Summary of complaints channel to third parties and distributors

The aFinance Group has drawn up a Code of Ethics which establishes the ethical principles and values to which all members of the Group are committed in the development of all their business activities.

Inform that the Ethical Channel is a confidential means of communication for all members of the aFinance Group and suppliers. In order to ensure the confidentiality of the data and the object of the communication, the documentation will be protected in accordance with the requirements established in Organic Law 3/2018 on the Protection of Personal Data (LOPD).

Our Code of Ethics is a key pillar of our corporate ethics and of the responsible conduct we show towards our teams and suppliers, so you can submit any questions, problems or irregularities related to compliance with our Code of Ethics.

If your notification is a complaint of commercial origin, please contact the following mailbox: [email protected].

On the other hand, if your complaint is related to the Data Protection Act, you can contact the following mailbox: [email protected].

Below, we provide you with a form for the creation of complaints, which you can make, even anonymously if you so wish.

Anonymous complaint

Identified complaint

Name

Last name

Phone

Communication of the reported event

What is your relationship with the AFINANCE GROUP?

When did it happen?

Is it still happening today?

Yes No

Persons involved

Do you have any additional information?

Description of the event

Tests or evidence

Has any official authority (Court, Police, etc.) given prior notice of this communication?

Yes No

To which entity have you communicated it?

Attach files

Select files

I have read and accept the privacy policy

WEB OWNER DATA

COMPANY NAME: AFINANCE FINANCIAL CONSULTING SL
TAX ID: B66481748
POSTAL ADDRESS: PASSEIG DE GRACIA 85, 7TH FLOOR, 08008, BARCELONA
EMAIL ADDRESS: [email protected]
COMMERCIAL REGISTER: Registered in the Mercantile Registry, in volume 37000, page 90, sheet B-294.590, entry 5.
MAIN PURPOSE: Financial intermediation for obtaining mortgage loans without providing advisory services.

In accordance with the current applicable personal data protection regulations, we inform you that your data will be incorporated into the processing system owned by AFINANCE FINANCIAL CONSULTING SL, with Tax ID B66481748 and registered office at PASSEIG DE GRACIA 85, 7TH FLOOR, 08008, BARCELONA, and that their respective purposes, retention periods, and legal bases are listed below. For those processing activities that require it, information on potential profiling and automated decision-making, as well as possible disclosures and international transfers planned by AFINANCE FINANCIAL CONSULTING SL, is also provided:

PROCESSES CARRIED OUT

Web form commercial actions

Purpose: Collection, recording, and processing of data for handling your inquiries and/or requests, as well as advertising and commercial prospecting.
Retention period: Records will be kept as long as consent is maintained, unless legally required otherwise.
Legal basis: Consent of the data subject.
Type of data: Purely identifying data.
Disclosures: None planned.
International transfers: None planned.
Profiling: None planned.

Commercial actions and/or advertising mailings

Purpose: Collection, recording, and processing of data for advertising and commercial prospecting purposes.
Retention period: Records will be kept as long as consent is maintained, unless legally required otherwise.
Legal basis: Consent of the data subject.
Type of data: Purely identifying data.
Disclosures: None planned.
International transfers: None planned.
Profiling: None planned.

Collection and management of potential clients

Purpose: To manage requests for information and the initial contact with individuals interested in financial intermediation services when such contact is made through the website, online forms, social media, instant messaging channels, or other digital means enabled by the entity, as well as, when the data subject has given their consent, to share their contact details with partner companies providing complementary services.
Retention period: Records will be retained for as long as the consent given remains valid, unless a legal obligation requires otherwise.
Legal basis: The data subject’s consent.
Type of data: Identification data only.
Data sharing: Data may be shared with partner companies providing complementary services, only when the data subject has given their consent.
International transfers: Not foreseen.
Profiling: Not foreseen.

Creditworthiness analysis and financial feasibility study

Purpose: To evaluate the economic, asset, and employment solvency of the client to determine the feasibility of a financing operation.
Retention period: Records will be kept for the period strictly necessary to comply with the aforementioned purposes, unless legally required otherwise.
Legal basis: Contract execution and consent of the data subject for the disclosure of data to Permisso.
Type of data: Purely identifying data, financial data, professional data, health data, solvency data, social circumstances.
Disclosures: Data provided by you may be disclosed to Beyond the Scope, S.L. (Permisso), to obtain client asset reports, only when the data subject consents.
International transfers: None planned.
Profiling: None planned.

