Sustainability | Inspiration

A conversation with Hugo Berenguer about architecture

SEPTEMBER 2026

11 minutes

Hugo Berenguer is CEO and partner at Rafael de La-Hoz Arquitectos, one of the leading practices in contemporary Spanish architecture. Drawing on a practice deeply rooted in Spanish architectural culture, he has championed a vision that integrates tradition, innovation, sustainability and strategy, viewing architecture as an exercise in cultural responsibility and forward-thinking.

Actiu’s connection with Rafael de La-Hoz’s architectural practice is long-standing and extensive. It began with Vicent Berbegal’s admiration for the architect, his works and his talent. The new Actiu RED space in Madrid is housed in the same building – a long-held dream of Actiu’s founder, who is a great admirer of the architect. As both brands have evolved, the practice and the company share many values, ranging from the importance of roots and the history of places, to respect for materials and care for people – whether through architecture or furniture. With Hugo, we reflect on respecting the memory of places, the importance of their identity and the ability to design new ways of living, working and interacting.

Actiu Red Project, Madrid

Projects such as Lagasca 99 in Madrid, which houses ACTIU RED, and the refurbishment of the Betis stadium in Seville exemplify this approach, which explores the city’s history and its material culture in order to translate them into contemporary architecture.

What does it mean to you for an architectural project to have a sense of history?

Memory implies a conscious awareness of the context in which the project is situated. And so, once we have that awareness, it is inevitable that – for better or for worse – it will influence the architecture. Sometimes we engage with that context, with that memory, in a positive way to reinforce the project’s concept.

But history also teaches us that there have been many moments in architecture when its ideals arose precisely from a rejection of previous ideas and of tradition. This, in itself, cannot happen without memory, without an understanding of history, because one cannot reject what one does not know.

Do you think that architecture is, above all, a cultural practice? In what way can a building express the identity of a place?

Architecture is inevitably a cultural practice. How can a project be designed without context?

When we architects design, we never face that ‘blank page’ that people fear so much, because we always work with specific elements: the climate, the topography, the building’s intended use, the dimensions of the human body, regulations, history… Before we even begin, the page is already filled with data that helps us shape the building.

And the key lies in the balance with which you blend these elements to solve the architectural problem, which will be different in each case. There will be projects where the key element is how the building fits into a historical context; in others, it will be functionality or the topography. That is the architect’s task: to correctly prioritise each project’s requirements in every situation so that the building provides the right solution.

I often imagine architecture as an equation in which you’re given a lot of data – those ingredients I mentioned earlier – and in which the unknown is the geometric solution, in the form of a building, that solves all the problems.

Hugo Berenguer, CEO and partner at Rafael de La-Hoz Arquitectos, at MDF 2026

How is scale managed in large-scale projects to ensure they maintain a human connection with the urban environment?

I think the issue of scale is one of the most difficult to get right, because it is very difficult for the human brain to make that leap from paper to reality. There are things that work very well on one scale but not on others. This is something that biology and biomechanics understand very well; they have known for a long time that certain organisms have limits on their size or shape depending on whether they are vertebrates or not. This also applies to architecture, and so we cannot apply the same design strategies to a small house as we would to a large stadium.

What role do materials play in creating a certain atmosphere and in the way people experience a space?

Materials are probably one of the most powerful tools architecture has at its disposal for creating atmospheres. Ultimately, people do not experience a building through its plans, but through light, textures, sounds, temperature or the way materials age over time.

The same space can convey completely different sensations depending on whether it is built from concrete, timber, stone or steel. Each material has its own physical properties, but also cultural connotations that inevitably influence how we perceive the space. For this reason, the choice of materials should never be a purely aesthetic decision. It relates to sustainability, maintenance, durability, comfort and also the identity of the project.

A very clear example where the prominence of materials is evident is Lagasca 99 itself , where Actiu’s showroom is located. The building’s façade is the first thing that catches the eye, showcasing three distinct materials that form part of a compositional strategy rooted in the interior’s functionality, such that each area – living room, bedroom or kitchen – is associated with a different material: glass, stone and wood, respectively.

