Legal Information

Version dated 25th May 2026. This version replaces all previous versions of the Dato Capital legal information.

1. Overview

The Dato Capital websites are owned by DATO CAPITAL LTD (United Kingdom) and operated under the "Dato Capital" brand on behalf of NETAMO SYSTEMS SL (Spain), which is the data controller within the meaning of Article 4(7) of Regulation (EU) 2016/679 (the "GDPR") for the processing of personal data carried out through these websites. Full identification details of both companies are available in the About Us page and in the Privacy Policy.

This page provides per-country information on the public registers and other official sources from which the data published on the websites is derived, the legal framework that makes that information publicly available, and the data protection laws under which the processing is carried out. The full Privacy Policy and the rights of data subjects apply to all of the jurisdictions listed below.

2. General framework

2.1 Data relating to legal entities is not personal data

As confirmed by Recital 14 of Regulation (EU) 2016/679 (GDPR), the GDPR "does not cover the processing of personal data which concerns legal persons and in particular undertakings established as legal persons, including the name and the form of the legal person and the contact details of the legal person". The European Commission has restated this position in its public guidance on the application of data-protection law to data about a company (available at commission.europa.eu).

Accordingly, data published on the websites that concerns a legal entity as such — including the company name, registered legal form, registration number, registered office, share capital, articles of association, annual accounts and similar corporate information — does not constitute personal data and falls outside the scope of the GDPR. Rights under the GDPR (including the right of erasure) cannot be exercised in respect of this category of information.

2.2 Data relating to natural persons

By contrast, information that identifies or relates to a natural person — including the names and corporate functions of directors, managers, members of supervisory or management boards, shareholders where disclosed, beneficial owners, persons with significant control, statutory auditors and equivalent — constitutes personal data within the meaning of Article 4(1) GDPR and is processed by NETAMO SYSTEMS SL in accordance with the GDPR.

Limited cases may arise in which information formally attached to a legal entity also identifies a natural person — for example, where a sole-trader business operates under the natural person's own name, or where a registered office disclosed in the source register corresponds to a private residence. In such cases, the information identifying the natural person is treated as personal data and is subject to the GDPR. The legal-entity information itself remains outside the scope of the GDPR. NETAMO SYSTEMS SL examines such cases on the individual circumstances of each request.

2.3 Applicable law

NETAMO SYSTEMS SL, as the controller established in Spain, processes personal data of natural persons appearing on the websites in accordance with the GDPR and with Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights, under the lead supervision of the Spanish Agencia Española de Protección de Datos (AEPD).

The fact that personal data are sourced from a public register does not exempt the controller from compliance with the GDPR. As confirmed by the Court of Justice of the European Union in Camera di Commercio di Lecce v Manni (judgment of 9 March 2017, C-398/15), data subjects retain the rights conferred by the GDPR in respect of personal data published in business registers. Such requests are examined on a case-by-case basis through a balancing of interests, as further described in the Privacy Policy.

In addition to the GDPR, the data protection laws of the jurisdictions from which the data are sourced may apply extraterritorially to the processing of personal data of residents of those jurisdictions. NETAMO SYSTEMS SL acknowledges this and addresses requests from residents of those jurisdictions through the same channel as GDPR requests (see section 4 below).

2.4 Legal basis and purpose of the processing

Across all jurisdictions, the legal basis on which the controller relies for the processing of personal data of natural persons appearing on the websites is Article 6(1)(f) GDPR (legitimate interest), or its equivalent in the applicable local law.

The legitimate interests pursued are of a public-interest character and include, in particular:

• Supporting transparency in commercial transactions, in line with the purpose of the public business registers from which the data are sourced;
• Enabling clients (including financial institutions, tax authorities, government bodies, law firms, journalists, compliance professionals and counterparties) to comply with their statutory obligations under anti-money-laundering, counter-terrorist-financing and know-your-customer legislation, in particular Directive (EU) 2015/849 and equivalent national legislation;
• Contributing to the prevention and detection of fraud, identity misuse, illegitimate concealment of beneficial ownership, and other abuses that would be facilitated by the selective removal of officer information from accessible business databases;
• Facilitating access to corporate information that is, by design of the relevant legal framework, intended to be publicly available.

2.5 Exceptions to the right of erasure

Article 17(3) GDPR provides that the right of erasure does not apply to the extent that processing is necessary, in particular, for compliance with a legal obligation to which the controller is subject, for reasons of public interest, or for the establishment, exercise or defence of legal claims. Where the processing of personal data of a corporate officer is necessary to give effect to the purposes described in section 2.4 above, NETAMO SYSTEMS SL may rely on Article 17(3) GDPR to decline an erasure request, in whole or in part. Any such decision is taken on a case-by-case basis, is communicated in writing to the data subject together with the reasons, and remains subject to the right of the data subject to lodge a complaint with a supervisory authority and to seek a judicial remedy.

Equivalent provisions in the applicable local data protection laws are applied in the same manner.

3. Jurisdictions covered

Spain (ES)

United Kingdom (UK)

The Netherlands (NL)

Luxembourg (LU)

Malta (MT)

Gibraltar (GI)

Panama (PA)

Cayman Islands (KY)

British Virgin Islands (VG)

Bermuda (BM)

Costa Rica (CR)

Curaçao (CW)

Venezuela (VE)

Mexico (MX)

4. Exercise of rights

Regardless of which jurisdiction's data protection law applies, data subjects may exercise their rights — in particular the rights of access, rectification, erasure, restriction, objection and (where applicable) data portability and withdrawal of consent — by addressing the data controller:

NETAMO SYSTEMS SL
Calle Zurbano 45, 1ª planta, 28010 Madrid, Spain
Email: privacy@netamo.com

NETAMO SYSTEMS SL will respond within one month from receipt of the request, in accordance with Article 12(3) GDPR. Equivalent or shorter response periods provided for under the applicable local law of the data subject's country will be observed where they are shorter than one month.

NETAMO SYSTEMS SL may request additional information to confirm the identity of the data subject where there are reasonable doubts, in accordance with Article 12(6) GDPR and the corresponding provisions of the applicable local data protection law.

Data subjects also have the right to lodge a complaint with a data protection supervisory authority. The lead supervisory authority for NETAMO SYSTEMS SL under the GDPR is the Spanish Agencia Española de Protección de Datos (AEPD). Data subjects may also lodge a complaint with the supervisory authority of their habitual residence, place of work or place of the alleged infringement — including, where applicable, the supervisory authorities of the jurisdictions identified in section 3 above.

5. Intellectual property

The selection, organisation, structure and presentation of the information made available through the websites, the source code of the websites, the "Dato Capital" brand, logos and graphic elements, and any database compiled in connection with the operation of the websites are protected by intellectual property rights, including copyright and sui generis database rights (where applicable). All such rights are owned by, or licensed to, NETAMO SYSTEMS SL.

The underlying factual information sourced from official public business registers is not, as such, owned by NETAMO SYSTEMS SL or by DATO CAPITAL LTD. That information remains subject to the legal regime of the relevant source register.

6. Accuracy of information

The information made available through the websites is derived from public registers in the jurisdictions listed in section 3 and is updated regularly to reflect changes in those registers. Users are referred to the original source register for the most up-to-date and authoritative version of any given record. The conditions under which the websites may be used are set out in the Terms of Service.