The information contained in this website (hereinafter, “Website” or “Site”) aims to describe the activities of IRIS Ventures S.G.E.I.C., S.L. (hereinafter, “IRIS” or “IRIS Ventures”), with NIF B05386644, and registered office at Avenida Diagonal, 640, 2F, 08017, Barcelona (Spain).
IRIS reserves the right to update, modify or delete information contained in this Site, as well as the conditions of use, at any time and without prior notice.
The use of this website attributes the condition of user (hereinafter, “User”) and implies acceptance of the conditions of use contained herein.
The Website is for information purposes only. Nothing in the Website should be construed as an offer, invitation or general solicitation to buy or sell any investments or securities, provide investment advisory services, make personal recommendations or to engage in any other transaction, and must not be relied upon in connection with any investment decision.
The User must make correct and diligent use of this Website and the information contained therein, in accordance with the law and with these conditions of use and shall be liable for damages and losses resulting from breaches of this obligation.
IRIS has made its best efforts to ensure that the information contained on this Site is reliable and truthful, and that no relevant information has been omitted to prevent erroneous estimations or estimates. Some information contained herein has been obtained from external sources. IRIS assumes no responsibility for the accuracy of this information.
Given the nature of this Site and the nature of its electronic dissemination through the internet, neither IRIS nor its directors and / or employees are responsible for any loss, cost or damage that may result or be related to the use or the inability to use any material incorporated or transmitted on or through the Site.
No IRIS member will be responsible for any data transmission errors, such as data loss or damage or alteration of any kind, including, without limitation, any direct, indirect or damage that may arise from the use of the information or the services provided on this Site.
The material on this Site is not guaranteed to be free from any type of infection: viruses, trojan horses and / or any other code that could be contaminating or destructive. You are responsible for taking appropriate protection measures in your computer systems, such as anti-virus checks.
This Website is subject to regular update and revision. While we attempt to ensure the correctness and timeliness of all material posted on the Website, we take no responsibility for errors or omissions which are the result of technical causes, or otherwise. We maintain the right to delete or modify in part or in full any information on this Website without prior notice.
You are solely liable for any use you may make of this information. IRIS makes no representation, warranty, condition, undertaking or term either express or implied as to the condition, quality, performance, accuracy, suitability, fitness for purpose, completeness or freedom from viruses of the content contained on the Website or that such content will be accurate, up to date, uninterrupted or error free. Whilst we take every care to ensure that the standard of the Website remains high and to maintain the continuity of it, the internet is not always a stable medium and errors, omissions, interruptions of service and delays may occur at any time for which IRIS accepts no responsibility.
This Site may contain links to other websites over which IRIS has no control or assumes any responsibility, neither for the materials nor for the information included in those websites, nor for any service or product that appears in them.
IRIS, its directors and / or employees exclude any responsibility for damages of any nature that may be due to the content of these other sites.
The contents of this Site (with the exception of references to third party sites) are the sole and exclusive property of IRIS, which has all the reserved rights, which are protected by the applicable intellectual property legislation. IRIS reserves the right to deny or prevent access to this Site to anyone without prior notice.
You may download or print copies of individual pages and / or sections of this Site provided that you do not remove the copyright notices or any other legal notice of IRIS’s ownership rights. The removal or modification of any information or security measures included on the Site is strictly prohibited.
IRIS does not grant the User any license of any kind on their intellectual property rights or on other rights in relation to the contents of this Site.
Therefore, any reproduction (total or partial), transmission (by electronic means or other means), modification, transformation, link or use for any reason of a public or commercial nature, of the Site and its contents is strictly prohibited, without prior permission and in writing by IRIS.
IRIS has adopted technological security measures to protect the information provided by Users from possible misuse, loss or alteration. However, IRIS does not guarantee confidentiality with respect to the communications and information of Users transmitted through this Site. Please do not transmit confidential information to the Site, or through the Site. You must know that the communications transmitted on the Site are public and not private communications.
The simple visit to our Site does not include the obligation to provide information of any kind. Any personal data provided by you through this Site is accurate to the best of your knowledge and you consent to us processing such information for the purpose you have requested – your express consent constitutes the legal grounds for the processing of your personal data. Such personal data provided by you will be used in the form, for the purposes, and with the limitations and rights contained in the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and free movement of such data, the Organic Law 3/2018, of December 5, of Data Protection and digital rights (“LOPD”), as well as any other applicable legislation regarding data protection. We will process such information only for this purpose and IRIS guarantees that the personal data provided will not be accessible by anyone other than IRIS and that will only be shown at the request of its own owner, provided that it is duly accredited. IRIS will not transfer your personal data to third parties (unless IRIS is required by law).
