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PRIVACY POLICY OF THE WEBSITE

PRIVACY POLICY OF THE WEBSITE

www.frepat.com

I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, FREPAT Urban Equipment (hereinafter, also the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate security level to the risk of the collected data.

Laws incorporated into this privacy policy

This privacy policy is adapted to Spanish and European regulations on personal data protection on the internet. Specifically, it complies with the following regulations:

The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).

Royal Decree 1720/2007, of December 21, approving the Regulations implementing 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 the personal data collected at FREPAT Urban Equipment is: FREPAT SL, with tax ID number B63837686 and registered in the Commercial Register of Barcelona with the following registration details: Volume 1, whose representative is: Marc Cortés Navas (hereinafter, Data Controller). The contact details are as follows:

Address: Pol. Ind. Cal Batlle, del Prat de Can Ducet nº17, Edifici B 17400 Breda, Girona

Contact telephone number: 934 180 912

Contact email: admin@frepat.com

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by FREPAT Urban Equipment through the forms provided on its pages will be incorporated and processed in our file in order to facilitate, streamline and fulfill the commitments established between FREPAT Urban Equipment and the User, or to maintain the relationship established in the forms that they fill out, or to respond to a request or inquiry. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR applies, a record of processing activities is kept which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

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

Principle of lawfulness, fairness and transparency: the User’s consent will always be required prior to completely transparent information about the purposes for which personal data is collected.

Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.

Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.

Principle of accuracy: personal data must be accurate and kept up-to-date.

Principle of storage limitation: 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 processing.

Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its security and confidentiality.

Principle of proactive responsibility: the controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed in FREPAT Urban Equipment are only identifying data. Under no circumstances are special categories of personal data processed in the sense of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. FREPAT Urban Equipment 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 will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed in case the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of processing personal data

Personal data is collected and managed by FREPAT Urban Equipment with the aim of facilitating, speeding up and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms filled out by the latter, or to attend a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operation and statistics, and activities related to the corporate purpose of FREPAT Urban Equipment, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to 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 processing to which the personal data will be destined; that is, the use or uses that will be given to the collected information.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 10 years, 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 retained or, when this is not possible, the criteria used to determine this period.

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.

Personal data of minors

Respecting the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by FREPAT Urban Equipment. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

FREPAT Urban Equipment undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, in order to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss, alteration, transmission, or unauthorized access or disclosure of such data.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since FREPAT Urban Equipment cannot guarantee the inviolability of the internet or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to promptly inform the User when a breach of personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Pursuant to Article 4 of the GDPR, a breach of personal data security means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.

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

Rights derived from the processing of personal data:

The User has the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, over FREPAT Urban Equipment, and may, therefore, exercise them against the Data Controller:

Right of access: The User has the right to obtain confirmation from FREPAT Urban Equipment whether or not their personal data is being processed, and if so, obtain information about their specific personal data and the processing carried out or to be carried out by FREPAT Urban Equipment, as well as, among other things, information available about the origin of such data and the recipients of communications made or planned with them.

Right of rectification: The User has the right to request the modification of their personal data that are inaccurate or, taking into account the purposes of the processing, incomplete.

Right to erasure (“right to be forgotten”): The User has the right, whenever current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue it; the personal data have been processed unlawfully; the personal data must be erased to comply with a legal obligation; or the personal data have 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, taking into account the available technology and the cost of its implementation, must take reasonable measures to inform the controllers who are processing the personal data of the interested party’s request for the deletion of any link to that personal data.

Right to restriction of processing: The User has the right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they challenge the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; or the User has objected to the processing.

Right to data portability: If the processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format and to transmit them to another Data Controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.

Right to object: The User has the right to object to the processing of their personal data or to stop the processing of such data by FREPAT Urban Equipment.

Right not to be subject to a decision based solely on automated processing, including profiling: The User has the right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, except where current legislation establishes otherwise.

Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-www.frepat.com”, specifying:

Name, surname of the User, and a copy of their ID. In cases where representation is accepted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the ID may be replaced by any other valid means in law that proves the identity.

Request with specific reasons for the request or information to be accessed.

Address for notifications.

Date and signature of the applicant.

Any document accrediting the request.

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

Postal address: Pol. Ind. Cal Batlle 17400 Breda, Girona

Email: admin@frepat.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party web pages that are different from FREPAT Urban Equipment and therefore not operated by FREPAT Urban Equipment. The owners of such websites will have their own data protection policies, and they will be responsible for their own files and privacy practices in each case.

Complaints to the supervisory authority

If the User believes that there is a problem or violation of the current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES IN THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the data controller can proceed with it in the manner, for the periods and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

FREPAT Urban Equipment reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically consult this page to be aware of the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

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