LEGAL NOTE

PRIVACY POLICY: RIGHTS OF INFORMATION

This Data Protection Policy regulates the processing of personal data provided by the User through the Internet portal (hereinafter, the “Portal”) that WINTERMAN SOLVIMAR, SLP makes available to Internet users. This Privacy Policy forms an integral part of the Legal Notice accessible at all times from the Portal.The User guarantees that the information provided is true, accurate, complete and up to date, and is liable for any damage or injury, direct or indirect, that may be caused as a result of the breach of such obligation. In the event that the data provided belonged to a third party, the User guarantees that he has informed the third party of the aspects contained in this document and has obtained his authorization to provide his 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 navigation on the different websites. Any personal information collected through these applications may be used by third party users of these applications, and their interactions are subject to the privacy policies of the companies providing the applications.

The Portal may host blogs, forums, and other social networking applications or services in order to facilitate the exchange of knowledge and content. Any personal information provided by the user may be shared with other users of this service, over whom WINTERMAN SOLVIMAR, SLP  has no control whatsoever.

In order to offer information or services of interest depending on the location of the User, WINTERMAN SOLVIMAR, SLP may access to data relating to the geolocation of the User’s device, in those cases where the user’s configuration for this purpose allows it.For technical security and system diagnostics purposes, WINTERMAN SOLVIMAR, SLP may record the IP address (the Internet access identification number of the device, which allows devices, systems and servers to recognize and communicate with each other) in an anonymous or aggregated manner. Such information may also be used for web performance analysis purposes.

WHO IS THE CONTROLLER OTF THE USER’S PERSONAL DATA? 
Company: WINTERMAN SOLVIMAR, SLP  is a Spanish Company registered in the Commercial Registry: “tomo 43616, folio 205, hoja B65945602, inscripción 1ª”. 
CIF B65945602
Address: Aribau, 168-170 3º 3ª, 08036 de Barcelona (Spain)
Teléfono: +34 932 128 622
Email: winterman@winterman.com

FOR WHAT PURPOSE DO WE PROCESS THE USER’S PERSONAL DATA? 
WINTERMAN SOLVIMAR, SLP process the information provided by the User in order to meet the various requests made by him/her. Depending on the nature of the application, the purpose of the application shall be to:

a) Manage the registration as a user of the Platform: The Personal Data you provide will be processed to identify you as a user of the Platform and give you access to the different functions, products and services that are available to you as a registered user.
b) To contact the User through e-mail, telephone calls, SMS or other equivalent electronic means of communication, in relation to updates or informative communications related to the contracted functionalities, products or services, including security updates of the Platform, whenever necessary or reasonable for their execution.
c) To attend the requests made by the User through the Customer Service channels available on our Platform or Physical Stores, if any.
d) Manage the Curriculums Vitae sent through the Portal.
e) Participation in blogs, through comments.
f) Communications through the Ethics Line or Whistle-blowingHotline, surveys.
g) Electronic communications of an informative or advertising nature of our products or services in accordance with your interests.

WINTERMAN SOLVIMAR, SLP may elaborate 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 the social login, WINTERMAN SOLVIMAR, SLP will only access the User’s personal data for which it has given its consent during the configuration of the access to the social network in question. Any information provided in connection with such social applications may be accessed by members of the corresponding social network; such interactions will be governed by the privacy policies of the entities providing the services. WINTERMAN SOLVIMAR, SLP  does not have any control or responsibility with respect to these entities or the use they make of user information.

INFORMATION ABOUT DATA PROCESSING FOR SENDING COMMUNICATIONS FROM WINTERMAN SOLVIMAR, SLP 
The data used, or provided, in the informative and/or promotional communications are processed by WINTERMAN SOLVIMAR, SLP  for purposes consisting with sending electronic information and communications on services, activities, publications, WINTERMAN SOLVIMAR, SLP  monitoring and optimization of marketing campaigns conducted using technologies for this purpose, and the development of profiles for commercial purposes.

The consent for the sending of such communications may be revoked at any time in each of the communications received through the mechanism provided for that purpose.The criterion for storing the data will be based on the statement contrary to the processing on your part. In any case, you may exercise your rights of access, rectification, limitation, cancellation, portability and opposition by sending your request to the postal address indicated above or by e-mail as indicated above.

