I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, Zafirion (hereinafter also referred to as the Website) is committed to adopting the necessary technical and organizational measures according to the level of security appropriate to the risk of the collected data.

Laws incorporated in this privacy policy

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

• Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and 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 Regulation developing 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).

Users outside the European Union should note that their personal data will be processed in accordance with the GDPR. However, the rights and protections granted under local legislation in their country may differ.

Data Controller Identification

The data controller of the personal data collected on Zafirion is: Andrés García-Ochoa González, NIF: 03915816C (hereinafter, Data Controller). The Data Controller’s contact details are:

Contact email: info@zafirion.com

Personal Data Registration

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected through forms on Zafirion, will be stored and processed in our files to facilitate, expedite, and fulfill the commitments established between Zafirion and the User, maintain the relationship established through the forms, or respond to a request or query. Except as provided in Article 30.5 of the GDPR, a record of processing activities is maintained specifying the purposes, processing activities, and other circumstances established in the GDPR.

Principles applicable to personal data processing

The processing of the User’s personal data will be subject to the following principles established in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

• Lawfulness, fairness, and transparency: The User’s consent will be obtained at all times, after providing full and transparent information regarding the purposes for which personal data is collected.
• Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
• Data minimization: Only personal data strictly necessary for the intended purposes will be collected.
• Accuracy: Personal data must be accurate and kept up to date. Every reasonable step must be taken to ensure that inaccurate personal data is corrected or deleted without delay.
• Storage limitation: Personal data will be kept in a form that permits identification of the User for no longer than is necessary for the purposes for which the personal data is processed.
• Integrity and confidentiality: Personal data will be processed securely to ensure confidentiality.
• Accountability: The Data Controller will be responsible for, and able to demonstrate, compliance with all the principles listed above.

Categories of personal data

The categories of personal data processed by Zafirion include basic identification and contact information. No special categories of personal data are processed under Article 9 of the GDPR.

Legal basis for processing personal data

The legal basis for processing personal data is consent. Zafirion undertakes to obtain the User’s explicit and verifiable consent for processing personal data for one or more specific purposes.

The User has the right to withdraw consent at any time. Withdrawing consent is as easy as giving it. As a general rule, withdrawal of consent will not affect the use of the Website.

When the User provides personal data through forms for inquiries, information requests, or other purposes related to the Website, they will be informed if completing certain fields is mandatory for the proper completion of the requested action.

Purpose of personal data processing

Personal data collected by Zafirion is processed to facilitate, expedite, and fulfill the commitments established between the Website and the User, maintain the relationship established through forms completed by the User, or respond to requests or inquiries.

Likewise, the data may be used for commercial purposes such as personalization, operational and statistical purposes, and activities inherent to the corporate purpose of Zafirion, as well as for data extraction, storage, and marketing studies to tailor the content offered to the User, and to improve the quality, functionality, and navigation of the Website.

The User will be informed at the time of data collection of the specific purpose(s) for which personal data will be processed.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of processing and, in any case, only for the following period: or until the User requests deletion.

At the time personal data is collected, the User will be informed of the period during which their personal data will be retained or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

User personal data will not be shared with third parties.

Users will be informed about recipients or categories of recipients of their personal data when it is collected.

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of the Spanish Organic Law 3/2018 of December 5, on Personal Data Protection and guarantee of digital rights, only individuals over 14 years old may give their consent for the lawful processing of their personal data by Zafirion. If the individual is under 14 years old, parental or guardian consent will be required for the processing, and it will only be considered lawful to the extent that such consent has been granted.

Confidentiality and security of personal data

Zafirion is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, to ensure the security of personal data and to prevent accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access to such data, whether transmitted, stored, or otherwise processed.

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

However, as Zafirion cannot guarantee the absolute invulnerability of the internet or the total absence of hackers or other parties who may fraudulently access personal data, the Data Controller commits to informing the User without undue delay if a personal data security breach occurs that is likely to pose a high risk to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data security breach is understood as any breach of security that causes accidental or unlawful destruction, loss, or alteration of transmitted, stored, or otherwise processed personal data, or unauthorized disclosure or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to ensuring and guaranteeing, by legal or contractual obligation, that this confidentiality is respected by their employees, associates, and any person to whom the information is made accessible.

Rights arising from the processing of personal data

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

• Right of access: This is the User’s right to obtain confirmation of whether Zafirion is processing their personal data and if so, to obtain information about their specific personal data and the processing carried out or being carried out by Zafirion including, among other things, information on the origin of such data and the recipients of communications made or intended regarding them.
• Right to rectification: This is the User’s right to have their personal data corrected if it is inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“right to be forgotten”): This is the User’s right, except where applicable law provides otherwise, to obtain the erasure of their personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis; the User objects to the processing and there is no other legitimate reason to continue it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained as part of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable steps to inform other controllers processing the personal data about the request of the data subject to erase any links to such personal data.
• Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest 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; and when the User has objected to the processing.
• Right to data portability: Where the processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit it to another controller. Whenever technically feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: This is the User’s right to prevent the processing of their personal data or to have such processing ceased by Zafirion.
• 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 individual decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by applicable law.

Users may exercise their rights by sending a written request to the Data Controller with the reference “GDPR-https://zafirion.com“, including:

• The User’s full name and a copy of their ID. In cases where representation is allowed, identification of the person representing the User by the same means, as well as the document accrediting the representation, will also be required. The photocopy of the ID may be replaced by any other legally valid means of proving identity.
• The request with the specific reasons for the request or the information to which access is sought.
• Address for notifications.
• Date and signature of the requester.
• Any document that supports the request being made.

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

Email: info@zafirion.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Zafirion, and therefore not operated by Zafirion. The owners of such websites will have their own data protection policies and will be responsible, in each case, for their own files and privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or a violation of the applicable regulations regarding the processing of their personal data, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the country where they have their habitual residence, place of work, or the location of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es ).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed accordingly, within the specified timeframes and for the indicated purposes. The use of the Website implies acceptance of its Privacy Policy.

These terms are governed by Spanish law, and any dispute arising from the processing of personal data or orders will be subject to the competent Spanish courts, unless the applicable local legislation indicates otherwise.

Zafirion reserves the right to modify its Privacy Policy at its own discretion, or due to legislative, jurisprudential, or doctrinal changes from 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 consult this page periodically to stay informed 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 with Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.