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PRIVACY POLICY: RIGHT TO INFORMATION

This Data Protection Policy regulates the processing of personal data provided by the User through the Internet portal (hereinafter, the “Portal”) made available by WINTERMAN SOLVIMAR, SLP to Internet users. This Privacy Policy is an integral part of the Legal Notice accessible at all times from the Portal.

The User guarantees that the data provided are true, accurate, complete, and up-to-date, and is responsible for any damage or harm, direct or indirect, that may arise as a result of non-compliance with this obligation. In the event that the provided data belong to a third party, the User guarantees that they have informed said third party of the aspects contained in this document and obtained their authorization to provide their data to WINTERMAN SOLVIMAR, SLP for the purposes indicated.

The Portal may offer features for sharing content through third-party applications, such as YouTube, Facebook, Twitter, Instagram, Pinterest, etc. These applications or social networks may collect and process information related to the user’s browsing on different websites. Any personal information collected through these applications may be used by other users of the same, and their interactions are subject to the privacy policies of the companies that provide the applications.

The Portal may host blogs, forums, and other social networking applications or services for the purpose of facilitating the exchange of knowledge and content. Any personal information provided by the user may be shared with other users of that service, over whom WINTERMAN SOLVIMAR, SLP has no control.

In order to provide information or services of interest based on the User’s location, WINTERMAN SOLVIMAR, SLP may access data related to the geolocation of the User’s device, in cases where the user’s configuration allows it.

For technical security and system diagnostics, in an anonymized or aggregated form, WINTERMAN SOLVIMAR, SLP may record the IP address (Internet access identification number of the device, which allows devices, systems, and servers to recognize and communicate with each other). This information may also be used for web performance analytics purposes.

WHO IS RESPONSIBLE FOR PROCESSING THE USER’S PERSONAL DATA? Identity: WINTERMAN SOLVIMAR, SLP is a Spanish company registered in the Mercantile Registry of Barcelona under volume 43616, folio 205, sheet B65945602, entry 1. VAT number: B65945602 Postal address: Aribau, 168-170 3rd 3rd, 08036 Barcelona (Spain) Phone: +34 932 128 622 Email: winterman@winterman.com

FOR WHAT PURPOSES DO WE PROCESS THE USER’S PERSONAL DATA? WINTERMAN SOLVIMAR, SLP processes the information provided by the User in order to attend to various requests made by the user. Depending on the nature of the request, the purpose will be:

a) Manage registration as a user of the Platform: The Personal Data you provide to us will be processed to identify you as a user of the Platform and give you access to its various functionalities, products, and services available to you as a registered user. b) Contact the User via email, telephone calls, SMS, or other equivalent electronic means, regarding updates or informational communications related to the functionalities, products, or services contracted, including Platform security updates, whenever necessary or reasonable for their execution. c) Address the requests or inquiries made by the User through the available Customer Service channels on our Platform or Physical Stores, if any. d) Manage the Curriculum Vitae submitted through the Portal. e) Participation in blogs, through comments. f) Communications through the Ethics Line or Whistle-blowing Hotline, surveys. g) Informational or advertising electronic communications about our products or services according to your interests.

WINTERMAN SOLVIMAR, SLP may create a commercial profile based on the information provided. No automated decisions will be made based on this profile. In the event that the User registers on the Portal through social login, WINTERMAN SOLVIMAR, SLP will only access the User’s personal data for which consent has been given during the configuration of the social network access in question. Any information provided in connection with such social applications may be accessed by members of the respective social network, and such interactions shall be governed by the privacy policies of the entities providing the services. WINTERMAN SOLVIMAR, SLP has no control or responsibility over such entities or their use of user information.

INFORMATION ABOUT DATA PROCESSING FOR SENDING COMMUNICATIONS FROM WINTERMAN SOLVIMAR, SLP The data used or provided in informational and/or promotional communications are processed by WINTERMAN SOLVIMAR, SLP for purposes consisting of sending electronic information and communications about services, activities, publications of WINTERMAN SOLVIMAR, SLP, monitoring and optimizing marketing campaigns carried out through appropriate technologies, and creating profiles for commercial purposes.

