Private office established in 2015.
Everything here was built.
We invest our own capital in the companies we build and govern, and in private credit, real estate, hospitality and art.
Private office established in 2015.
We invest our own capital in the companies we build and govern, and in private credit, real estate, hospitality and art.
Santomera Bay, S.L. is committed to protecting whistleblowers against any form of retaliation, in accordance with Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption.
All communications will be treated in the strictest confidence. You can find more information in our Privacy Policy and in our Internal Information System and Whistleblower Protection Policy and Quality and Information Security Policy.
Ways to access the Whistleblowing Channel
External reporting channels
In addition, the whistleblower may also turn to the competent authorities to file the corresponding report:
Legal notice
In accordance with Article 10 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (hereinafter, the “LSSI”), we inform you that the website https://www.santomerabay.com (hereinafter, the “Website” or the “Portal”) is operated by SANTOMERA BAY, S.L. (hereinafter, “SANTOMERA”), with Tax Identification Number B-66578774. It was incorporated on 16/07/2015 and is registered in the Commercial Registry of Madrid, Section 8, Registry Sheet 885143 (incorporation published in the BORME on 28/08/2015), with registered office at Paseo de Recoletos 6, 28001, Madrid, Spain.
This Legal Notice (hereinafter, the “Legal Notice”) sets out the conditions governing the use of the information society services that SANTOMERA makes available to users through the Website. Matters relating to the processing of Users’ personal data in connection with the use of the Website are governed by the Privacy Policy.
Accordingly, accessing and using the Website means that the user (hereinafter, the “User”) fully accepts and undertakes to comply in full with this Legal Notice, the Privacy Policy, and any instructions or recommendations given in each specific case.
Access to the Website is free of charge, except for the cost of the connection through the telecommunications network supplied by the access provider the User has contracted. SANTOMERA reserves the right to make, at any time and without prior notice, changes and updates to the Website and its contents, configuration and presentation, including this Legal Notice, and we therefore recommend reading it each time you access and browse the Portal.
The User undertakes not to use the Website for fraudulent purposes, nor to engage in any conduct that could damage the image, interests and rights of SANTOMERA or of third parties, and undertakes to use the Portal, and the services and contents included in it, diligently, correctly and lawfully. In particular, the User undertakes to refrain from removing, evading or tampering with the copyright and other data identifying the rights of their holders incorporated in the contents of the Portal, as well as any technical protection devices or any information mechanisms that such contents may include.
Likewise, the User undertakes not to perform any act intended to damage, disable or overload the Website, or that would in any way prevent its normal use and operation. Should the User breach this Legal Notice, or should SANTOMERA reasonably suspect that they are doing so, SANTOMERA reserves the right to limit, suspend or terminate their access to the Website, adopting any technical measure necessary for that purpose.
Likewise, SANTOMERA reserves the right to decide, at any time, on the continuation of the services it provides through the Portal.
Intellectual and industrial property
The intellectual property rights over the arrangement of the contents of the Website (including the sui generis right over the database), its graphic design (look & feel), distinctive signs (trademarks and trade names), the underlying computer programs (including source code), as well as the various elements that make up the Portal (texts, graphics, photographs, videos, etc.) belong to SANTOMERA, or SANTOMERA holds, where applicable, the right to use and exploit them, and as such they constitute works protected by the intellectual and industrial property legislation in force. The User’s use of the Website in no way entails the assignment of any intellectual and/or industrial property right over the Portal, its contents and/or the distinctive signs of SANTOMERA.
To that end, by means of this Legal Notice, except where legally permitted, the User is expressly prohibited from reproducing, transforming, distributing, publicly communicating, making available, extracting and/or reusing the Website, its contents and/or the distinctive signs of SANTOMERA. The reproduction of elements or contents of the Website for profit or commercial purposes is expressly and strictly prohibited.
