PRIVACY POLICY

BASIC INFORMATION ON DATA PROTECTION

ADDITIONAL INFORMATION ABOUT DATA PROTECTION

A2 SOFTWARE CAMBRILS, S.L. (hereinafter referred to as "the Company") undertakes, as Controller of your personal data, to take the necessary technical and organisational measures to ensure that the processing of your data is in accordance with the provisions of Regulation (EU) 2016/679 (hereinafter referred to as "GDPR") and Spanish Organic Law 3/2018, of December 5 ^th, on Protection of Personal Data and guarantee of digital rights.

The Company processes your personal data in a lawful and loyal manner, ensuring that they receive adequate protection and are not misused. Likewise, the Company's willingness is to be transparent in the field of managing the personal data of its customers and users, making available to the above all the necessary information about the collection and processing of their data.

The purpose of the Privacy Policy is to inform you about who will process your personal data, why we collect this data, how long we will store the collected data, to whom we will transfer it and what your rights are in this area.

By providing us with your personal information and using our Website, we understand that you have read and understood the personal data protection information set out in this Privacy Policy and in the Cookie Policy.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

The Controller of your personal data is:

2. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Depending on the products, services or functionalities requested by customers and users, the Company will generally deal with the following data:

Identification and contact data: name and surname, e-mail address, among others.

- Automatically collected data: when interacting with our Website certain browsing data is collected automatically. This information is collected through cookies, the regulation of which is detailed in the Company's Cookie Policy

The information we may collect automatically refers to your use of our Website and the devices you use to access and interact with it. Some of the data we collect are: the IP address of the device you are using, the browsing program you use, your operating system, the date and time of access to the Website, the Internet address of the website by which you accessed our Website, geolocation data, information about the pages visited by the user within the Website and the browsing time on each page.

The personal data collected is processed for the following purposes:

- Quality analysis: conducting surveys on customer and user satisfaction in relation to the quality of the products and services offered by the Company.

- Customer and user service: providing customer and user support in order to channel and respond to their requests, queries and complaints for their management and resolution.

- Improve user experience on the Company's Website: performing analytical and statistical studies on how users browse the Company's Website in order to optimize it.

3. WHAT IS THE LEGITIMATION FOR PROCESSING OF YOUR DATA?

The lawful basis that allows us to process your personal data depends on the purpose for which we process it, as detailed below:

- Quality analysis. The lawfulness of processing your data lies in the legitimate interest of the Company to analyze the degree of satisfaction of customers and users, in order to be able to offer them products and services of the best quality;

- Customer and user service. The lawfulness of processing your data lies in the legitimate interest of the Company to meet your requests and complaints in order to properly respond to them and provide you with the proper support. In case of queries related to the exercise of your legally recognized rights in the field of data protection, the Company requires the processing of your data to comply with the legal obligations that apply in this field.

- Improve user experience on the Company's Website: the lawfulness of processing your data lies in the legitimate interest of the Company to know the degree of user satisfaction and take appropriate corrective measures to improve the quality of our services.

4. HOW LONG WILL WE STORE YOUR DATA?

Your personal data will be duly stored for the time necessary to be used for the purpose for which they were collected.

Your personal data will be properly stored, applying the appropriate security measures to ensure its accuracy and completeness, for the time necessary to be used according to the purpose for which they were collected or as long as you do not exercise your right of erasing or restriction of the processing.

In such cases, we will keep your personal information blocked, without giving it any processing, for the periods legally provided to meet any liabilities and to be able to prove compliance with our legal and contractual obligations. Subsequently, the Company will permanently delete your personal data.

5. WHO CAN WE SHARE YOUR DATA WITH?

Your personal data will be processed by members of the Company acting on behalf of the organization and which have signed the corresponding contracts that include specific obligations of confidentiality and diligent management of personal data in accordance with the legislation in this field.

In certain cases, in order to be able to fulfill the purposes set out in this Privacy Policy, the Company needs to share your personal data with the following third parties:

- Financial institutions.

- Technology and analytical service providers.

- Customer service providers.

