PRIVACY POLICY OF THE WEBSITE

www.halotech.com

I. PRIVACY POLICY AND DATA PROTECTION In compliance with current legislation, Halotech (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into 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 complies with the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of individuals 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 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 data controller Address: INDUSTRIAL ESTATE ROMICA, C/ 5 BIS, No.15 – PLOT 60C, 02007 ALBACETE, SPAIN

Contact phone:

Contact email: finances@livall.eu

Personal Data Registration In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Halotech, through the forms extended on its pages, will be incorporated and treated in our file in order to facilitate, expedite, and comply with the commitments established between Halotech and the User or to maintain the relationship established in the forms that the latter 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 applies, a record of processing activities is maintained specifying, according to its 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 User’s personal data shall be subject to the following principles set forth 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:

• Lawfulness, fairness, and transparency: User consent will be required at all times after transparent information on the purposes for which personal data is collected.
• Purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
• Data minimization: The personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Accuracy: Personal data must be accurate and always kept up to date.
• Storage limitation: Personal data will only be retained for the time necessary for the purposes of its processing.
• Integrity and confidentiality: Personal data will be processed in a way that ensures its security and confidentiality.
• Proactive responsibility: The data controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data The categories of data processed at Halotech are only identifying 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. Halotech 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. Withdrawing consent shall be as easy as giving it. As a general rule, the withdrawal of consent shall 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 if the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing to which personal data are intended Personal data is collected and managed by Halotech for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining 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 of Halotech, as well as for data extraction, storage, 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 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 information collected.

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: 24, or until the User requests its deletion.

At the time 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.

Recipients of personal data The User’s personal data will not be shared with third parties.

In any case, at the time 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 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 to the lawful processing of their personal data by Halotech. If the individual is under 14 years of age, the consent of their parents or guardians is necessary for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data Halotech undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to ensure the security of personal data and to prevent its destruction, loss, or alteration, whether accidental or unlawful, or unauthorized disclosure or access to said 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, because Halotech 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 inform the User without undue delay when a breach of the security of personal data occurs that is likely to result in a high risk to the rights and freedoms of individuals. In accordance with Article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or processed in another way.

Personal data will be treated as confidential by the data controller, who undertakes to inform and ensure, through 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 derived from the processing of personal data The User has, and may, therefore, exercise against the data controller 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:

• Right of access: This is the User’s right to obtain confirmation of whether Halotech is processing their personal data or not and, if so, to obtain information about their specific personal data and the processing that Halotech has carried out or is carrying out, as well as, among other things, the available information on the origin of such 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 corrected if it is inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): This is the User’s right, whenever current legislation does not establish otherwise, to obtain the erasure of their personal data when it 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 for the processing; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data has been processed unlawfully; the personal data must be erased to comply 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, taking into account the available technology and the cost of its implementation, shall take reasonable measures to inform the controllers who are processing the personal data of the data subject’s request for deletion of any link 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 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; and when the User has objected to the processing.
• Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the data controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Where technically feasible, the data controller shall transmit the data directly to that other controller.
• Right to object: This is the User’s right not to have their personal data processed or to cease processing by Halotech.
• 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 individualized decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights by written communication addressed to the data controller with the reference “GDPR-www.halotech.com“, specifying:

• User’s name, surnames, and a copy of their ID card. In cases where representation is admitted, the 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 card may be substituted by any other valid legal means that prove the identity.
• Request with specific reasons for the request or information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document proving the request made.

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

Postal address: INDUSTRIAL ESTATE ROMICA, C/ 5 BIS, No.15 – PLOT 60C, 02007 ALBACETE, SPAIN

Email: finances@livall.eu

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

Complaints to the supervisory authority In case the User considers that there is a problem or infringement of 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, 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 (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY It is necessary for the User to have read and agree to the conditions regarding 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 implies acceptance of its Privacy Policy.

Halotech 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. Users are advised to 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 April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and 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.