HOW LONG WILL WE KEEP THE USER’S PERSONAL DATA? 
In general, the personal data provided will be kept for the time necessary to comply with the User’s request or for as long as it is not requested to be cancelled by the User, without prejudice to the 5 or 10 year limitation periods for liability actions arising from a contractual relationship, established in article 1964 of the Spanish Civil Code and 121-20 Civil Code of Catalonia, respectively, depending on whether one or the other is applicable. In the specific case of curriculum vitae, the data will be kept for the period 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 legitimation by consent of the User or because the processing of your data is necessary for the management and maintenance of a contract subscribed with you; likewise, the processing of your data may be necessary to comply with our legal obligations and finally, we can use your data to obtain a legitimate interest, such as being able to contact the user and offering products and services that may be of interest to you.

TO WHICH RECIPIENTS WILL THE USER’S PERSONAL DATA BE COMMUNICATED?
WINTERMAN SOLVIMAR, SLP relies on various service providers to offer the products or services mentioned, such as computer and storage services. That is why we will communicate your data when necessary to comply with the purposes mentioned in this Data Protection Policy. Likewise, the data may be transferred to administrations and public bodies for the fulfillment of obligations directly required to WINTERMAN SOLVIMAR, SLP.In those cases in which the User’s request so justifies, the identification data may be provided to other entities affiliated to the WINTERMAN SOLVIMAR, SLP network, including those located outside the European Economic Area, for the sole purpose of attending to the request linked to the country of destination.

WHAT ARE THE USER’S RIGHTS WHEN PROVIDING US WITH PERSONAL DATA?
The User has the right to obtain confirmation as to whether WINTERMAN SOLVIMAR, SLP processes personal data concerning him or her, as well as to access to his or her personal data, request the rectification of inaccurate data or, where appropriate, request their cancellation when, among other reasons, the data are no longer necessary for the purposes for which they were collected.In certain circumstances, the User may request the limitation of the processing of his/her data, in which case they will only be kept for the exercise or defense of claims.In certain circumstances and for reasons related to his particular situation, the User may object to the processing of his data.

WINTERMAN SOLVIMAR, SLP  will cease the processing of data, except for compelling legitimate reasons, or the exercise or defense of possible claims.The User may raise the questions he or she considers in relation to this Policy as well as exercise his or her rights under the terms established by law by sending a letter by post to WINTERMAN SOLVIMAR, SLP , at the postal address indicated above or by e-mail as indicated above, indicating the corresponding request and accompanied by a copy of the ID card or document proving identity.Likewise, the User or the data subject shall have the right to revoke the consent given at any time and may contact the Spanish Data Protection Agency to submit any complaint it deems appropriate.

LSSICE
In compliance with the provisions of Article 21 of Law 34/2002, of 11th July, on information society and electronic commerce services (henceforth LSSICE), by accepting this Legal Notice, you are requesting and/or expressly authorizing us to send you advertising or promotional communications by e-mail. As the recipient of such communications, you have the right to revoke this consent, at any time, by simply notifying us of your intention by post or e-mail at the above addresses, indicating “UNSUBSCRIBE EMAIL” as the reference on the envelope or in the subject line of the e-mail.

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

TERMS OF USE

INTELLECTUAL PROPERTY AND USE OF THE CONTENTS:
The texts, images, sounds, videos, interactive screen designs, graphic designs, general or specialized information and the rest of the contents of this website are property of WINTERMAN SOLVIMAR, SLP or of third parties that have licensed WINTERMAN SOLVIMAR, SLP for its use. 
All logos, trademarks and industrial designs that appear on this website are part of the intellectual property rights of WINTERMAN SOLVIMAR, SLP. Any form of reproduction, distribution, public communication and transformation is prohibited without the express authorization of WINTERMAN SOLVIMAR, SLP. The disclosure, use, transmission, distribution, reproduction and transformation, in whole or in part, in any form or medium, 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 personal and does not violate the rights recognized to WINTERMAN SOLVIMAR, SLP, and it does not imply the granting of any license to the user. It is strictly forbidden to use it for commercial, promotional or other purposes contrary to the law, morality or public order, which could harm the interests or damage the image of the Holder or legitimate third parties, as well as its distribution, modification, alteration or decompilation.

It is not permitted to modify the originals of this Site in any way, or the reproduction, public display, presentation or distribution or any other use of them for any commercial or public purpose, unless WINTERMAN SOLVIMAR, SLP authorizes it in advance and expressly in writing for certain materials. For the purposes of these Terms, any use of these materials on any other web site or in a networked computer environment, for any purpose whatsoever, is prohibited. The authorization granted to use this Site shall be understood to be automatically terminated in the event of any breach of these Terms and Conditions, and shall be obliged to immediately destroy any information obtained or printed from the Site.