You will have the right to access at any time your data stored in our files, as well as the rectification, removal, opposition, limitation and portability to the processing thereof (hereinafter, “Privacy Rights”). You can exercise your Privacy Rights through the email [ï] or by letter sent to the following address: Avenida Diagonal, 640, 2F, 08017, Barcelona (Spain).
A complaint can be filed to the Spanish Agency for Data protection. Obtain the necessary information at: www.aepd.es.
Access and use of the Site will be subject to Spanish Legislation. If you access the Site from outside Spain, you will be responsible for ensuring compliance with the national laws that are applicable to you in relation to access and / or use of the information contained herein.
IRIS Ventures S.L with NIF B05386644, with registered office at Avenida Diagonal, 640, 2F, 08017, Barcelona (Spain); Registered in the Mercantile Registry of Barcelona, on inscription number 1, tomo 47810, folio 36, hoja 562928
IRIS Ventures S.G.E.I.C., S.L. uses cookies on www.weareiris.com. By using the Service, you consent to the use of cookies.
Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.
Cookies are small text files that the Website you are visiting stores on your computer, phone or other device, with information about the navigation you do on this website. As they provide information to the Website’s owners, they are widely used to ensure correct and efficient functioning of the Website. Among other uses, cookies allow us to store and recover information about your browsing habits and the computer you are using. Based upon the information the cookies contain and the way your computer is being used, they allow the user to be recognized and identified in order to improve your browsing experience and provide the services you have requested. Cookies provide information about the use of a Website. The main purpose of our cookies is to improve your experience on our website. For example, cookies help us to identify you and remember your preferences while you are browsing. The information collected in the cookies also allows us to improve our website by analyzing the routes users use to access our Website.
Types of cookies used by IRIS Ventures S.G.E.I.C., S.L.
The cookies we use on our Website are the following:
● Technical cookies: These are the Website’s own cookies that are essential for the proper functioning of the Website and are stored for technical reasons and for purposes of personalization (they allow the user to access the Website with some general pre-defined characteristics, such as the language selected, they identify the user’s browser connection, control data communication and maintain user safety in navigation), and they also allow use of the various services the Website provides. If the user disables cookies of this type by adjusting the browser settings, it will no longer be possible to continue navigating at the Website.
● Analytical cookies: These are used to compile statistics about the user’s activities. For example, they analyze the number of users visiting the Website, the number of web pages they visit, the activities they perform there, and the frequency of their usage. The information compiled is always anonymous, which means that it is impossible to establish any link between that information and the individual to which it refers. You can always consent to their use, as well as revoke the authorization.
What cookies do we use?
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The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”. Duration: 1 year
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The cookie is set by the GDPR Cookie Consent plugin to store whether or not the user has consented to the use of cookies. It does not store any personal data. Duration: 1 year
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Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Necessary” category . Duration: 1 year
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Set by the GDPR Cookie Consent plugin, this cookie is used to store the user consent for cookies in the category “Performance”. Duration: 1 year
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Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Analytics” category . Duration: 1 year
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Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Advertisement” category . Duration: 1 year
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Set by the GDPR Cookie Consent plugin, this cookie is used to store the user consent for cookies in the category “Others”. Duration: 1 year
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The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. Duration: 2 years
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Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. Duration: 1 day
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Set by Google to distinguish users. Stores unique user ID for statistic purposes. Duration: 1 minute
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This cookie is installed by Google Analytics and it indicates the ID of the account used to visualize the data. Duration: 2 years
Control and management of cookies
At any time you can retract the consent to the installation of cookies that you have given by deleting the cookies through the cookie control panel that you will find on our website, along with the above indications or by installing a rejection system in your web browser.
Depending on the specific browser being used, the procedure for rejecting and deleting cookies will be one of the following:
● Google Chrome: https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop&hl=es
● Firefox: https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-sitios-web-rastrear-preferencias
● Internet Explorer: https://support.microsoft.com/es-es/help/17442/windows-internet-explorer-delete-manage-cookies
● Safari: https://support.apple.com/es-es/guide/safari/sfri11471/mac
The web browsers are the tools in charge of storing the cookies and from this place you must make your right to delete or disable them. This Website cannot guarantee the correct or incorrect handling of cookies by the above-mentioned browsers.
International data transfers
The third-party cookies used on this website belong to Google, located in the United States, outside the European Economic Area. Google has adhered to the E.U.-U.S. Privacy Shield Framework.
Exercises of rights and processing of personal data
The responsible for processing is IRIS Ventures S.G.E.I.C., S.L. with an address at Avenida Diagonal, 640, 2F, 08017, Barcelona (Spain). If you would like further information about how we use cookies, please send an email to rgpd@weareiris.com. You can also find additional information on the processing of your information, in particular on your rights (access, data portability, revocation of consent, rectification, opposition, limitation of processing, deletion) in IRIS Venture’s privacy policy available
Updates and changes to the Cookie Policy
IRIS Ventures S.G.E.I.C., S.L. may modify this Cookie Policy in accordance with new legislative and regulatory requirements or in order to adjust this policy to the instructions issued by the Spanish Data Protection Agency. When significant changes are made to this Cookie Policy, the user will be informed by means of an information notice on the Website.