- Authorities and public bodies to: respond to an order, subpoena or judicial investigation, or for any other cause required by law; address possible liabilities arising from the processing of personal data; prevent illegal uses of our Website or violations of our Website policies; attending third-party claims; contribute to the prevention and investigation of fraud assumptions, among others.

These third-party collaborators only have access to the personal information necessary to carry out the corresponding services and are required not to use it for any purpose other than that requested. The Company also requires these third parties the same degree of protection and confidentiality that we apply in the management of your personal information. In addition, all of them are subject to the obligations provided for in their respective data processing agreements closed with the Company.

Certain third-party collaborators may be in countries or territories located outside the European Union. In these cases, the Company transfers your data to them in accordance with the guarantees legally required for such situations:

- We check whether the third party is located in a country or territory that has been declared of adequate level of protection by the European Commission.

- In the absence of the above, we check if any of the following warranties are made:

o Conclusion of a contract containing standard data protection clauses approved by the European Commission.

o Implementation of binding corporate standards approved by the competent supervisory authority.

o Third-party's adherence to a Code of Conduct or certification mechanisms.

- In the absence of the above, in order to carry out the transfer of your data we ask for your express consent or request the express authorization of the competent supervisory authority.

6. WHAT ARE YOUR RIGHTS?

You are entitled to exercise the following rights in relation to the processing of your personal data:

- Access (Art. 15 GDPR): allows you to obtain certain information about the purposes for which your data is being processed, the recipients to which they are being communicated or the categories of data being processed, among others.

- Rectification (art. 16 GDPR): allows you to contact the Controller in order to modify those personal data that were inaccurate and to complete those that were incomplete.

- Erasure (art. 17 GDPR): allows you to request the erasing, without undue delay, of your personal data that are being processed by the Controller.

- Restriction of the processing (art. 18 GDPR): allows to obtain from the Controller the restriction of the processing of your data when certain conditions are met.

- Portability (art. 20 GDPR): allows you to receive your personal data or send it to a third party, in a structured, commonly used and mechanically readable format.

- Objection (Art. 21 GDPR): allows you to object to the processing of your data carried out by the Controller. However, you can only exercise this right against processing covered by the lawful basis of a public interest or a legitimate interest of the Controller.

- Objection to automated processing (Art. 22 GDPR): allows you not to be the subject of decisions based solely on the automated processing of your data, including profiling, when that decision-making has a legal effect on you or otherwise significantly affects you.

6.1. How can I exercise my rights?

In order to exercise your data protection rights, the Company makes available the following means:

- By written and signed request addressed to the Company (Paseo Sant Joan Baptista la Salle 9, 1-1. 43850, Cambrils (Tarragona)), indicating the reason for your application and the right you wish to exercise, having to attach a photocopy of the ID or equivalent document proving the identity of the applicant.

- Sending a completed and signed form, attaching a photocopy of the ID or equivalent document proving the identity of the applicant, to the email address: a2@a2software.net

The forms are provided below in order to exercise the various rights:

o Right of access: https://www.aepd.es/sites/default/files/2019-09/fo...

o Right of rectification: https://www.aepd.es/sites/default/files/2019-09/fo...

o Right of erasing: https://www.aepd.es/sites/default/files/2019-09/fo...

o Right to limit processing: https://www.aepd.es/sites/default/files/2019-09/fo...

o Right to portability: https://www.aepd.es/sites/default/files/2019-09/fo...

o Right of objection: https://www.aepd.es/sites/default/files/2019-09/fo...

o Right to object to automated processing: https://www.aepd.es/sites/default/files/2019-09/fo...

You also have the right to contact the competent data protection supervisory authority for any claim arising from the processing of your personal data, which in Spain is the “Agencia Española de Protección de Datos” (Formulario Presentación de Reclamaciones).

7. CHANGES IN THE PRIVACY POLICY

This Privacy Policy is subject to continuous review by the Company and is amended whenever necessary in order to adapt it to the current legislation of each moment or to any variation on our Website.

In the event that the update of the Policy implies a substantial change in the processing of your personal data, we will notify you of such modification through our Website (through a banner, pop-up or push notification) for the purposes that you can review and evaluate it.

Therefore, we recommend that you periodically review the Privacy Policy to stay informed about any developments related to the processing of your personal data.