CorporateDefese
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PRIVACY POLICY

CORPORATE DEFENSE S.L.P and CORPORATE DEFENSE COMPLIANCE S.L., both with address at Salustiano Olózaga, 5 Escalera derecha, 2ª planta 28001 MADRID, Tax number B85010635 and B8708493535 respectively and with telephone number +34 917 819 107 (hereinafter jointly CORPORATE DEFENSE), as responsible for the processing of your personal data, inform you:

CORPORATE DEFENSE will process your data in full compliance with current data protection regulations, without being subject to exclusively automated or profiling decisions that could significantly affect you and without being used for purposes further or other than those reflected in this document.

A) DATA PROCESSING:

Below we provide detailed information on the processing we carry out based on the categories of people we deal with or certain activities we carry out, for what purposes, on what basis, for how long, and with whom, if anyone, we share such data.

1.- CLIENTS

a) Purposes and legitimacy of processing: Your data will be processed for the following purposes:

a. The provision of contracted services (independently by the entity with which you have contracted the service), including loyalty activities, client service, collections, etc.. We are able to do so since it is necessary for the execution of the contractual relationship that we maintain with you as a client.

b. Accounting and tax management of CORPORATE DEFENSE, since it is necessary to comply with our legal obligations.

c. Send you communications in relation to special events, such as birthday greetings, based on our own legitimate interest in maintaining the most cordial relationship possible with you.

d. To send you proposals about our services at your request or interest, as this is necessary for the conclusion and, where appropriate, execution of the contract for the provision of services.

e. Additionally and only if necessary, we will also process your data for control and security purposes, legal advice and regulatory compliance, as necessary to satisfy our legitimate interest in the defense of our interests and rights, to aovid conduct contrary to our codes and internal regulations and to comply with our legal obligations (audit, compliance with criminal law, personal data protection…).

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative or by other sources (complaints from third parties, witnesses or competent authorities). We keep them as long as you maintain the contractual relationship with us and subsequently, duly blocked, for the legally established period for defending or filing of possible claims.

c) Types of data: The types of data we use from you are identifying, contact, personal characteristics (such as nationality and marital status), economic, financial and transaction-related data, as well as any other data necessary for the proper carrying out of the contracted service. We rarely may also process other types of information that may be relevant in a possible internal incident, investigation or complaint.

d) Communication of your data: We may share your personal data with the following entities and/or persons:

In addition, with the following suppliers of ours, although exclusively to the extent that they are required to provide us with their services:

e) International data transfers: Exceptionally, we may need to transfer your personal data to Courts and Tribunals or other dispute resolution bodies, Law Enforcement, Attorneys, Experts, Notaries and Registrars outside the European Economic Area, if this is necessary for the exercise or defense of claims.

2.- POTENTIAL CLIENTS

a) Purposes and legitimacy of processing: Your data will be processed for the following purposes:

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative or by other sources (complaints from third parties, witnesses or competent authorities. We keep them as long as you do not object to the processing or, where appropriate, withdraw the consent previously given, and subsequently, duly blocked, for the legally stipulated period for defending or filing of possible claims.

c) Types of data: The types of data we use from you are identifying and contact data. Very rarely, we may also process other types of information that may be relevant in a possible incident, investigation or claim.

d) Communication of your data: We may share your personal data with Public Administrations, other Public Bodies and entities authorized by law, when required or necessary.

In addition, with the following suppliers of ours, but only to the extent required to provide us with their services:

e) International data transfers: Not foreseen.

3.- SUPPLIERS

a) Purposes and legitimacy of the processing: Your data will be processed for the following purposes:

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative or by other sources (recommendation from third parties, advertising spaces or through your corporate website) or by other sources (complaints from third parties, witnesses or competent authorities). We keep them as long as you maintain the contractual relationship with us and thereafter, duly blocked, for the legally stipulated period for defending or filing of possible claims.

c) Types of data: The types of data we use are your identification data, personal characteristics (such as nationality and marital status), academic and/or professional data, occupational data and data relating to transactions. Very rarely, we may also process other types of information that may be relevant to a possible internal incident, investigation or complaint.

d) Communication of your data: We may share your personal data with the following entities and/or persons:

In addition, with the following suppliers of ours, but only to the extent that they are required to provide us with their services:

e) International data transfers: Not foreseen.