Lagasca 99 Project, Madrid

To what extent should the context (climatic, historical, social) influence the formal and technical decisions of a project?

I think they must influence them greatly, because that is precisely where architecture originates. As architects, we are used to working within constraints. In fact, we often perform better the more constraints we face. The climate, history, regulations, the client’s needs, technological capabilities or the social characteristics of a place are not obstacles to the project, but rather the ingredients that help us shape it.

That said, this does not mean that the context dictates a single possible solution. Two architects can face exactly the same conditions and arrive at completely different proposals. The important thing is to understand that formal and technical decisions should not be made arbitrarily. They must stem from a proper understanding of all these circumstances and the ability to synthesise them into a coherent proposal.

In some projects, the historical context will carry greater weight; in others, the climate, topography or specific functional constraints will. The architect’s task consists precisely in prioritising these factors and finding the right balance in each case.

In some projects, the historical context will be the most significant factor; in others, it will be the climate, the topography or specific functional constraints.

The architect’s role is precisely to prioritise these considerations and strike the right balance in each case.

I find it hard to imagine good architecture that is indifferent to its context. In fact, when a building is truly well designed, something very interesting usually happens: it gives the impression that it could not have been built anywhere else.

Inside the Lagasca 99 building

How does the dimension of time influence the way you design? Should architecture aim for permanence or constant adaptation?

I think it’s both at the same time.

On the one hand, buildings are designed to last for many years. In fact, building structures are calculated to last for 50 years under normal use; in the case of hospitals, this can be as long as 100 years. The reality is that, if well maintained, they last much longer.

It is therefore an activity that, by its very nature, is intended to be long-lasting.

Having said that – and I’ll now tie this in with the other part of the question – only those buildings that are particularly good from an architectural point of view and are protected, or those whose design allows them to adapt to new uses or new ways of living in them, will endure .

How can we strike a balance between respecting our architectural heritage and incorporating new technologies and methodologies?

I think these are separate issues. Respecting heritage does not mean imitating it or restricting the use of new technologies. This is a very interesting debate that concerns the integration of new architectural styles into historic or already established settings.

Sometimes, we get the impression that respect is based on providing architectural solutions that are a continuation of the past, on imitating what came before, and I think that is quite wrong.

Look at the great historic cities you admire; they’re a mix of different architectural styles, some of which are separated by 2,000 years. The thing is, our minds have already categorised them as historical styles, and that plays tricks on us. How many examples do we have in Europe or in Spain of Roman architecture blended with Islamic, Romanesque, Gothic, Renaissance or Baroque buildings, which have little or nothing in common with one another?

What does a Roman building have in common with a Gothic one? Nothing – neither stylistically, nor conceptually, nor in terms of the technological methods used in their construction.

In fact, I believe that the blend of architectural styles – each of which is a faithful reflection of the ideas of its respective historical period – is what makes European cities so attractive and interesting: that blend, that coexistence of styles.

We cannot create architecture that does not reflect the times in which we live. Consider this: Mies defined architecture as ‘the will of an era translated into space’, and I believe he could not have put it more accurately.

Hugo Berenguer alongside Soledat Berbegal and Roberto García at MDF 2026

Respecting heritage means studying it, understanding it and taking it into account when designing – which is very different from imitating it, because that leads to the fossilisation of cities, whereas buildings should be living entities, constantly evolving.

How important is collaboration between architectural practices and industry in the evolution of spatial design?

In my opinion, it is very important. The development of the industry and new technologies has led to a vast array of technical solutions on the market for tackling the same problem.

Nowadays, it is impossible for an architect to have in-depth knowledge of all the advances taking place in materials, construction systems, building services, sustainability or digitalisation. That is why collaboration with industry is becoming increasingly necessary.

The best solutions usually emerge when both parties work together from the outset towards shared objectives. As architects, we provide an overarching vision of the project, whilst the industry contributes specialist knowledge, innovative capacity and technical expertise.

