Guatemala Water Infrastructure Company K/S (“GWIC”) is committed to protecting the privacy and integrity of personal data.
As part of its activities, GWIC is required to conduct investor onboarding, identity verification, anti-money laundering checks, counter-terrorist financing controls and other compliance-related procedures. These activities require the collection and processing of personal data relating to prospective investors, existing investors, beneficial owners, representatives and other relevant individuals.
This Privacy Notice describes how GWIC processes personal data in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the Danish Data Protection Act and other applicable laws.
Guatemala Water Infrastructure Company K/S is the data controller responsible for the processing of personal data described in this Privacy Notice.
If you have any questions about this Privacy Notice or how we process your personal data, you may contact us using the details below:
GWIC has not appointed a Data Protection Officer. If you have any questions regarding the processing of your personal data or wish to exercise your rights under applicable data protection laws, please contact us using the details above.
GWIC may process the following categories of personal data in connection with investor onboarding, know-your-customer (KYC) procedures, anti-money laundering (AML) and counter-terrorist financing (CTF) compliance requirements:
This may include your name, previous names or aliases, date and place of birth, nationality, residential address, telephone number, email address, signature and information contained in identification documents, such as passports, identity cards or driving licences. GWIC may also process national identification numbers, including Danish CPR numbers where applicable.
This may include information regarding your tax residence, tax identification number(s) and other information required to comply with applicable legal or regulatory requirements.
This may include information required for KYC and AML/CTF purposes, such as information concerning beneficial ownership, ownership and control structures, authorised representatives, source of wealth, source of funds, business activities, occupation, employer, politically exposed person (PEP) status, and related declarations and supporting documentation.
As a general rule, personal data are collected directly from the individual concerned or from the relevant investor entity.
GWIC processes personal data for the purpose of assessing and onboarding prospective investors and complying with applicable anti-money laundering (AML), counter-terrorist financing (CTF) and know-your-customer (KYC) requirements. This includes verifying the identity of prospective investors, beneficial owners, controlling persons and authorised representatives, obtaining and assessing information relating to beneficial ownership, source of wealth and source of funds, assessing politically exposed person (PEP) status and maintaining records required by law.
Legal obligation: GWIC processes personal data where necessary to comply with a legal obligation to which GWIC is subject. This legal basis is found in Article 6(1)(c) of the GDPR. The legal obligation is laid down in section 10(1) of the Danish Anti-Money Laundering Act.
Investor onboarding and administration: To the extent GWIC processes personal data in order to assess, establish or administer an investment relationship with a natural person investor, such processing may also be based on Article 6(1)(b) of the GDPR, where the processing is necessary in order to take steps prior to entering into a contract or to perform a contract with the investor.
Where GWIC processes personal data about representatives, beneficial owners, controlling persons or other individuals connected to a legal person investor, and such processing is not covered by a legal obligation, GWIC may process the personal data on the basis of Article 6(1)(f) of the GDPR. In such cases, GWIC’s legitimate interest is to establish and administer the investor relationship and to maintain appropriate records of the onboarding and due diligence process.
Data concerning national identification numbers, including Danish CPR numbers, are processed on the basis of section 11(2)(1) of the Danish Data Protection Act.
GWIC may share personal data where necessary to comply with applicable legal and regulatory requirements, including KYC, AML and CTF requirements. In particular, personal data may be shared with GWIC’s banking partners, legal advisers, auditors, competent authorities and, where relevant, GWIC’s Spanish subsidiary qualifying as an Entidad de Tenencia de Valores Extranjeros (ETVE), including for purposes relating to group administration, investor onboarding, compliance, tax structuring, reporting and the management of the investment structure.
Where required by law, GWIC may also disclose personal data to public authorities, including the Danish Financial Intelligence Unit (Hvidvasksekretariatet).
GWIC transfers personal data outside the EU/EEA. In particular, personal data may be shared with entities within the underlying operating group in Guatemala and with Guatemala-based advisers in connection with investor onboarding, compliance and the management of the investment structure.
Where personal data are transferred outside the EU/EEA, including to an underlying group company or other affiliated entity outside the EU/EEA, GWIC will ensure that appropriate safeguards are implemented in accordance with applicable data protection laws. Such safeguards may include an intra-group data transfer agreement incorporating the European Commission’s Standard Contractual Clauses or another valid transfer mechanism under the GDPR.
GWIC retains personal data only for as long as necessary for the purposes described in this Privacy Notice and to comply with applicable legal and regulatory requirements.
Personal data collected for AML, CTF and KYC purposes will generally be retained for a minimum of five years following the end of the relevant business relationship. Under certain circumstances such periods may be shorter or longer, including for the purpose of complying with legal requirements for deletion and storage.
Under applicable data protection laws, you have a number of rights in relation to GWIC’s processing of your personal data. These rights include:
If you wish to exercise any of these rights, please contact GWIC using the contact details set out in section 2 of this Privacy Notice. Please note that the exercise of your rights may be subject to limitations under applicable law.
If you believe that GWIC’s processing of your personal data does not comply with applicable data protection laws, you have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet).
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Denmark
Website: www.datatilsynet.dk
www.guatemalawater.com does not use cookies, tracking pixels, analytics tools or similar technologies. No cookie consent banner is displayed because none is required: the website sets no cookies of any kind.
Information submitted through the website’s contact form (name, organisation, email address, country and message) is transmitted to Investor Relations by email and is used solely to respond to the enquiry, as described in this Privacy Notice.
GWIC may update this Privacy Notice from time to time to reflect changes in applicable law, regulatory requirements or GWIC’s processing activities.
The most recent version of this Privacy Notice will be available on this website and by GWIC upon request.