I. PERSONAL DATA CONTROLLER

The Data Controller of personal data is: Pratia Spain SL

II. DATA PROTECTION OFFICER

In all matters regarding the processing of personal data and the exercise of rights related to data processing, you may contact the Data Protection Officer, Matías Martínez, directly via  – e-mail adress: privacy@pratia.com / dpo.spain@pratia.com.

III. PURPOSES AND BASIS OF PROCESSING

Your personal data will be processed for the following purposes and on the basis of:

• taking action to conclude and perform a contract to which you are a party – pursuant to art. 6 sec. 1 lit. b GDPR,

• taking actions related to striving to conclude, and then concluding and implementing a contract with a contractor, contact with a contractor where you are employed and/or whom you represent – pursuant to art. 6 sec. 1 lit. f GDPR,

• fulfillment of legal obligations related to, among others, with: paying taxes, including keeping and storing tax books and documents related to keeping tax books and storing accounting documents. The legal basis for data processing are legal obligations resulting from tax regulations (Tax Ordinance, Value Added Tax Act, Corporate Income Tax Act), accounting regulations (Accounting Act) – pursuant to art. 6 sec. 1 lit. c GDPR,

• consideration of complaints, service, investigation and defense of possible claims – based on the legitimate interest of PRATIA- in accordance with art. 6. sec. 1 lit. f GDPR,

• direct marketing – based on the legitimate interest of PRATIA in particular the possibility of presenting products and services offered by PRATIA to contractors. – based on Article. 6 sec. 1 lit. f GDPR,

• statistical and analytical – based on the legitimate interest of PRATIA, in particular the possibility of creating internal sales reports and lists regarding the history of cooperation – pursuant to art. 6 sec. 1 lit. f GDPR,

• survey of opinions on the services provided, in particular the need to improve the quality of services provided by PRATIA – based on Article. 6 sec. 1 lit. f GDPR.

IV. SOURCES OF DATA OBTAINING

Your personal data may have been obtained by the Data Controller:

1. directly from you,

2. some information about you may have been obtained from publicly available sources (e.g. from your websites),

3. made available by the contractor with whom you have an employment contract or a civil law contract.

In connection with the performance of the contract, the Data Controller will process your personal data to the extent necessary, in particular: name(s), surname, business e-mail address, business telephone number, position, place of employment/company of business.

V. PERSONAL DATA RECIPIENTS

Your personal data may be transferred by PRATIA to the entities cooperating with PRATIA (recipients), and in particular IT service providers and entities providing the following services: accounting and financial, archiving, delivery of correspondence and parcels, legal, debt collection – where such entities process data on the basis of an agreement with the controller and only in accordance with the controller’s instructions.

VI. PERIOD OF DATA STORAGE

Your personal data will be stored for the period of:

1. the validity of the contract with the counterparty,

2. until the data processing obligations under the law expire,

3. until the statute of limitations for any claims arising from this contract,

4. until an effective objection is filed.

VII. RIGHTS OF PERSONS WHOM THE DATA CONCERN

You have the following rights related to the processing of your personal data:

• the right to withdraw consent. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal,
• the right to access your data,
• the right to rectify your personal data ,
• the right to delete your personal data ,or limit the processing of them,
• the right to transfer your data, i.e. the right to receive your personal data from PRATIA in a structured, commonly used, machine-readable IT format. You can send these data to a different data controller or request that PRATIA send the data to a different controller. However, PRATIA will do so only if such a message is technically possible. The right to transfer your personal data applies only to the data processed on the basis of your consent or a contract with you,
• the right to lodge an objection – in the cases where PRATIA processes your personal data on the basis of its legitimate interest. You may lodge an objection because of your particular situation at the e-mail address: privacy@pratia.com or the address of the registered office of PRATIA with a note «Data Protection Officer».

VIII. RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with the Spanish Data Protection Agency.

In the event thar yoy understand that your rights have been neglected by our entity, you can make a claim at the Spanish Data Protection Agency, through any of the following means:

• Sede electrónica: www.agpd.es
• Postal address:

Agencia Española de Protección de Datos
C/ Jorge Juan, 6
28001-Madrid

• Telephone:

Telf. 901 100 099

Telf. 91 266 35 17

IX. INFORMATION ON THE REQUIREMENT OF / VOLUNTARY PROVISION OF DATA

The providing of your personal data is voluntary. However, it is necessary for the entering into and performance of a contract with a contractor, and for the performance of justified data controller’s tasks.

X. INFORMATION ON TRANSFERRING PERSONAL DATA OUTSIDE THE EEA

Your personal data will be transferred outside the EEA, in compliance with the conditions of Chapter V of the GDPR.

XI. INFORMATION ON AUTOMATED PROCESSING, INCLUDING THE PROFILING. Your personal data is not subject to automated processing, including the profiling.