Furthermore, this collaboration helps to bridge the gap between the idea and its realisation. Projects that would have been impossible just a few years ago can now often be built thanks to the development of new technologies or new production systems.

I believe that innovation in architecture is rarely the result of the isolated work of a single person. It usually emerges when different disciplines collaborate and share knowledge.

How can architectural spaces foster collaboration, creativity and collective well-being?

That’s an interesting question. You see, before the pandemic, there was a whole theory surrounding new workspaces designed to encourage collaboration between employees with a view to boosting creativity, sharing ideas and visions, and so on. This all stemmed from the understanding that the best ideas often don’t come about in planned meetings, but rather through informal interactions – in corridors, the café area, and so on.

Building on that, offices began to be designed to encourage spontaneous encounters between employees; I think they called it ‘creative collisions’.

Then the pandemic hit and, for a while, all talk of this ceased as we moved to remote working and working from home… which, in my view, is a mistake because I fully agree with the pre-pandemic trends; they make perfect sense and I believe they work very well, and that architecture had a lot to say on the matter.

Another very interesting example is its application in hospital buildings, where the aim is not simply to design spaces to prevent problems or illnesses, but to create environments that actively promote people’s wellbeing and health.

In this sense, architecture ceases to be merely functional or aesthetic and becomes a tool that influences how people perceive, understand and experience space.

Rey Juan Carlos University Hospital by Rafael de la-Hoz Architects

Applied to design, this translates into strategies such as the use of natural light, a connection with nature, air quality, the choice of healthy materials, and the creation of spaces that foster both social interaction and privacy. It is not just a matter of preventing stress or illness, but of enhancing the positive experience of the space.

Numerous scientific studies have shown that the availability of natural light in hospital rooms has a positive influence on patients’ progress, promoting a faster recovery and improving their general well-being.

Furthermore, views of the natural environment help to reduce stress and the need for pain medication, which results in a more positive hospital experience and a more efficient recovery.

As a manager and creative professional, how do you develop a strategic vision without losing conceptual depth?

I am convinced that an architect is not just a great designer, but so much more. An architect must have a strong humanistic side. As we discussed, they must have a good understanding of history and the work of our ancestors; they must also possess strong analytical skills and be good with numbers. Furthermore, the profession requires technical knowledge of other disciplines such as materials, structural analysis, building services, acoustics and sustainability… In fact, on building sites, by law we are the directors and coordinators of all these disciplines.

An architect must also be able to explain their architectural vision to a client in a way they can understand, convince them and secure the commission. They must be articulate and, therefore, a good salesperson. If they are good at this, they will secure contracts and must therefore have legal knowledge. They must also negotiate their fee, as a great deal is at stake.

They must know how to organise their practice, whether large or small; they must understand what the sector needs at any given time and decide how to stand out…

And, of course, they must also be a good designer and possess conceptual depth.

But whilst this may sound complicated when put like that, it is what architects have been doing all their lives and what we have been trained to do at architecture schools.

What are the major challenges that architecture must tackle in order to remain relevant in a constantly changing world?

I believe there are major challenges on different scales and on various fronts… Let me give a few examples.

Generally speaking, I believe that architecture has diminished its capacity to act as a social tool in the face of a culture of spectacular, ‘Instagrammable’ buildings that are, however, often disconnected from society’s real needs. In this sense, it has lost a great deal of influence to political and economic interests… I believe that a profession with such a strong social vocation ought to be far more independent of all that.

In urban design, I’m very concerned about the challenge facing many cities due to the growth of tourism, which is turning them into theme parks where I find it impossible to live. What’s more, I find it almost unbearable even to be a tourist in certain cities… It’s something that’s spiralling out of control and deserves serious reflection.

I believe we need to discuss the emergence of AI as a challenge to be integrated into the profession. As a tool, it can enhance creativity, but it carries the risk of replacing critical thinking. It is also an issue that will spark many debates on intellectual property and authorship, which , I have no doubt, will prove to be a headache in the coming years.

