I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation,FundsFinders(hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws that this privacy policy incorporates

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

• 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 Guarantee of Digital Rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving 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 Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for processing personal data

The person responsible for the processing of personal data collected inFundsFindersis:Om Ràfols Cots, with NIF:47119139M(hereinafter, Data Controller). Their contact details are as follows:

Address:arboç street 16 3-6 Vilafranca del Penedes, Barcelona 08720

Contact phone number:+34 634741914

Contact email:recadosylisto@gmail.com

Personal Data Record

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected byFundsFinders, through the forms extended on its pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established betweenFundsFindersand the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or query from the User. 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 is applicable, a record of processing activities is kept that 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 Organic Law 3/2018, of December 5, on the 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 after being fully informed of the purposes for which the personal data is collected.
• Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
• Data minimisation principle: only the personal data collected will be those strictly necessary in relation to the purposes for which they are processed.
• Accuracy principle: personal data must be accurate and always up to date.
• Principle of limitation of the conservation 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 processing.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees their security and confidentiality.
• Proactive accountability principle: The Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data that are processed inFundsFindersThey are only identification data. Under no circumstances are special categories of personal data processed within the meaning 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.FundsFindersundertakes 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 his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not affect 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 if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing of personal data

Personal data is collected and managed byFundsFindersin order to facilitate, expedite and fulfil 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.

Likewise, the data may be used for commercial purposes of personalization, operation and statistics, and activities related to the corporate purpose ofFundsFinders, 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 personal data is obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed; that is, the use or uses that will be given to the information collected.

Personal data retention periods

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:1, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed of the period during which the personal data will be stored or, when that 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

In compliance with 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 processing of their personal data in a lawful manner byFundsFindersIf the data subject is under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

FundsFindersundertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication or access to such data.

However, becauseFundsFinderscannot 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 personal data breach occurs that is likely to entail a high risk for the rights and freedoms of natural persons. Pursuant to Article 4 of the GDPR, a personal data breach is understood to mean any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or to unauthorized communication of or access to such data.

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

Rights arising from the processing of personal data

The User has overFundsFindersand may therefore exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights, against the Data Controller:

• Right of access: It is the User’s right to obtain confirmation of whetherFundsFindersis processing your personal data or not and, if so, obtain information about your specific personal data and the processing thatFundsFindershas made or will make, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned thereof.
• Right to rectification: This is the User’s right to have their personal data modified if it is found to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure («the right to be forgotten»): This is the right of the User, unless otherwise provided by current legislation, to obtain the deletion of his/her personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and there is no other legal basis for this; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the technology available and the cost of its implementation, must adopt reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any links to said personal data.
• Right to restriction of processing: This is the User’s right to limit the processing of his or her personal data. The User has the right to obtain restriction of processing when he or she contests the accuracy of his or her 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 objected to the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
• Right to object: This is the User’s right to prevent the processing of their personal data or to stop the processing of their personal data by third parties.FundsFinders.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualised decision based solely on the automated processing of his or her personal data, including profiling, unless otherwise provided by current legislation.

Therefore, the User may exercise his/her rights by means of written communication addressed to the Data Controller with the reference «RGPD-https://fundsfinders.ai/«, specifying:

• Name, surname of the User and copy of the ID. 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 ID may be replaced by any other legally valid means that accredits the identity.
• Request with the specific reasons for the request or information to which you wish to access.
• Address for notifications.
• Date and signature of the applicant.
• Any document that supports the request you are making.

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

Postal address:arboç street 16 3-6 Vilafranca del Penedes, Barcelona 08720

Email:recadosylisto@gmail.com

Links to third party websites

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

Complaints to the supervisory 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 a supervisory authority, in particular, in the State in which they have their habitual residence, place of work or 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 TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as accept the processing of his/her personal data so that the Data Controller can proceed with the processing in the manner, during the periods and for the purposes indicated. Use of the Website implies acceptance of the Privacy Policy of the Website.

FundsFindersreserves the right to modify its Privacy Policy at its own discretion or as a result of a legislative, jurisprudential or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically to stay abreast of the latest changes or updates.

This Privacy Policy has been 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 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.