Limitation of liability
The User acknowledges and accepts that the use of the Website is at all times at their sole risk and responsibility, and SANTOMERA is therefore not liable for any misuse or improper use of the Portal. To that end, SANTOMERA shall only be liable for damages the User may suffer from the use of the Website where such damages are provided for in the legislation in force. In particular, SANTOMERA shall not be liable for: the content of the sites linked through the links included within the Website.
In this regard, the terms set out in the “General provisions” section of this Legal Notice shall apply. Damages of any kind caused to the User’s computer equipment by viruses, worms, trojans or any other harmful element. The User acknowledges that the use of the Internet entails the assumption of a risk that their computer equipment may be affected by the aforementioned elements. To that end, it is in all cases the User’s responsibility to have adequate tools for the detection and removal of harmful electronic programs. Damages of any kind caused to the User that result from failures or disconnections in telecommunications networks that cause the suspension, cancellation or interruption of the Website service while it is being provided or beforehand. In this regard, the User acknowledges that access to the Portal requires services supplied by third parties outside SANTOMERA’s control (for example: telecommunications network operators, access providers, etc.), whose reliability, quality, continuity and operation are not SANTOMERA’s responsibility.
The inclusion of contents on the Website does not in any way constitute the provision of a legal advisory service. The User acknowledges that, since the application of the law to specific cases is not automatic but may vary depending on very diverse circumstances, the information contained in the contents is insufficient for decision-making of any kind. Therefore, the information included in the contents cannot be regarded as an alternative to legal advice, and SANTOMERA advises the User against making decisions on the basis of the information contained in the contents without obtaining appropriate professional advice.
Links
The Website may include technical linking devices (links) that allow the User to access other Internet pages and portals (hereinafter, “Linked Sites”). In such cases, SANTOMERA acts as an intermediary service provider in accordance with Article 17 of the LSSI, and shall only be liable for the contents and services provided on the Linked Sites to the extent that it has actual knowledge of their unlawfulness and has not disabled the link with due diligence. Should the User consider that a Linked Site contains unlawful or inappropriate content, we ask that they notify SANTOMERA at contact@santomerabay.com.
In no event shall this notification entail an obligation to remove the corresponding link. The existence of Linked Sites in no way implies that SANTOMERA has actual knowledge, or knowledge of any other kind, of their services and contents in the event of unlawfulness, nor that it necessarily has agreements with those responsible for or owners of the Linked Sites. Nor does the existence of such links constitute a recommendation, promotion, identification or endorsement by SANTOMERA of the statements, contents or services provided through the Linked Sites. Consequently, SANTOMERA is not responsible for the content of the Linked Sites, nor for their terms of use and privacy policies, and the User is solely responsible for checking and accepting them each time they access and use them.
The User and, in general, any natural or legal person who intends to establish a link from their page or site to the Portal must obtain prior written authorisation from SANTOMERA. The establishment of such a link does not in any case imply the existence of a relationship between SANTOMERA and the owner of the site or page on which it is established, nor SANTOMERA’s acceptance or approval of its contents or services. In any case, SANTOMERA reserves the right to prohibit or disable links to the Website at any time, especially where the activity or contents of the page or site that includes the link are unlawful.
General provisions
The use of the Website is governed by and construed in accordance with Spanish law, and by using the Portal the User agrees that any conflict or dispute arising between the User and SANTOMERA shall be dealt with by the competent courts and tribunals in accordance with the applicable legislation.
Should any of the provisions of this Legal Notice be declared null and void, it shall be withdrawn or replaced. In any case, such a declaration of nullity shall not affect the validity of the remaining provisions set out herein.
Privacy policy
Last updated: November 2026
Our Privacy Policy complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
Our contact details
SANTOMERA BAY, S.L.
Paseo de Recoletos 6, 28001, Madrid, Spain
Tel. +34 91 724 64 62
Email: privacy@santomerabay.com
What do we use personal data for?