Privacy policy

About our privacy policy and the processing of personal data

This Privacy Policy explains what types of personal data ACTIU collects from its customers, contacts, suppliers, partners and job applicants, why it collects such data and for what purposes. By way of definition, personal data is any information that can be used to identify a specific person (a natural person). The personal data that you are going to provide us with will be included in a file owned by our company for the purposes and under the terms set out below.

This processing is subject to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the free movement of such data.The processing of your personal data will be subject to the provisions of the European Parliament and Council Regulation of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), as well as Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights and its implementing regulations, in the event that such data refer to Spanish citizens.

Controller of the processing of your personal data

The party responsible for processing your personal data is ACTIU BERBEGAL Y FORMAS, S.A. (ACTIU).

Address: Parque Tecnológico Actiu,
CV-80 motorway, Onil-Castalla exit,
03420 Castalla (Alicante).
TAX ID: A03137874.
Telephone: +34 966 560 700

You can contact the Data Protection Delegate for any question related to the processing of your personal data at the following address: lopd@actiu.com

What types of personal data does ACTIU collect?

ACTIU collects the data strictly necessary to manage the relationships established with its clients, contacts, suppliers and collaborators. In any case, the data collected will be adequate and not excessive, being limited to what is necessary in relation to the purposes for which they are processed, and will be processed fairly and lawfully, and with due care.

The type of information we may collect will depend on the type of relationship ACTIU has with each user. In general, the most common categories are as follows:

Contact information: name, aliases and email address.
Organisation and contact information, in the case of corporate members.
User content: content of communications with the System Administrator, questions and suggestions.
Device and browser information, such as network and connection information (including Internet Service Provider [ISP] and Internet Protocol [IP] addresses), device and browser identifiers and information (including device, application, or browser type, device and browser type, device name, and browser type).(including device, application or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), cookie identifiers and information, and similar data.
Location data, such as the location of the user's device.
Demographic information, such as country and language preference.
In case of job applications, information about the candidate (identification and contact details, education and professional experience).

Purposes of processing personal data. What may we need your personal data for?

If we collect your personal data, we may need it for various reasons and depending on ACTIU's activities, including the following:

Web forms

The personal data you provide us with through the forms provided on the website or any other means of contact will be processed in order to deal with your queries and requests. When necessary, we will forward your request internally to the corresponding department for its correct management.

We will use your data to send you communications of interest if you have subscribed to our newsletter, communication of events, offers or any other type of service provided by ACTIU.

Legitimation: The legal basis for the processing of your data is the consent deemed to have been granted by providing us with your data and accepting this privacy policy.

Clients

The personal data that you provide us with when you maintain relations as a customer of ACTIU will be processed for the following purposes: customer management, product sales, order processing, fulfilment of tax and accounting obligations, sending quality questionnaires and sending communications of interest. In this sense, data provided from contact persons in companies that are necessary to maintain the relationship are also included in this group of interested parties.

Legitimation: The legal basis for the processing of your data is the existence of a contractual relationship and the legitimate interest of ACTIU to send you communications of interest in relation to its commercial prospecting activity to generate new business opportunities and customer loyalty, as well as to improve its services.

Suppliers

The personal data you provide us with when you maintain collaborative relationships and/or as an ACTIU supplier will be processed for general supplier management (supplier registration, contract management, orders and payments, etc.), for compliance with tax and accounting obligations, and to maintain a database of contacts for future contracts and/or collaborations.

Legitimation: The legal basis for the processing of your data is the existence of a contractual relationship.

Competitions and events

The personal data you provide when you register for a competition or event will be processed to manage the event (registration, participation, voting, raffles, event logistics, publication of information and images and related activities).The personal data you provide when you register for an event or competition will be processed for the purposes of managing the event (registration, participation, voting, prize draws, event logistics, publication of information and images and related activities), and for sending you information related to the event or communications about future events and activities of interest. Please note that if you register to participate in an event, ACTIU may share basic information about participants (name, company and email address) with other participants in the same event for the purposes of communication, exchange of ideas and networking. Responsibility for the use of such data by these persons or companies is not the responsibility of ACTIU and they must ask for your consent depending on the use they want to make of it, as well as inform you of their own personal data protection policy.