4.- LEGAL REPRESENTATIVES AND CONTACT PERSONS

a) Purposes and legitimacy of the processing: Your data will be processed for the following purposes:

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative or by other sources (the company you provide your services to, LinkedIn or the corporate website of the company you work for) or by other sources (complaints from third parties, witnesses or competent authorities). We keep them as long as you provide your services to the entity with which we maintain a relationship, and thereafter, duly blocked, for the legally stipulated period for defending or filing of possible claims.

c) Types of data: The types of data we use are your identifying data, personal characteristics (such as nationality or marital status), contact details, academic and / or professional data, job occupation.

Very rarely, we may also process other types of information that may be relevant to a possible internal incident, investigation or complaint.

d) Communication of your data: We may share your personal data with the following entities and/or persons:

In addition, with the following suppliers of ours, but only to the extent that they are required to provide us with their services:

e) International data transfers: Exceptionally, we may need to transfer your personal data to Courts and Tribunals or other conflict resolution bodies, Law Enforcement, Attorneys, Experts, Notaries and Registrars outside the European Economic Area, if this is necessary for the formulation, exercise or defense of claims.

5.- RELATED TO OUR FILES (OPPOSING PARTIES, WITNESESS, EXPERT WITNESESS, ETC.)

a) Purposes and legitimacy of the treatment: Your data will be processed for the following purposes:

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative or by other sources (through our clients, witnesses, private detectives, etc.). We keep them as long as we maintain our relationship with our client and during the claims, out-of-court or judicial, or corresponding procedures remain alive and later, duly blocked, during the legally established period for the defense or interposition of possible claims.

c) Types of data: The types of data we use are your identifying data, contact data and any other that, depending on each case, is necessary for the defense of the interests and rights of our clients.

d) Communication of your data: We may share your personal data with the following entities and/or persons:

In addition, with the following suppliers of ours, but only to the extent that they are required to provide us with their services:

e) International data transfers: We may need to transfer your personal data to Courts and Tribunals or other dispute resolution bodies, Law Enforcement, Attorneys, Experts, Notaries and Registrars outside the European Economic Area, if this is necessary for the formulation, exercise or defense of claims.

6.- JOB CANDIDATES

a) Purposes and legitimacy of processing: Your data will be processed for the following purposes:

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative or by other sources (platforms such as LinkedIn or talent search companies). We keep them for 1 year from the receipt of the candidate’s application, CV or candidate history, unless they are necessary for a longer period for the exercise or defense of possible claims or for investigation of possible irregularities or criminal acts.

c) Types of data: The types of data we use are your identifying data, contact data, academic and/or professional data, job occupation data. Very rarely, we may also process other types of information that may be relevant to a possible incident, investigation or complaint.

d) Communication of your data: We may share your personal data with Public Administrations, other Public Bodies and entities authorized by law, when required or necessary.

In addition, with the following suppliers of ours, but only to the extent required to provide us with their services:

e) International data transfers: Not foreseen.

7.- WEB USERS

a) Purposes and legitimacy of processing: Your data will be processed for the following purposes:

b) Source and conservation period of your data: The data have been provided to us by you or your legal representative. Those obtained, if any, through cookies, we keep them for the period of time that, for each cookie or type of cookie is indicated in our cookie notice and / or cookie policy cookies policy. With respect to the data you provide when you send us an email, they will be kept until the communication received is definitively attended and then, duly blocked, during the legally established period for the defense and lodging of possible claims.

c) Types of data: The types of data we use from you are identifying, contact and any other that you provide us through the communication you send us and, in the case of cookies, identifying (visitor ID) data relating to the device from which you access our website (such as IP and browser used) and browsing habits and preferences.

d) Communication of your data: Your data will be shared with the cookie providers indicated in our Cookies Policy.

e) International data transfers: The use of the Google Analytics cookie set involves the transfer of your data to Google Inc, an entity based in the USA, a place that does not offer a level of protection equivalent to that required in Europe with regard to the processing of personal data. For this reason, Google has undertaken to implement a series of measures to ensure an adequate level of protection and equivalent to the European level through the so-called contractual clauses as indicated by Google in its document of Analytics data protection measures.

