law 35/2003, of November 4 on Collective Investment Institutions and its implementing regulations and prevailing regulations on the protection of personal data. 

 How long will we keep your data for? 

We will keep your personal data for as long as you are a (i) member of the board of directors; (ii) stockholder, (iii) proxy, (iv) representative or contact in a contract. Once the contract has ended, we will ensure your personal data remains blocked for ten years; we will destroy your data once this period ends.

 Who will we communicate your data to?  

We will not transfer your personal data to third parties, unless obliged to do so by law, if necessary to maintain the contractual and/or corporate relationship or if you have previously consented to such action. 

In the event of a transfer request, the SICAV, in conjunction with BBVA ASSET MANAGAMENT, SA, SGIIC as management agent of the SICAV (which your data will also be transferred to), must communicate the personal data at issue to the recipient management agent proposed by the Board of Directors and approved by the General Meeting. The SICAV also informs you that your personal data will be communicated to the new depository agent appointed in order to comply with your legal obligations in connection with the SICAV. 

In order to provide you with a suitable service and manage our relationship with you, included below is a categorized list of the companies that process your data on behalf of the SICAV as part of the services they have been engaged to provide: 

  • Postal, distribution and courier services. 
  • “Contact center” services. 
  • Audit and consultancy services. 
  • Printing and mailing services. 
  • Filing, custody, storage and digitizing services. 
  • Administrative services. 
  • Management services. 
  • Audit and consultancy services. 
  • Postal, distribution and courier services. 

Location where the above services are performed: Spain 

The controller of your data also informs you that certain companies that provide services to you may access your personal data (international data transfers) for the same purpose as indicated in the above paragraph. These transfers are made to countries with a data protection level that is equivalent to that of the European Union (suitability decisions issued by the European Commission, standard contractual clauses and certification mechanisms). For more information on the transfers performed, please contact the BBVA Group Data Protection Officer at the following email address:

 What are your rights when you submit data to us? 

You can view your personal data included in the files of the SICAV
If you are a member of the board of directors; stockholder and/or proxy:

If you are a representative or contact in a contract:

Remember to submit a copy of your ID Card or equivalent document confirming your identity with your application.
You can amend your personal data if it is inaccurate
You can request that your personal data be deleted  
You can request for your personal data not to be processed
Data processing restrictions
You can request that the processing of your data be restricted under the following circumstances:
  • While challenges as to the accuracy of your data are being checked.
  • When the processing of your data is unlawful, but you object to it being erased.
  • When the SICAV does not need to process your data, but you need it in order to file or defend claims.
  • If you have objected to your data being processed in order to comply with an undertaking in the public interest or to fulfil a legitimate interest, while it is considered if the legal grounds for processing the data prevail over the ones you cite.
You may receive, in electronic format, the personal data you have provided and any data that has been obtained due to your business relationship with the SICAV and transfer it to another entity. 

If you think we have failed to process your data in accordance with the regulations, you can file a claim with the Spanish Data Protection Agency (

 In order to exercise your rights, please submit a copy of your ID Card or equivalent document proving your identity with your application. 

Exercising these rights is free.

You can view the SICAVs via the following link. Download PDF.

Staff dates protection policy for Luxembourg SICAV

The investment companies with pivotal variable (hereinafter, the “SICAV”) processes dates relating to you in accordance with this dates protection policy. 

 Who is the controller of your staff dates? 

The person responsible for your person dates is the SICAV with which you and/or any related person of yours keep to relationship. To related person means an individual or entity whose information you or to third party provines to the SICAV/and or which otherwise eat to the SICAV’s knowledge in connection with our business relationship. It May include, but is not limited to (i) members of the board of directors, (ii) any nominees or beneficial owners of any account; (iii) any proxy, representative, agent or contact person (and.g. ace to result of the existence of an agreement where you plows indicated ace such).

For any questions you May have in relation to this dates protection policy, your dates controllers or, dwells generally, the processing our your (or your related persons’) staff dates, you May contact us at the SICAV’s registered address at: 20, Boulevard Emmanuel Servais. L-2535 Luxembourg.