Legitimation: The legal basis for processing your data is the consent you give us when you register for the competition or event and ACTIU's legitimate interest in keeping you informed about it.

In these cases, a specific privacy policy may be established depending on each event, which will be informed at the time of registration.

Questionnaires and surveys

ACTIU may invite you to participate in questionnaires and surveys. These questionnaires and surveys will generally be designed in such a way that they can be answered without adding any personal data. If you nevertheless provide any personal data in a questionnaire or survey, ACTIU may use it to improve its products and services.

Legitimation: The legal basis for processing your data is the consent you give us when you complete the survey or questionnaire and ACTIU's legitimate interest in improving its products and services.

Registration of access and visits

In order to access the facilities of the ACTIU GROUP companies, we may ask you to identify yourself in the access register. The purpose of the processing of your data is to carry out a control of visits and the management of external personnel with access to the buildings.

During your visit, images may be taken that will serve us to document the visit or event, as well as to give it visibility, through our own channels (RRSS, website or various media).

Legitimation: The legal basis for the processing of your data is the legitimate interest of ACTIU for access control and security of its facilities, as well as the registration of activities and promotion of the same.

Video surveillance

ACTIU has a closed circuit of video surveillance cameras. The purpose of the processing of your image is the video surveillance and security of its facilities.

Legitimation: The legal basis for the processing of your data is the legitimate interest of ACTIU for the security of our facilities.

At ACTIU we will treat your personal data with absolute confidentiality, undertaking to keep them secret and guaranteeing our duty to safeguard them by adopting all necessary measures to prevent their alteration, loss, inappropriate loss, unauthorised processing or access, misuse, access, disclosure or destruction, in accordance with the legal obligations that apply to us as the parties responsible for the processing of your personal data. To protect this personal information, we take reasonable precautions and follow industry best practices.

Job applications

The information you provide to us when you apply for a job offer or submit a curriculum vitae (CV) will be processed for the following purposes:

Personnel selection during the processes that the company keeps open.
Maintaining a file with information on the professional profiles of candidates to provide services in our company in the event that a new vacancy arises.
Formalisation of an employment contract.

Legitimation: The legal basis for the processing of your data is your own consent, which is granted by sending your CV and accepting the privacy conditions.

Ethical channel

The personal data you provide us with through the form provided in the Ethics Channel or through a complaint filed with the company by any other alternative means (e-mail, post or personal interview) will be processed for the purpose of managing the investigation procedure.

Retention of your data

The data will be kept, in the case of customers or suppliers and their employees, for the duration of the contractual relationship and, thereafter, for the legal periods established by law for the prescription of contractual obligations, as well as for matters related to accounting and tax legislation. In all other cases, the data will be kept in accordance with the conditions established in the collection, for the time necessary to achieve the purpose for which they have been processed or until you withdraw your consent, object to the use of the data or inform us that you wish to delete them from our database.

In the case of images captured by our video surveillance systems, these images will be kept for a maximum period of one month.

In the case of sound, video and other images, they may be retained for educational, informational and/or promotional reasons (internally and externally) for a longer period of time, especially if they have been published on portals, networks or other media. In such a case, personal data will be limited to that strictly necessary for the maintenance of such information.

Disclosure

We may disclose your personal information if we are required to do so by law or if you violate our terms of service.

Where your consent is required to disclose your personal data to third parties, we will inform you on the data collection forms about the purpose of the processing, the data to be disclosed and the identity or business sectors of any potential recipients of your personal data.

Data processing by third parties

We inform you that ACTIU's service providers may have access to your data when it is necessary for the management of the services provided or contractual relations established with ACTIU, as well as for the maintenance of its systems (financial institutions, data storage, computer support and systems maintenance, legal, tax or accounting consultancies). Some of these companies may be located outside the European Union, so we will ensure that these suppliers comply with the guarantee requirements demanded by the applicable regulations on personal data protection. If you would like to request information about the suppliers with access to your data, you can contact us at lopd@actiu.com.