EXCLUSION OF LIABILITY:
WINTERMAN SOLVIMAR, SLP does not guarantee that the information on this website is correct, updated or complete, and this website may contain technical inaccuracies or typographical errors.
WINTERMAN SOLVIMAR, SLP assumes no responsibility (and expressly disclaims any liability) for the updating of this site to keep the information up to date nor does it guarantee that the information published is accurate or complete. Therefore, the user must confirm that the information published is accurate and complete before making any decision regarding any service, product or subject described on this site.
WINTERMAN SOLVIMAR, SLP does not assume responsibility for any damages that the user may suffer due to the lack of availability or functioning of the site and/or of all or some of its elements, information, services, contents, etc., or for the lack of veracity or accuracy of any of them, as well as for any damages that the user may suffer through accessible Internet spaces, such as web pages, etc., through hyperlinks or links established on the site.

USER NAME AND PASSWORD: 
In the event that any page of this Site requires the use of passwords, you are responsible for protecting it from unauthorized use and disclosure. Any use of this Site using your name and password is at your own risk. Inform WINTERMAN SOLVIMAR, SLP immediately in case you notice any unauthorized use or disclosure of your password. The user may only choose as a password words, numbers or sets of both that are not contrary to the law, morality, generally accepted good customs or public order. It is forbidden to use passwords that, in any way, infringe intellectual property rights, or coincide or resemble company names or advertising slogans, when it does not have the right title to do so. The damages suffered by the user himself or by third parties as a result of using access codes and passwords that violate the provisions herein shall be the sole and exclusive responsibility of the user.

CONNECTIONS TO OTHER WEB SITES: 
The connections of this Site to third party web sites have been established solely as a utility for the user. In case of using such connections, this Site will be abandoned. WINTERMAN SOLVIMAR, SLP has not reviewed all the websites of third parties, and does not control and is not responsible for them or their content. Consequently, WINTERMAN SOLVIMAR, SLP does not endorse or make any statement regarding such web sites, or any information, software or other products or materials found therein, or any result that may be achieved through its use. The user will be the only responsible in case of deciding to access any of the third party websites connected to this Site.

MODIFICATIONS AND UPDATES:

WINTERMAN SOLVIMAR, SLP reserves the right to make unannounced changes it deems appropriate to its website, and may change, delete or add content and services provided through the same as well as the way they are presented or located on its website.

TRANSLATIONS:

The text of this website may be available in languages other than Spanish. The text may have been translated by a person or by computer software, without intervention or human revision. These translations are provided for your convenience, and WINTERMAN SOLVIMAR, SLP does not guarantee that the translation is accurate or complete, whether it is an automatic translation or if a person has made.

APPLICABLE LAW AND FORUM: 

WINTERMAN SOLVIMAR, SLP will pursue the breach of the above conditions of use as any misuse of its website exercising all civil and criminal actions that may correspond in law.
In order to solve any possible questions regarding the use of this website or its contents, they will be governed by and interpreted in accordance with these Conditions of Use, the Legal Notice and Spanish legislation, and the parties will submit to the jurisdiction of the Courts and Tribunals of Barcelona, unless a law does not permit it, expressly waiving any other jurisdiction that may correspond to them by virtue of their domicile.

COOKIE POLICY

DEFINITION AND FUNCTION OF COOKIES
What are cookies? A cookie is a file that is downloaded to your computer when you access to certain web pages. Cookies allow a website to, among other things, store and recover information about the browsing habits of a user or their computer and, depending on the information they contain and the way they use their computer, may be used to recognize the user.
The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on our Website and the sites visited just before and after the Website.
By browsing and continuing to use our Website, you are consenting to the use of the cookies set forth above, for the periods indicated and under the conditions contained in this Cookies Policy.

WHAT TYPES OF COOKIES DOES THIS WEBSITE USE?
Technical Cookies: a type of cookie designed to collect and store data while the user accesses the website, for winterman without exhaustive character for the selection of the language or session.
Analysis Cookies: are those that either because they are processed by us or by third parties, allow us to quantify the number of users and thus make the measurement and statistical analysis of the use made by users of the service offered. In order to do this, we analyze your navigation on our website in order to improve the range of products or services we offer you.

HOW TO DISABLE OR DELETE COOKIES
You can allow, block or delete cookies installed on your computer by configuring the settings of the browser options installed on your computer.If you do not accept cookies, the website may not work properly.If you wish to withdraw your consent to this Cookies Policy at any time, you must delete the cookies stored on your computer (computer or mobile device) through the settings and configurations of your Internet browser.Unless you have adjusted your browser settings, our system will create cookies when you visit our Website.

INFORMATION ON THE IDENTIFICATION OF WHO USES COOKIES
The information obtained by the cookies is processed only by the owner of the website who has contracted Google Analytics to provide the service. On its web site you will be able to access its legal conditions.