Privacy policy - G. Elexalde S.A.

This privacy policy (the "Privacy Policy") describes and explains the framework in which G. ELEXALDE S.A. collects and treats the data of any individual or legal entity (the "Client") to whom legal, tax and commercial advice services are provided, in order to protect and respect the privacy of all of them.

This Privacy Policy is applicable to all personal data collected and / or processed by G. ELEXALDE S.A. in the exercise of the provision of its services, including, among others, access or use from any country in the world, of the web platform G. ELEXALDE S.A. www.g-elexalde.com, as well as its content and, in general, of the legal advice services and solutions provided by G. ELEXALDE S.A. Offer to the Customer.

G. ELEXALDE S.A. collects and treats the personal data that the Client puts at your disposal for the provision of the contracted services, being these essential for the registration and provision of the same. In this regard, the Client knows and accepts that the non-completion of certain personal data will prevent G. ELEXALDE S.A. provide all those services linked to such data.

For the purposes of this Privacy Policy, it must be understood as "Interested" any natural or legal person whose data may be subject to treatment by G. ELEXALDE S.A.

If there is any doubt, question or need that may arise in relation to the Privacy Policy, it is stated that all Interested Parties may contact G. ELEXALDE S.A. through elexalde@g-elexalde.com

1. RESPONSIBLE FOR THE TREATMENT

Responsible for all personal data processed as a result of using or contracting the services provided by G. ELEXALDE S.A., with CIF number A48093918, domiciled in Amorebieta (Bizkaia), Zubieta Industrial Estate 3, U.I. 11, and registered in the Mercantile Register of Bizkaia, Volume 3211 of the General Section of Companies, Folio 63, Sheet no. BI-4626 A, inscrip. 14, Date 8.3.07, with telephone 94 6300060 and electronic address elexalde@g-elexalde.com

2. DELEGATE OF DATA PROTECTION

G. ELEXALDE S.A. has appointed a Delegate for Data Protection, whose electronic contact address is as follows: elexalde@g-elexalde.com

3. PURPOSE OF THE TREATMENT

G. ELEXALDE S.A. performs a data treatment focused on the following purposes:

• Purpose of a contractual nature: The data processing performed by G. ELEXALDE S.A. as a result of contracting the provision of their legal services, or the signing of a contract with G. ELEXALDE S.A., has the following purposes:

o Manage the existing relationship between G. ELEXALDE S.A. and the Client, attending to the requests or requests raised by this.

o Offer the solution and / or advice to their needs, through the provision of legal services of fiscal and mercantile nature.

o Send notifications or information that G. ELEXALDE S.A. deems it convenient to inform the Client for the correct provision of the services and for the maintenance of the contractual relationship between both.

o Perform the appropriate anonymization procedures, after which G. ELEXALDE S.A. will no longer be in a position to identify the Client or to relate it to the data that the latter gave for the provision of the services contracted with G. ELEXALDE S.A ..

o Purpose of commercial nature: The data processing performed by G. ELEXALDE S.A. as a result of signing a contract with G. ELEXALDE S.A., and failing that, by the voluntary consent of the Interested Party, and failing this, for the legitimate interest of G. ELEXALDE S.A., pursues the following purposes:

o Periodically send commercial information about news, products and / or services related to G. ELEXALDE S.A., which may be of interest.

o Prepare a commercial profile of the clients, in order to send them information and / or operations related to products and / or services that may be of interest.

o Conduct market studies.

It is hereby stated that in no case G. ELEXALDE S.A., will treat, exploit, assign or transfer personal data to a use or purpose other than those expressly indicated here.

4. LEGITIMATION OF THE TREATMENT

The legality on the processing of personal data that ELEXALDE S.A. performs It is based on the following sources or causes:

Legitimation for the execution of a contract or provision of a service: In the event that the personal data processed comes from the information provided by the Client as a result of the signing of a contract with G. ELEXALDE S.A. for the provision and / or reception of legal advice services, the legal basis for the treatment of such data is based on the execution of said contract or on the provision of the service requested by the Client, and is performed under the terms and conditions subscribed in the same and in this Privacy Policy.

Legitimization by consent of the interested party: In the cases in which the data are provided by the Client voluntarily, the legal basis for the treatment of their data is based on the contribution of their consent. In these cases, the Client may withdraw his consent at any time, exercising the rights that correspond to him and which are detailed in this Privacy Policy.

The express denial of consent for commercial purposes does not affect the maintenance or fulfillment of the contractual relationship by which the advisory services of G. ELEXALDE S.A. that, in your case, have been hired. In this case, G. ELEXALDE S.A. You may continue to process the data for the sole purpose of executing the subscribed contract.

Legitimation based on the legitimate interest of G. ELEXALDE S.A. : Without prejudice to the causes described, G. ELEXALDE S.A. it treats personal data to fulfill its legitimate interests. Specifically, it is understood by legitimate interests of this, the possibility of promoting, offering, maintaining and improving the performance of the provision of services, develop new services or functions that are useful for G. ELEXALDE S.A. , and to promote and offer the services offered by G. ELEXALDE S.A. between the different Clients and / or potential Clients thereof.

5. COMMUNICATION OF DATA AND ADDRESSEES

As a general rule, G. ELEXALDE S.A. does not sell, exchange or transfer to third parties, the personal data collected and / or processed in the exercise of the provision of legal, tax and commercial advice services.

However, it is indicated that an optimal provision of the services offered by G. ELEXALDE S.A. may require third party service providers of G. ELEXALDE S.A. Access personal data collected and / or processed by it.

For this reason, it is warned that, when access to such data is strictly necessary for the provision of the services of G. ELEXALDE SA, the data collected or processed may be transferred and / or communicated to third parties who subscribe legal relationships with G. ELEXALDE SA, with the purpose of managing part of the services contracted with G. ELEXALDE SA and / or collaborate in the correct provision of the same.