The consent for sending such communications may be revoked at any time in each of the communications received through the mechanism enabled for this purpose. The data retention criterion will be based on the expression of opposition to the processing by the user. In any case, you may exercise your rights of access, rectification, limitation, erasure, portability, and objection, by directing your request to the postal address indicated above or through the aforementioned email address.

HOW LONG WILL WE KEEP THE USER’S PERSONAL DATA? As a general rule, the personal data provided will be kept for the time necessary to attend to the User’s request or until its deletion is requested by the User, without prejudice to the periods of 5 or 10 years for the prescription of liability actions arising from a contractual relationship, established in article 1964 of the Civil Code and 121-20 of the Civil Code of Catalonia, respectively, depending on whether one or the other is applicable. In the specific case of resumes, the data will be kept for the time necessary to carry out the personnel selection process, unless otherwise indicated by the interested party.

WHAT IS THE LEGITIMACY FOR THE PROCESSING OF THE USER’S PERSONAL DATA? The legal basis for the processing of the data is the User’s consent or because the processing of their data is necessary for the management and maintenance of a contract entered into with you; likewise, the processing of your data may be necessary to comply with our legal obligations and finally, we may use your data to achieve a legitimate interest, such as being able to contact the user and offer them products and services that may be of interest to them.

TO WHOM WILL THE USER’S PERSONAL DATA BE COMMUNICATED? WINTERMAN SOLVIMAR, SLP relies on various service providers to offer the mentioned products or services, such as computer and storage services. Therefore, we will proceed to communicate your data when necessary to fulfill the purposes mentioned in this Data Protection Policy.

Likewise, the data may be transferred to public administrations and bodies to fulfill obligations directly enforceable to WINTERMAN SOLVIMAR, SLP. In cases where the User’s request justifies it, identifying data may be provided to other entities allied with the WINTERMAN SOLVIMAR, SLP network, including those located outside the European Economic Area, solely for the purpose of addressing the request linked to the destination country.

WHAT ARE THE USER’S RIGHTS WHEN PROVIDING THEIR PERSONAL DATA?


User shall have the right to obtain confirmation as to whether WINTERMAN SOLVIMAR, SLP is processing personal data concerning them, as well as to access their personal data, request the rectification of inaccurate data, or, where appropriate, request their erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

Under certain circumstances, User may request the restriction of the processing of their data, in which case they will only be retained for the exercise or defense of legal claims. Under certain circumstances and for reasons related to their particular situation, User may object to the processing of their data. WINTERMAN SOLVIMAR, SLP will cease processing the data, except for compelling legitimate reasons, or the exercise or defense of possible legal claims.

User may raise any questions they consider pertinent regarding this Policy, as well as exercise their rights in the legally established terms, by directing a communication via postal mail to WINTERMAN SOLVIMAR, SLP, at the postal address indicated above or through the previously indicated email, indicating the corresponding request and accompanied by a copy of their ID card or proof of identity.

Likewise, User or interested party shall have the right to revoke the consent given at any time and may address the Spanish Data Protection Agency to file the claim they deem appropriate.

LSSICE

In compliance with the provisions of article 21 of Law 34/2002, of July 11, on information society services and electronic commerce, by accepting this Legal Notice, you are requesting and/or expressly authorizing us to send you advertising or promotional communications by email. As a recipient of such communications, you have the right to revoke this consent at any time, by simply notifying us of your desire by postal or electronic mail through the addresses indicated above, indicating as a reference on the envelope or in the subject of the email “UNSUBSCRIBE EMAIL”.

Likewise, we inform you that in accordance with the aforementioned Law 34/2002, we must retain on our server the connection data and traffic generated by the communications established for a period of twelve months.

TERMS OF USE

INTELLECTUAL AND INDUSTRIAL PROPERTY AND USE OF CONTENTS:

The texts, images, sound, video, interactive screen designs, graphic designs, general or specialized information, and the rest of the contents of this Website are the property of WINTERMAN SOLVIMAR, SLP or third parties who have licensed WINTERMAN SOLVIMAR, SLP for their use.