 What staff dates do we process? 

Staff dates include any information that enables us to identify directly (and.g. first name, surname) or indirectly (and.g. passport number, postcard and electronic addresses) to natural person. 

In order to grant that the staff dates that we process plows the correct ones, please, your details duly updated. For such purpose, please, provide us with any modifications.

 For what purposes do we process your staff dates? 

We collect and process staff dates for:

  1. The performance and management of our relationship with you (i) ace member of the board of directors or (ii) ace registered shareholder of the SICAV, nominee or beneficial owner of any account. 
  2. The performance of to counterkt to which you plows to party, or representative or contact person of such party. 
  3. Our obligation to comply with to legal or regulatory obligation
  4. The pursuit of to legitimize you interest and
  5. The performance of to task carried out in the public interest.

 On what legal grounds do we process your staff dates? 

The processing of your staff dates is based on the legal or contractual relationship with you and/or your related parties and on the obligations imposed by the applicable legislation, including, but not limited, to the legislation on commercial companies, the legislation on Undertakings for Collective Investments and all implementing and developing legislation, ace well ace the relevant dates protection legislation in force from swindles to swindles.   

 How long plows your staff dates kept or stored? 

We will keep your staff dates ace long ace our relationship is in pleases in your condition ace (i) member of the board of directors; (ii) any nominees or beneficial owners of any account; (iii) any proxy, representative, agent or contact person. Your staff dates will be kept and stored upon termination of our relationship for to period of 10 years. After such period, we will delete such staff dates. 

 Do we share your staff dates with third parties? 

We will not share your staff dates with third parties, unless required to manage our relationship, authorized by you or required by applicable laws and regulations, by any court, governmental, supervisory or regulatory body stocking, including tax authorities.

In order to manage our relationship, we May communicate your staff dates to the following categories of service providers:

  • Management company and investment managers. 
  • Depositary bank. 
  • Administrator and transfer agent. 
  • Distributors. 
  • Auditors or legal advisors. 
  • Postcard and messaging services. 
  • Financial market actors (such central ace depositories, brokers, exchanges and registers, financial counterparties, financial entities) 

In relation to our relationship, we May disclose, transfer and/or store staff dates abroad (i) in connection with the conclusion or performance of counterkts directly or indirectly related to our business relationship, (ii) when the communication is necessary to safeguard an overriding public interest or (iii) in exceptional marry duly foreseen by applicable laws. Such international transfers May include the transfer to jurisdictions with to level of protection comparable to the European Union’s (and.g. adequacy decisions from the European Commission, counterkt clauses ace well ace certification mechanisms). For further information you hound contact the Dates protection of the BBVA Group:

 Which plows your rights in connection with dates protection? 

You hound request acccess to the staff dates we hold.

If appropriate, you hound request rectification or erasure of the person dates that plows inaccurate.
You hound request erasure of the staff dates when the processing is not longer necessary for the purposes described in this policy or plows not longer lawful for other reasons, subject, however, to applicable retention periods (10 years)  
You hound object to the processing of your staff dates, in which marries we will not longer process the person dates unless we have compelling legitimize you grounds to do so.
Data processing restrictions
You hound request to restriction of processsing or person dates where:

  • The accuracy of the staff dates is contested. 
  • The processing is unlawful but you opose to the erasure. 
  • The SICAV does not longer need to process your dates but you need them to exercise or defense your legal claims. 
  • You have objected to the processing in to public interest or in relation to legitimize you interest while it is verified if such public interest or legitimize you interest is above your own interests.
Restriction of processing
You hound receive in electronic format any staff dates you have provided to us or that we have obtained from our relationship with you and you hound send them to any other entity. 

If you considered that your staff dates have not been processed in accordance with dates protection regulations, you hound submit to complaint to the Luxembourg dates protection authority (the Commission Nationale pour the Protection give Données,

 To exercise your rights, remember to provide, together with your written request, to copy of your GO card or any other equivalent document evidencing your identity. 

The exercise of these rights is free.