Data controller
GARNET MANAGEMENT S.L., NIF B-06852073, with registered office at Paseo de Gracia 101, principal 2º, 08008 Barcelona, Spain, is the controller of the personal data collected through this website. You can contact us at [email protected].
What data we collect
We collect only the data you choose to give us through the contact form on this website: your name, email address and, if you provide them, your telephone number, company name, country and the content of your message.
We also process limited technical data that your browser sends automatically when you visit — such as your IP address, browser type and the pages you view — together with the cookies described in our Cookies policy.
Why we process it, and on what basis
To answer your enquiry. When you submit the contact form, we use your details to reply and, where relevant, to prepare an indicative valuation or recovery proposal. The legal basis is your consent, and the steps taken at your request prior to entering into a contract.
To operate and secure the website. We process technical data to deliver the site, remember your language preference and protect against abuse and automated submissions. The legal basis is our legitimate interest in running a secure website.
Analytics and advertising cookies are set only if you enable them in the cookie settings. The legal basis is your consent, which you may withdraw at any time.
Who receives your data
Enquiries submitted through the form are delivered by email to the Garnet team responsible for the market you select, and may be shared with Garnet group companies in that market in order to answer you. We also rely on service providers who process data on our behalf — our email provider and our hosting provider — under written data-processing agreements.
Where a recipient is located outside the European Economic Area, transfers are made under the safeguards permitted by Chapter V of the GDPR. [Confirm the specific mechanism and the group entities involved.]
We do not sell your personal data.
Spam protection
The contact form is protected by reCAPTCHA Enterprise, a service of Google Ireland Limited. To distinguish human submissions from automated ones, reCAPTCHA collects information about your device and your interaction with the page — including your IP address, browser and operating system data, and mouse and keyboard behaviour — and transmits it to Google for analysis. Google acts as an independent controller for that data; its processing is governed by the Google Privacy Policy and Terms of Service.
We rely on our legitimate interest in preventing abuse of the form (Article 6(1)(f) GDPR). [Several supervisory authorities take the view that reCAPTCHA requires prior consent rather than legitimate interest — confirm which basis Garnet relies on, and whether the form should be gated behind the cookie banner in the EU.]
How long we keep it
We keep contact-form correspondence for as long as needed to deal with your enquiry and, thereafter, for the period required to defend against possible claims. [Confirm the retention period Garnet applies.]
Your rights
You have the right to access your personal data; to have inaccurate data corrected; to have your data erased; to restrict or object to processing; and to receive your data in a portable format. Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out beforehand.
To exercise these rights, write to [email protected], stating which right you wish to exercise. If you believe your data has been handled improperly, you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es) or the supervisory authority in your country of residence.
Debtor data
Where Garnet processes personal data of debtors in the course of acquiring or servicing loan portfolios, it does so as controller or processor under the terms agreed with the originating creditor, and under the applicable national debt-collection and data-protection rules. That processing is not carried out through this website. [Confirm wording and, if a separate debtor privacy notice exists, link it here.]
Changes to this policy
We may update this policy to reflect changes in our practices or in the law. The version published on this page is the one in force.