In any case, such communication and / or transfer of data to third parties will be made for the same purposes and purposes for which they have been collected by G. ELEXALDE SA, and these third parties will be, in any case, contractually bound to comply with them. obligations of confidentiality to which G. ELEXALDE SA submits The purpose of such transfer of data to other addressees must be necessary for the development of the activities of G. ELEXALDE SA.

By accepting this Privacy Policy, Clients understand that some of the aforementioned service providers may be located in countries outside the European Economic Area or that they do not offer a level of security equivalent to Spanish. In these cases, the transfers are based on the authorization of the Directorate of the Spanish Control Authority, in model model clauses approved by the Commission and, where appropriate, on the Privacy Shield.

In addition to the above, G. ELEXALDE S.A. may make assignments and / or communications of personal data to meet their legal obligations with respect to Public Administrations and / or Judicial Bodies, in cases where this is required in accordance with current legislation at all times.

The user has the right to consent or prevent the transfer of personal data to third parties. The data will not be transferred to third parties except for legal obligations or after receiving the explicit consent.

6. DEADLINES

The personal data collected and / or processed by G. ELEXALDE S.A. They will be kept for as long as necessary to fulfill the purposes for which they were collected.

In this regard, once the services are provided or the contract expires, the provision of the legal advice services of G. ELEXALDE SA, the personal and informational data and / or the data generated as a result of the contract was terminated. The provision of services will be immediately eliminated with a safe and confidential nature.

Notwithstanding the foregoing, Once the contractual and / or commercial relationship subscribed with G. ELEXALDE SA has been finalized, it may continue to maintain the contact details of the Client, for a maximum period of three (3) years, for the sole purpose of send information and / or promotions regarding products and / or services of G. ELEXALDE SA that may be of your interest.

Also, G. ELEXALDE S.A. may anonymize the personal data collected and / or processed, in order to use them solely and exclusively for statistical purposes.

In any case, the data will be available exclusively to Judges and Courts, the Public Prosecutor or the competent Public Administrations, and in particular, at the disposal of the data protection authorities, to attend to the possible responsibilities arising from the treatment, during the term of prescription of these. Once these deadlines have elapsed, the data will be deleted.

7. RIGHTS OF INTERESTED PARTIES

Through this Privacy Policy, G. ELEXALDE S.A. informs and makes available to the Interested Parties the possibility of all of them exercising at any time, freely and voluntarily, the rights listed below:

• Right of access, to know the type of data collected and treated, as well as the characteristics of the treatment performed.

• Right of rectification, to request the modification of the collected data, as these are inaccurate or not true.

• Portability right, to request the obtaining of a copy of the data object of treatment by G. ELEXALDE S.A.

• Right to limitation of treatment, to request the suspension of treatment in the event that it is illegal or the accuracy of the data has been challenged.

• Right of withdrawal, to request the elimination of the data collected, when the treatment is no longer necessary.

• Right of opposition, to request the cessation of the sending of commercial communications by G. ELEXALDE S.A.

• Right to revoke the consent given.

• Right to claim before the AEPD, to request before said body the protection of the rights granted by the current regulations.

G. ELEXALDE, S.A. with CIF number A48093918, domiciled in Amorebieta (Bizkaia), Polígono Industrial Zubieta 3, U.I. 11, and registered in the Mercantile Register of Bizkaia, Volume 3211 of the General Section of Companies, Folio 63, Sheet no. BI-4626 A, inscrip. 14, Date 8.3.07.

These rights may be exercised free of charge by any Interested Party, by means of a written and signed request sent by postal mail to Polígono Industrial Zubieta 3, U.I. 11, 48.340 Amorebieta (Bizkaia, Spain), or through the email elexalde@g-elexalde.com

The request must include the following information: name and surname of the Client, address for the purposes of notifications, photocopy of the National Identity Document, Passport or CIF (in case of being a legal entity), and request in which the request is specified. In this regard, it is noted that the AEPD website makes available to the Interested Parties, a series of models that will help them in the exercise of their rights.

Finally, it is indicated that the withdrawal of consent by an Interested Party by the above procedure does not affect the lawfulness of the treatment prior to its withdrawal. In this regard, it is noted that G. ELEXALDE S.A. may continue to treat the data of the Interested Party to the extent that current regulations permit.

8. SECURITY MEASURES

In accordance with the provisions of applicable regulations, G. ELEXALDE S.A. It undertakes to adopt the necessary measures to comply with its duty to keep secret all the personal data it may collect and / or treat, avoiding its alteration, loss, treatment and / or unauthorized access.

In this regard, it is stated that G. ELEXALDE S.A. It has implemented the security measures of technical and / or organizational nature necessary to ensure the security of your personal data, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed.

In relation to this, it is declared that G. ELEXALDE S.A. it is an entity concerned about privacy, and in order to reinforce the confidentiality and integrity of the information in its organization, it continuously maintains the supervision, control and evaluation of its processes to ensure respect for the privacy and security of the information referred to in the present Privacy Policy.

9. UPDATING OF THE PRIVACY POLICY

G. ELEXALDE S.A., reserves the right to modify its privacy policy or conditions of use for reasons of adaptation to current legislation.

The user of this website is recommended to periodically review this page, since the use of this website by the user will be understood as acceptance of the privacy policy. Ensure the absolute confidentiality and privacy of the personal data collected.

The security measures have been adopted in order to avoid alteration, loss, treatment or unauthorized access. However, G. ELEXALDE S.A. will not be responsible for the incidents that may arise around personal data when these are derived, or from an attack or unauthorized access to the systems in such a way that it is impossible to detect or prevent it even adopting the measures according to the state of technology current.