In the event that you contact us through one of our forms or through third parties (architectural portals, etc.), either to request information of any kind or to purchase any of our products or services, in order to answer your questions or analyse the needs raised in a personalised manner, we may respond directly or through the members of our network of distributors or collaborators in your place of residence, to whom we will send your data for this purpose.

All the entities referred to in this section will use this data for the same purposes and subject to the same conditions specified in this Privacy Policy.

ACTIU undertakes to maintain the confidentiality of the personal data provided, as well as to apply the security measures provided for in Spanish and European legislation, and to require third parties to whom the data is communicated to adopt identical measures.

Location of the information

All personal data related to the organisation and management of events are stored in secure computer applications and servers, as well as in specific electronic folders accessible only to authorised persons. ACTIU systems and servers are password protected and require an authorised username and password for access. Information is stored securely to safeguard the confidentiality and privacy of the data it contains. Paper documents are kept in secure cabinets or files.

In addition, all persons handling personal data within the ACTIU sign a confidentiality statement.

User rights

Your rights as a user in relation to the personal data you have provided to us (commonly known as ARCO-POL rights) are as follows:

Access: you may consult your personal data included in ACTIU files.
Rectification: you may modify your personal data when it is inaccurate or inadequate, or request the completion of such information when it is incomplete.
Deletion: you may request the total or partial deletion of your personal data.
Opposition: you may request that we do not process your personal data, although we may continue to process your data if we have legitimate grounds for the processing to override your privacy interest.
Restriction of processing: you may request that we restrict the processing of your data when: (i) the accuracy of your data is being challenged; (ii) the processing is lawful but you object to the erasure of your data; (iii) we do not need to process your data but you need it for the exercise or defence of claims; (iv) you have objected to the processing of your data while we verify whether the legitimate grounds for processing override your legitimate grounds.
Portability: you may receive a copy of the personal data you have provided to us in electronic form, as well as to transmit it to another entity without hindrance from us.
Withdrawal of consent: you may withdraw your consent at any time without affecting the lawfulness of the processing.

These rights differ depending on the local data protection laws in each country, state or territory. However, they may include more or less of the above rights.

If you believe that ACTIU is not processing your personal data in accordance with the requirements specified in this Privacy Policy or in the applicable data protection legislation, you may lodge a complaint with the Spanish data protection authorities (Agencia Española de Protección de Datos).

Links to other websites

Our website or any of our social media posts may contain links to websites external to our company. In these cases, ACTIU is not responsible for the privacy policies or the content of such sites. We recommend that you carefully read the privacy policies of such websites and social media sites.

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time and without prior notice, especially due to possible changes in regulations, jurisprudence or the criteria followed by the competent authority or the Spanish Data Protection Agency, so it is advisable to visit it regularly. Changes and clarifications will come into force immediately after their publication on the website. If we make material changes to this policy, we will notify you here that it has been updated.

Questions and contact information

If you have any questions or concerns, you may contact us through any of our communication channels.

However, to exercise your ARCO-POL rights or to register a complaint, you may contact our dpo at lopd@actiu.com, or by post to:

Address: Parque Tecnológico Actiu,
CV-80 Highway, Onil-Castalla exit,
03420 Castalla (Alicante).
TAX IDENTIFICATION NUMBER: A03137874.
Telephone: +34 966 560 700

Cookies policy

You can visit our cookie policy here.

Last updated: February 2023

Applications for selection processes

Maintenance of your data

The data will be kept for a maximum period of 2 years from its incorporation into our database or from its last update or modification carried out or requested by the candidate, being subsequently deleted or unusable on its servers as far as the security and data management system allows it. We inform you that you can update or modify your CV in our database at any time by re-entering it or informing us in writing.

Data processing by third parties

We inform you that ACTIU's service providers may have access to your data when it is necessary for the management of the services provided or contractual relations established with ACTIU, as well as for the maintenance of its systems (data storage, computer support and systems maintenance, legal, tax or accounting consultancies, transport companies or travel agencies). Some of these companies may be located outside the European Union, so we will ensure that these suppliers comply with the guarantee requirements demanded by the applicable regulations on personal data protection. If you wish to request information about the suppliers with access to your data, you can contact us at lopd@actiu.com.