All logos, trademarks, and industrial designs appearing on this Website are part of the industrial property rights of WINTERMAN SOLVIMAR, SLP, and any reproduction, distribution, public communication, and transformation without the express authorization of WINTERMAN SOLVIMAR, SLP is prohibited. Disclosure, use, transmission, distribution, reproduction, and transformation, in whole or in part, on any medium or media, of the contents of this Website without the prior and express consent of WINTERMAN SOLVIMAR, SLP is prohibited unless otherwise indicated or its use is for personal purposes and does not violate the rights recognized to WINTERMAN SOLVIMAR, SLP, and does not imply the granting of any license to the user. Its use for commercial, promotional, or illegal purposes, contrary to law, morals, or public order, which could harm the interests or damage the image of the Owner or legitimate third parties, as well as its distribution, modification, alteration, or decompilation are strictly prohibited.

Modification of the originals of this Site in any way is not allowed, nor is the reproduction, public exhibition, presentation, or distribution or any other use of them for commercial or public purposes, unless WINTERMAN SOLVIMAR, SLP expressly and previously authorizes it in writing for certain materials. For the purposes of these Conditions, any use of these materials on any other website or in a computer network environment, regardless of the purpose, is prohibited. The authorization granted to use this Site will automatically be terminated in case of breaching any of these Conditions, being obliged to immediately destroy any information obtained or printed from the Site.

DISCLAIMER OF WARRANTIES:

WINTERMAN SOLVIMAR, SLP does not guarantee that the information on this Website is correct, up-to-date, or complete, and this site may contain technical inaccuracies or typographical errors.

WINTERMAN SOLVIMAR, SLP assumes no responsibility (and expressly disclaims any responsibility) for updating this site to keep information current or for guaranteeing that the published information is accurate or complete. Therefore, the user must confirm that the published information is accurate and complete before making any decision related to any service, product, or topic described on this site.

WINTERMAN SOLVIMAR, SLP also assumes no responsibility for any damages that the user may suffer due to the lack of availability or operation of the site and/or all or some of its elements, information, services, contents, etc., or due to the lack of truthfulness or accuracy of any of them, as well as for any damages that the user may suffer through internet accessible spaces, such as web pages, etc., through hyperlinks or links established on the site.

USERNAME AND ACCESS CODE

In case any page of this Site requires the use of access codes, you will be responsible for protecting them against unauthorized use and disclosures. Any use of this Site using your name and access code will be your responsibility. Immediately inform WINTERMAN SOLVIMAR, SLP in case you notice any unauthorized use or disclosure of your access code. The user may only choose as a password words, numbers, or combinations of both that are not contrary to law, morality, generally accepted good customs, or public order. The use of passwords that, in any way, constitute a violation of industrial and intellectual property rights, or coincide with or resemble social denominations or advertising slogans, when lacking a fair title to do so, is prohibited. Any damages suffered by the user himself, or caused to third parties, as a consequence of using access codes and passwords that violate what is stipulated here will be the sole and exclusive responsibility of the user.

In case any page of this Site requires the use of access codes, you will be responsible for protecting them against unauthorized use and disclosures. Any use of this Site using your name and access code will be your responsibility. Immediately inform WINTERMAN SOLVIMAR, SLP in case you notice any unauthorized use or disclosure of your access code. The user may only choose as a password words, numbers, or combinations of both that are not contrary to law, morality, generally accepted good customs, or public order. The use of passwords that, in any way, constitute a violation of industrial and intellectual property rights, or coincide with or resemble social denominations or advertising slogans, when lacking a fair title to do so, is prohibited. Any damages suffered by the user himself, or caused to third parties, as a consequence of using access codes and passwords that violate what is stipulated here will be the sole and exclusive responsibility of the user.

CONNECTIONS TO OTHER WEBSITES

The connections from this Site to third-party websites have been established solely as a convenience for the user. If you use such connections, you will leave this Site. WINTERMAN SOLVIMAR, SLP has not reviewed all third-party websites and does not control or assume responsibility for them or their content. Consequently, WINTERMAN SOLVIMAR, SLP does not