Privacy Policy
Last updated: January 15, 2026
At Disbursementop S.L. we are committed to protecting the privacy of our users. This Privacy Policy describes how we collect, use and protect your personal information in accordance with the General Data Protection Regulation (GDPR) and the Spanish Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD).
1. Data Controller
Disbursementop S.L., with tax identification number (CIF) B-87654321 and registered office at Calle de Serrano 45, 3rd Floor, 28001 Madrid, Spain, is the controller of your personal data. You may contact our Data Protection Officer at dpd@disbursementop.com.
2. Personal Data Collected
We collect personal data that you voluntarily provide when using our services: full name, email address and any additional information included in the contact form. We also automatically collect technical data such as IP address, browser type and version, operating system, pages visited and session duration.
3. Purposes of Processing
We process your personal data to: manage and respond to enquiries received through the contact form; inform you about our real estate crowdlending services, subject to your consent; comply with legal obligations before the CNMV, the Bank of Spain and the Tax Agency; improve the functionality and user experience of our platform; and prevent fraudulent or unlawful activities.
4. Legal Basis for Processing
The processing of your data is based on: the explicit consent given when completing the contact form; the performance of or pre-contractual measures arising from your interest in our services; compliance with legal obligations in tax, commercial and anti-money laundering matters; and the legitimate interest of Disbursementop S.L. in improving its services and commercial communications.
5. Data Retention Periods
Contact data will be retained for as long as a business relationship exists and, once concluded, for the legally applicable limitation periods (generally between 4 and 10 years under Spanish law). Browsing and cookie data is retained for a maximum of 13 months in accordance with AEPD guidelines.
6. Disclosure of Data to Third Parties
Your personal data will not be disclosed to third parties unless a legal obligation exists. We may share data with processors that provide essential services for our activity (web hosting providers, analytics tools and email services), always under contracts ensuring GDPR compliance.
7. International Transfers
In the event of data transfer outside the European Economic Area, we will apply appropriate safeguards such as standard contractual clauses approved by the European Commission, or verify that the destination country has a valid adequacy decision.
8. Data Subject Rights
You may exercise at any time the rights of access, rectification, erasure, objection, restriction of processing and data portability by writing to privacidad@disbursementop.com, enclosing a copy of an identity document. You also have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you consider that the processing of your data infringes applicable legislation.
9. Security Measures
We have implemented technical and organisational measures to protect your personal data, including TLS encryption for data transmission, role-based access controls, periodic backups, annual security audits and ongoing staff training in data protection.
10. Updates to this Policy
We reserve the right to update this Privacy Policy to adapt it to regulatory, case-law or technical changes. Significant amendments will be communicated through the platform or by email to registered users.