8.- TELEPHONE ASSISTANCE

a) Purposes and legitimacy of processing: Your data will be processed for the following purposes:

Management of visits, calls, appointments and requests received at the reception, by virtue of the contractual or pre-contractual relationship that we maintain with our clients or potential clients, as well as the legitimate interest of Corporate Defense in attending communications or requests.

b) Period of conservation of your data: We will retain your data as long as necessary for the aforementioned purposes plus the legal term for the possible defense or filing of claims.

c) Communication of your data: We may share your personal data with the following suppliers of ours, although exclusively to the extent required to provide us with their services:

d) International data transfers: Not foreseen.

Asimismo, le informamos de que, si considera que se ha producido algún tipo de vulneración en relación con el tratamiento de sus datos personales, puede presentar una reclamación ante la autoridad de control competente (en España la Agencia Española de Protección de Datos u organismo que lo sustituya en el futuro, para otros países europeos consulte aquí).

B) IS IT MANDATORY THAT YOU PROVIDE US WITH YOUR PERSONAL DATA?

It will be mandatory that you provide us with the data that, as described below for each category of persons, are necessary for those purposes based on the execution of a contract we have with you or for the fulfillment of legal obligations. In these cases, if such data is not provided, it will not be possible to fulfill your request or to execute all or part of the corresponding contract.

C) ABOUT OUR SUPPLIERS:

When choosing suppliers whose services involve them processing personal data under our control, CORPORATE DEFENSE applies strict criteria to choose only those who offer an adequate guarantee. We also contractually require them to adopt the necessary technical and organizational measures to guarantee the protection of the rights and freedoms of the persons whose information is processed and to use personal data only for what is strictly necessary according to the service they provide us with and the duration of that service.

D) YOUR RIGHTS AND HOW TO EXERCISE THEM:

You have the right to obtain information about the processing of your data, to access it, to have it rectified or, where appropriate, erased. In certain circumstances, you also have the right to limit the processing of your data, in which case we will only keep them for the exercise or defense of claims, to object to their processing and to their portability by transmitting them to you or directly to another company that you designate.

Withdrawal of consent: In relation to the processing of your data that we carry out based on the consent you have given us for it, you have the right to withdraw, at any time, such consent, although the withdrawal will not produce retroactive effects, so it will not affect the processing that had been carried out up to that moment.

You may exercise your right to object to the purposes described above that are based on the satisfaction of a legitimate or public interest. This right may be denied if, in view of the request made, it is proven that compelling legitimate grounds for the processing prevail or if the data are necessary for the formulation, exercise or defense of claims.

To exercise any of these rights you can contact CORPORATE DEFENSE at the postal address Plaza de la Independencia 2, 5º Izq. (28001, Madrid) or at the e-mail address cd@corporate-defense.com.

We also inform you that, if you consider that there has been any kind of violation in relation to the processing of your personal data, you can file a complaint with the competent supervisory authority (in Spain the Spanish Data Protection Agency or body that replaces it in the future, for other European countries see here).

E) CONTACT POINT:

For additional information, or for any other question regarding the processing of your data, please do not hesitate to contact our Data Protection Delegate through:

Address: Avinguda Mas Pins, NUM 150, PISO 3, RIUDELLOTS DE LA SELVA (17457), GIRONA – SPAIN.

E-mail: REGISTRO.DPD@CONVERSIA.ES

Current version dated December 23, 2021