LEGAL ADVICE AND PRIVACY POLICY

In compliance with current legislation, Ubliz (hereinafter referred to as Website) commits to adopt technical measures and organizational requirements, according to the level of security appropriate to the risk of the data collected.

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Laws incorporated in this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it respects the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, about the protection of natural persons with regard to the processing of personal data and the free circulation of these data (GDPR).
• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for processing personal data

The person responsible for processing personal data collected in Ubliz is: UBLIZ SYSTEMS, S.L. with NIF: B10923456 and registered in: Mercantile Registry of Seville. Their contact details are as follows:

Address: Glorieta Aníbal González s/n, CP 41940 Tomares (Seville - Spain)

Contact email: info@ubliz.com

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Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Ubliz, through the extended forms on its pages, will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between Ubliz and the User or the maintenance of the relationship that is established in the forms that he fills out, or to attend to a request or query of the same. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD is applicable a record of treatment activities is maintained that specifies, according to its purposes, the treatment activities carried out and the other circumstances established in the RGPD.

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Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles contained in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, of Protection of Personal Data and guarantee of digital rights:

• Principle of legality, loyalty and transparency: the User's consent will be required at all times prior to completely transparent information on the purposes for which the personal data is collected.
• Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.
• Accuracy principle: personal data must be exact and always updated.
• Principle of limitation of the retention period: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its treatment.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied..

Categories of personal data

The categories of data that are processed in Ubliz are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

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Legal basis for personal data processing

The legal basis for personal data processing is consent. Ubliz undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On the occasions in which the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory. because they are essential for the proper development of the operation performed.

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Purposes of the treatment to which the personal data is destined

The personal data is collected and managed by Ubliz in order to be able to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to respond to a request or query.

In addition, the data may be used for a commercial personalization, operational and statistical purpose, and activities of the corporate purpose of Ubliz, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

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Periods of retention of personal data

Personal data will only be holded for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 6 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

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Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

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Secrecy and security of personal data

Ubliz is commited to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent destruction , accidental or unlawful loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

However, because Ubliz cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a violation of the security of personal data that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, a breach of the security of personal data is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform of and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible information.

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Rights derived from the personal data processing

The user has the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data against the Data Controller and guarantee of digital rights:

• Right of access: It is the User's right to obtain confirmation of whether or not Ubliz is treating their personal data and, if so, obtain information about their specific personal data and the treatment that Ubliz has made or carried out, as well as, among other things, the information available on the origin of such data and the recipients of the communications made or planned thereof.
• Right of rectification: It is the User's right to modify their personal data that turns out to be inaccurate or incomplete according to the purposes of the treatment.
• Right of deletion ("the right to be forgotten"): It is the User's right to delete their personal data when they are no longer necessary for the purposes for which they were collected or treated; the User has withdrawn their consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller must take reasonable measures to inform those responsible for processing the personal data of the interested party's request to delete any link to those personal data.
• Right to limitation of treatment: It is the User's right to limit the treatment of their personal data. The User has the right to obtain the limitation of the treatment when he contests the accuracy of his personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
• Right to data portability: In the event that the treatment is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured format, of common use and mechanical reading, and to transmit them to another person in charge of the treatment. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right of opposition: It is the User's right not to carry out the processing of their personal data or to stop its processing by Ubliz.
• Right not to be the subject of a decision based solely on automated processing, including profiling: It is the User's right not to be the subject of an individualized decision based only on the automated processing of their personal data, including profiling existing, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "RGPD-www.ubliz.com", specifying:

• Name, surnames of the User and a copy of the DNI. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other legally valid documents that proves the identity.
• Request with the specific reasons for the request or information to which you want to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request made.

This request and any other attached document may be sent to the following address and/or email:

Postal address: Glorieta Aníbal González s/n, Module 313, CP 41940 Tomares (Seville - Spain)

Email: info@ubliz.com

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Links to third-party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Ubliz, and therefore are not operated by Ubliz. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

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Claims before the control authority

In the event that the User considers that there is a problem or infringement of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with an authority. of control, in particular, in the State in which he has his habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (https://www.aepd.es/).

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