1. Introduction
Citizen collaboration is a key element in the Spanish Rule of Law, since it is not only manifested in the correct fulfillment of personal obligations, but also in the collective commitment to the proper functioning of public and private institutions. Citizen collaboration is also considered a duty of every citizen when they witness the commission of a crime.Furthermore, in some areas, such as finance or competition protection, specific instruments have been incorporated so that citizens can provide supervisory bodies with useful information about irregular or illegal actions. There are also cases in which civic actions have made it possible to promote investigations that have concluded with the imposition of the corresponding criminal sentence for irregular or corrupt behavior.It is important to highlight that the legal system must protect citizens who report violations of the legal system within the framework of a professional relationship since, at times, these civic behaviors have generated painful consequences for those who have reported such corrupt practices and other violations. Therefore, it is essential to establish awareness in society that those who break the law must be prosecuted and that non-compliance should not be condoned or silenced.
2. Aim
The objective of this policy is to state the general principles of action that govern the internal whistleblower information and defense system (hereinafter, System) defined in IRIS Ventures S.G.E.I.C., S.L. (thereafter, “IRIS Ventures”) and publicize it with the purpose of collaborating in the collective commitment to the proper functioning of public and private institutions.IRIS Ventures guarantees adequate protection to those informants against possible retaliation that they may suffer and strengthens the information culture and integrity infrastructure of the entity and promotes the information culture as a mechanism to prevent and detect threats to the public interest through implementation of this System.
3. Scope
3.1 Material scope of application
The System is applicable to any communication made by an informant that involves an action or omission that may constitute a serious or very serious criminal or administrative offense or that may constitute a breach of European Union Law provided that:
Given the aforementioned, in the event that information is communicated outside of this material scope of application, IRIS Ventures reserves the right to proceed with its investigation, but the informant would not be covered by the protection measures against retaliation.
3.2 Personal scope of application
The System is applicable to informants who have obtained information about an infraction in a work or professional context , including in any case:
It will also apply to informants who communicate information about an infraction obtained within the framework of an employment or statutory relationship that has already ended, interns, workers in training periods regardless of whether or not they receive remuneration, as well as those whose employment relationship has not yet begun, in cases where information about infringements has been obtained during the selection or pre-contractual negotiation process.The protection measures for the informant will also apply, where appropriate, specifically to the legal representatives of the workers in the exercise of their functions of advice and support to the informant and to any natural or legal person to whom the informant provides services , or gets assisted, or who are related to the informant and who may suffer retaliation, such as coworkers or family members of the informant.
4. General principles of action
IRIS Ventures has implemented an internal information system based on the following general principles of action:
5. Management of the internal information system by an external third party.
The management of the internal information system of IRIS Ventures, understood as the reception of information, is outsourced to Informa Consulting Compliance, SL (thereafter, Informa Consulting).Informa Consulting guarantees respect for independence, confidentiality, data protection and the secrecy of communications.Informa Consulting will be considered the data processor for the purposes of personal data protection legislation.
6. Responsible for the internal information system and personnel with access to information
The Board of Directors, as the person most responsible for the implementation of the internal information system, has appointed the Head of Legal, Ms. Eugenia Zozaya, as responsible for the System, who will exercise her position independently of the Board of Directors.The System Manager will be responsible for the diligent processing of the information received through internal channels.Access to personal data contained in the internal training system will be limited, within the scope of its powers and functions, exclusively to:
Having said the above, the processing of data by other people will be lawful, or even its communication to third parties, when it is necessary for the adoption of corrective measures in the entity or the processing of sanctioning or criminal procedures that, where appropriate, may be appropriate.
7. Internal channels for receiving information
IRIS Ventures has two internal channels for receiving information, the main one consisting of an electronic mailbox which is accessible through the public address:http://compliance.informaconsulting.com/FormularioPublico/LadingPage?Token=7458640f-0dd5-458c-8e7a-fd3967f54056 , and another alternative, at the request of the informant, consisting of the possibility of requiring a face-to-face meeting with the System Manager.All personnel not responsible for processing the internal channel are warned that they must maintain due confidentiality in the event that any communication is not sent through the main established internal channel (electronic mailbox), constituting a very serious infraction, and that they must immediately transmit it to the System Manager.
8. Approval and modifications
The content of this Policy is subject to approval by the Board of Directors of IRIS Ventures. Any modification of its content as a consequence of the continuous improvement of the system must be approved.