Intermediation and communication of data to financial institutions

Purpose: To present the client’s financial profile to collaborating financial institutions to obtain financing offers, as well as manage and send the necessary documentation to official appraisers for issuing appraisal reports linked to the financial operation.
Retention period: During the period strictly necessary to comply with the aforementioned purposes, unless legally required otherwise.
Legal basis: Contract execution.
Type of data: Purely identifying data, financial data, professional data, health data, solvency data, social circumstances.
Disclosures: Tax Agency, Banks and Savings Banks, Financial Institutions, and Official or Accredited Appraisers. Legal basis for disclosure: Compliance with the law and execution of the contract.
International transfers: None planned.
Profiling: None planned.

Anti-Money Laundering management

Purpose: Collection, recording, and processing of personal data of clients and potential clients to comply with current Anti-Money Laundering regulations.
Retention period: Data will be kept for 10 years, according to the law.
Legal basis: Compliance with the law.
Type of data: Purely identifying and sensitive data.
Disclosures: Data provided by you may be disclosed to the Tax Agency, Banks, and Savings Banks to fulfill tax obligations established in applicable regulations. Legal basis for disclosure: Compliance with the law.
International transfers: None planned.
Profiling: None planned.

HR management

Purpose: Collection, recording, and processing of candidate data for personnel selection purposes, and for management, analysis, and archiving of candidate resumes.
Retention period: Data will be kept for 1 year, according to the law.
Legal basis: Legitimate interest.
Type of data: Purely identifying data.
Disclosures: Data will be disclosed to SESAME LABS SL for managing job offers.
International transfers: None planned.
Profiling: None planned.

Regulatory compliance management

Purpose: Management and processing of obligations and duties arising from compliance with applicable regulations.
Retention period: Retention of document copies until actions to claim potential liability expire.
Legal basis: Compliance with the law.
Type of data: Purely identifying data.
Disclosures: Data provided by you may be disclosed to competent public authorities for compliance with applicable regulations. Legal basis for disclosure: Legitimate interest.
International transfers: None planned.
Profiling: None planned.

Administrative coordination of notarial signing

Purpose: To administratively coordinate the signing of the mortgage loan between the client and the financial institution once the operation is approved, facilitating scheduling and sending information necessary for preparing the public deed.
Retention period: For the period strictly necessary to comply with the above purposes, unless legally required otherwise.
Legal basis: Contract execution.
Type of data: Purely identifying data.
Disclosures: Data provided by you will be disclosed to Notaries. Legal basis for disclosure: Contract execution.
International transfers: None planned.
Profiling: None planned.

Personal Shopper service management

Purpose: To manage the search and coordination of property visits so that they can serve as collateral for a financial operation.
Retention period: For the period strictly necessary to comply with the above purposes, unless legally required otherwise.
Legal basis: Contract execution.
Type of data: Purely identifying data.
Disclosures: Data provided by you may be disclosed to third parties strictly necessary for proper service provision (e.g., real estate collaborators), as well as to Public Administrations and competent authorities when legally required.
International transfers: None planned.
Profiling: None planned.

Website management

Purpose: Processing and management of data necessary for website functionality.
Retention period: While consent is maintained.
Legal basis: Consent of the data subject.
Type of data: Purely identifying data.
Disclosures: None planned.
International transfers: None planned.
Profiling: None planned.

Whistleblowing channel management

Purpose: To process communications in accordance with Law 2/2023 of February 20, regulating the protection of individuals reporting legal violations and anti-corruption matters.
Retention period: For the time strictly necessary to decide on the initiation of investigations, and in any case deleted from the communication channel after three months, unless retention is needed to provide evidence of the functioning of the prevention model, in which case the data may continue to be processed by the authority responsible for investigating the reported facts.
Legal basis: Compliance with the law.
Type of data: Purely identifying data.
Disclosures: Competent public authorities. Legal basis for disclosure: Compliance with the law.
International transfers: None planned.
Profiling: None planned.

Cookies installation

Purpose: Management and installation of cookies.
Retention period: While consent is maintained.
Legal basis: Consent of the data subject.
Type of data: Purely identifying data.
Disclosures: None.
International transfers: None planned.
Profiling: None planned.

Newsletter

Purpose: Management of newsletter subscription for sending communications.
Retention period: While consent is maintained.
Legal basis: Consent of the data subject.
Type of data: Purely identifying data.
Disclosures: None.
International transfers: None planned.
Profiling: None planned.

Image processing

Purpose: Collection, recording, and processing of images captured via photographs and/or videos produced by the entity, to enhance corporate image and/or promote the entity’s activities on its website and/or social media.
Retention period: While consent is maintained.
Legal basis: Consent of the data subject.
Type of data: Purely identifying data.
Disclosures: None.
International transfers: None planned.
Profiling: None planned.