All the entities referred to in this section will use this data for the same purposes and subject to the same conditions specified in this Privacy Policy.

Acceptance of the privacy policy

Submitting your CV or your application for any of the positions published on our website implies that you have read, understood and accept ACTIU's privacy policy, giving your consent for Actiu to process and transfer your personal data according to the conditions indicated in this Policy. To this effect, if you use our web portal, you must tick the acceptance option before sending your CV and/or application. In case of delivery or remission by other means, this Privacy Policy will apply to you, informing you that you can make use of your rights as informed in the point "User rights".

We inform you that your refusal to provide the required data or your non-consent to the use of the same in accordance with this policy will prevent us from processing your application.

Ethical channel

Maintenance of your data

The data processed when you file a complaint through the Ethical Channel or any other alternative method may be kept in the information system only for the time necessary to decide whether to initiate an investigation into the facts reported. In any case, if three months have elapsed since the receipt of the communication without any investigation having been initiated, they must be deleted, unless the purpose of their retention is to leave evidence of the operation of the system. If, in fact, the aforementioned possibility of conservation is chosen, the Head of the Internal Information System shall report on the appropriateness of leaving the aforementioned evidence, adopting all the custody measures that may be appropriate. In these cases, the user may not exercise his or her right of objection and suppression.

In any case, personal data relating to information received and internal investigations will be kept for as long as necessary, although the data may not be kept for a period of more than ten years under any circumstances.

Persons entitled to access your data

Access to the personal data contained in the Internal Information System shall be limited, within the scope of their powers and functions, exclusively to the following persons:

The Head of the Internal Information System and whoever manages it directly.
To the Head of HR or the duly designated competent body, only when disciplinary measures may be taken against an employee.
To the Head of the legal services of the entity or body, if legal measures should be taken in relation to the facts described in the communication.
To the persons in charge of processing that may be appointed.
To the data protection officer.
To the professionals designated by the person in charge of the Internal Information System who serve as support for the correct processing of the complaints.

In the aforementioned cases, the corresponding document offered by the administrative body shall be signed, regulating the status of data processor of the said authorised persons.

However, the processing of the data by other persons or even the communication to third parties shall be lawful, when necessary for the adoption of corrective measures in the entity or the processing of the sanctioning or criminal proceedings that, as the case may be, may be applicable.

Personal data that are not necessary for the knowledge and investigation of the actions or omissions reported shall not be processed and, where appropriate, shall be deleted immediately.

Processing of data by third parties

We inform you that ACTIU service providers may have access to your data when it is necessary for the management of the services provided or contractual relations established with ACTIU, as well as for the maintenance of its systems (data storage, IT support and maintenance of systems, or legal advice). Some of these companies may be located outside the European Union, so we will ensure that these suppliers comply with the guarantee requirements demanded by the applicable regulations on personal data protection. If you wish to request information about the suppliers with access to your data, you can contact us at lopd@actiu.com.

All the entities referred to in this section will use this data for the same purposes and subject to the same conditions specified in this Privacy Policy.

Disclosure

We may disclose your personal information if we are required to do so by law or if you breach our terms of service.

Acceptance of Privacy Policy

By submitting a complaint through ACTIU's internal reporting system, you signify that you have read, understood and agree to ACTIU's Privacy Policy and consent to ACTIU's processing and disclosure of your personal information in accordance with the terms and conditions set out in this Policy. To this effect, if you use our web portal, you must check the acceptance option before sending your complaint. In the event of delivery or forwarding by other means, this Privacy Policy will apply to you, informing you that you may exercise your rights as described in the section "User rights".

We inform you that your refusal to provide the required data or your non-consent to the use of the same in accordance with this policy will prevent us from being able to process your request.

In relation to the Data Controller, Purposes and legitimacy for processing, User Rights and Changes to the Privacy Policy, we refer to the general part of the ACTIU Privacy Policy.

Date of last update: May 2025