We process personal data for the following purposes:
We also process the data we receive from candidates in current or future selection processes in order to manage those talent recruitment processes.
What legal bases do we rely on to process personal data?
We process personal data whenever at least one of the following conditions is met:
To which recipients may we disclose personal data?
We may share the personal data we process, for example:
Where it is necessary to transfer personal data to recipients located in countries outside the EU, or that do not guarantee a level of protection equivalent to that derived from Regulation (EU) 2016/679, we do so only in compliance with the requirements established by law.
How long do we keep the data?
We keep personal data for as long as we consider necessary in each case to be able to justify and/or account for our management, which may be linked to statutory limitation periods or to the possibility of receiving requests from competent authorities.
What security measures do we apply?
In order to safeguard the security of documentation and communications, we apply technical and organisational measures to guarantee an appropriate level of security in accordance with the applicable regulations.
What rights do you have and how can you exercise them?
You may request access to your personal data, its rectification or erasure, portability, or restriction of its processing, or you may object to the processing, by contacting SANTOMERA (using the contact details we have provided at the beginning of this Privacy Policy).
As regards processing based on consent, you may withdraw your consent at any time. You also have the right to lodge a complaint with the Spanish Data Protection Agency.
Review and update
This Privacy Policy is reviewed and updated at least annually.
Cookie policy
SANTOMERA BAY, S.L. (hereinafter, “SANTOMERA”) uses cookies for the operation of its website. To learn all the information relating to SANTOMERA’s Cookie Policy, you can consult this Cookie Policy.
SANTOMERA may modify this Cookie Policy in light of legislative or regulatory requirements, or in order to adapt it to the instructions issued by the Spanish Data Protection Agency, and users are therefore advised to visit SANTOMERA’s cookie policy periodically. When significant changes are made to this Cookie Policy, users will be notified on the website itself. For any questions or queries about this cookie policy, please contact us at privacy@santomerabay.com
According to the entity that manages them
According to how long they remain active
According to their purpose
What types of cookies are there?
Following the guidelines of the Spanish Data Protection Agency, we detail below the cookies used by this website in order to inform you as accurately as possible.
Analytics and measurement cookies
We only use analytics cookies if you accept them. If you reject them, or do not respond, no analytics cookie is installed.
These cookies are third-party cookies (Google LLC). Your choice is stored in your browser’s local storage for 12 months, and you can change it at any time:
Other third-party resources
The website loads its typeface (Avenir) from Adobe Fonts, a third-party service. To deliver the font, your browser connects to Adobe’s servers, which receive technical data such as your IP address. This does not depend on your cookie choice.
Personal data
Information on how we process personal data, the legal bases, recipients, retention periods, security measures and your rights, including the right to lodge a complaint with the Spanish Data Protection Agency, is set out in our Privacy Policy. If you have any question about this Cookie Policy, you can also write to privacy@santomerabay.com.
Review and update
This Cookie Policy is reviewed and updated at least annually.
This is an English translation of the original document in Spanish. In the event of any discrepancy, the Spanish version prevails. Download the original PDF (Spanish).
Internal Information System and Whistleblower Protection Policy
1. Purpose
This “Internal Information System and Whistleblower Protection Policy” (hereinafter, the “Policy”) demonstrates the commitment of Santomera Group1 (hereinafter, “Santomera Group” or the “Group”) to regulatory compliance, ethics and dialogue, fostering a culture of honesty, transparency and communication, and guaranteeing the protection of whistleblowers against possible retaliation.
For these reasons, Santomera Group has an Internal Information and Whistleblower Protection System (hereinafter, the “Internal Information System” or the “System”) as a formal mechanism for reporting irregularities, one of the guiding principles of which is the protection of any person who reports irregularities.
2. Scope of application
2.1. Personal scope
This Policy applies to Santomera Group, as well as to all directors, managers, employees and persons who have a relationship with the Group, regardless of their functional or hierarchical position (hereinafter, the “Personnel”).