Video surveillance

Purpose: To ensure the security of facilities, assets, and/or persons.
Retention period: 1 month, in compliance with Article 22.3 of Law 3/2018 of December 5 on Data Protection and Guarantee of Digital Rights.
Legal basis: Public interest.
Type of data: Purely identifying data.
Disclosures: Data may be disclosed to Law Enforcement and Courts to comply with applicable regulations and guarantee security and protection of people. Legal basis: Compliance with the law.
International transfers: None planned.
Profiling: None planned.

DATA MANAGEMENT

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC, AFINANCE FINANCIAL CONSULTING SL informs the User regarding the websites https://www.afinance.es/en/ and derivatives (hereinafter, websites), that the information that may be collected on the websites will be incorporated into the processing systems under the responsibility of AFINANCE FINANCIAL CONSULTING SL PRIME SL, with the purposes of managing and maintaining the relationship with the User regarding the websites, as well as for information, statistical, and marketing activities related to the services and associated activities.

AFINANCE FINANCIAL CONSULTING SL informs that the legal basis supporting the aforementioned processing is the existence of a legitimate interest. Likewise, regarding the installation of cookies, processing is legitimized by the consent given by the data subjects or, where applicable, their legal representatives.

AFINANCE FINANCIAL CONSULTING SL informs that data will be retained while the User’s consent is maintained, except in cases where legal retention is required.
In accordance with the rights conferred by current data protection regulations, the User may contact the competent Supervisory Authority to file a complaint deemed appropriate, as well as exercise the rights of access, rectification, restriction of processing, erasure, portability, and objection regarding the processing of their personal data, as well as withdraw consent previously given for such processing.

In accordance with Article 32 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC, AFINANCE FINANCIAL CONSULTING SL undertakes to adopt the necessary technical and organizational measures, according to the level of risks associated with the processing carried out by it and indicated in the terms and conditions of use, to ensure integrity, confidentiality, and availability. Likewise, AFINANCE FINANCIAL CONSULTING SL informs that if the User enters data in third-party website forms, such third parties will be responsible for the personal data and must adopt the technical measures described in the following section.

RIGHTS OF DATA SUBJECTS

AFINANCE FINANCIAL CONSULTING SL informs Users that they may exercise the rights of access, rectification, restriction, erasure, portability, and objection regarding the processing of their personal data before the Data Controller, as well as withdraw previously given consent.

Right of Access: The right of the user to obtain information about their specific personal data and any processing that has been or is being carried out, as well as information available about the origin of such data and communications made or planned.
Right of Rectification: The right of the data subject to have inaccurate or incomplete data corrected. This can only be satisfied regarding information under the control of the entity, for example, deleting comments published on the website, images, or web content where the user’s personal data appears.
Right to Restrict Processing: The right to limit the purposes of processing originally planned by the data controller.
Right to Erasure: The right to have personal data erased, except as provided by the GDPR or other applicable regulations that determine the mandatory retention of such data, in terms of time and manner.
Right to Portability: The right to receive personal data provided by the user in a structured, commonly used, machine-readable format, and to transmit it to another controller.
Right to Object: The right of the user to prevent the processing of their personal data or to stop such processing by the entity.

To exercise any of the rights described above, the following requirements must be met:

- Submission of a written request by postal mail to Paseo de Gracia, 85, 7th floor, Barcelona (08008) or by email to [email protected].

- The request submitted by the data subject exercising their rights must meet the following legal requirements:

The requester must reliably identify themselves, and if doubts arise about the identity of the requester, they will be asked to correct the request (e.g., by providing additional information such as ID number, ID document, or email address).
A specific description of the request (indicating the information to which access is requested). If no specific file is referenced, all information held with the user’s personal data will be provided. If information from a specific file is requested, only that file’s information will be provided. Requests regarding third-party information will never be provided. Requests by phone will be directed to submit in writing, with instructions and the address to send it to. Information will never be provided by phone.
Address for notifications.
Date and signature of the requester.
Documents supporting the request.
The data subject must use any means that allows proof of sending and receipt of the request.

Finally, you are informed that you have the right to file a complaint with the Spanish Data Protection Agency if you become aware of, or consider, that an event may constitute a breach of the applicable data protection regulations.

AFINANCE FINANCIAL CONSULTING SL undertakes to adopt the necessary technical and organizational measures, according to the level of risks associated with the processing carried out by it and indicated in the terms and conditions of use, to ensure integrity, confidentiality, and availability.

Last updated: March 2026

To follow up an anonymous complaint, you should consult the following address www.afinance.es/en/denuncias, providing only the code generated at the end of the complaint process, so we suggest that you take note of the code generated. On the other hand, in the case of an identified complaint, you can follow up by sending your query to [email protected] indicating your identification details or the complaint code.

Summary of complaints channel to third parties and distributors

Report sent correctly