In addition, any person, natural or legal, who has had, has or may have a professional relationship with Santomera Group, or a relationship within a professional context (hereinafter, “Third Parties”), is encouraged to use the Internal Information System in the cases regulated in this Policy and in its implementing procedure, as a formal mechanism and irrespective of other channels of communication made available to Third Parties.
2.2. Material scope
Both Personnel and Third Parties may file, through the Internal Information System, any reports they consider appropriate on the following matters:
A. Infringements covered by Article 2 of Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption:
Although it is possible to submit through the Santomera Group System matters other than those above, it is hereby stated that only communications concerning the matters listed in the preceding paragraphs will be covered by the protection measures established in Law 2/2023 of 20 February.
B. In addition, any other breaches or violations relating to ethics and compliance or to Santomera Group’s internal rules.
Communications concerning matters of an interpersonal nature2 that do not involve a breach and/or that form part of the strictly personal and private sphere between the persons involved fall outside the scope of the System. Likewise, any communication on information that is already publicly available, or that amounts to mere rumours, is excluded.
3. Principles and guarantees of the Santomera Group Internal Information System
The basic principles of action and guarantees on which the Santomera Group Internal Information System is based are set out below:
4. Communication mechanisms at Santomera Group
Santomera Group has various channels of communication with our Personnel and Third Parties to foster a culture of integrity and communication as a cornerstone of our Internal Information System.
The reporting channels available at Santomera Group are described below:
Likewise, clear and accessible information on the external reporting channels to the competent authorities is provided through the above-mentioned Santomera Group websites.
Communications received through the Internal Information System will be processed in accordance with the “Internal Information System and Whistleblower Protection Procedure”.
Should any information falling within the material scope of the System be communicated by means other than those described above, it will be ensured that its handling complies with the provisions of this Policy.
5. Internal Information System Manager
The Governing Body of Santomera Group has appointed the System Manager Body as the Internal Information System Manager, which will be responsible for the functions and responsibilities established in “Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption”.
The System Manager will act autonomously and independently from any other bodies, committees or commissions of Santomera Group, and will ensure the diligent processing of the procedure for handling the communications received.
In no case may the System Manager receive instructions of any kind in the exercise of these functions, and the System Manager must have all the personal and material resources necessary to carry them out.
6. Approval, publication and entry into force
The Governing Body of Santomera Group promotes and approves this Policy, thereby fulfilling its function of establishing the necessary foundations for the proper and efficient management of the Internal Information System and promoting compliance with the principles and guarantees set out in this Policy.
This Policy is published on the Santomera Group website and will be reviewed, updated, approved and disseminated periodically and whenever any amendments need to be made.
Notes
This is an English translation of the original document in Spanish. In the event of any discrepancy, the Spanish version prevails. Download the original PDF (Spanish).
QUALITY AND INFORMATION SECURITY POLICY
Santomera Bay, S.L. (the “Firm”) is a private equity firm specialised in investing in sectors such as alternative private financing, real estate, hospitality and art, either directly or through the creation, acquisition, development and management of specialised companies.
As a strategic and industrial partner, we combine investment capacity with strategic vision, leadership, corporate governance and operational and management capabilities to drive growth, transformation and sustainable value creation.
Aware that excellence in management, the trust of our partners, investors, clients and collaborators, and the protection of information are fundamental pillars of our activity, the Firm has an Integrated Quality and Information Security Management System in accordance with the standards UNE-EN ISO 9001:2015 and UNE-EN ISO/IEC 27001:2023.
This Policy is the frame of reference for setting quality and information security objectives, promoting a culture of continuous improvement, innovation and responsible management based on the following Principles and Commitments.
PRINCIPLES
COMMITMENTS
This Policy is available to all Firm personnel and to stakeholders, and is reviewed periodically to ensure it remains appropriate to the organisation’s purposes and strategy.
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