LEGAL WARNING

In compliance with the provisions of Law 34/2002 of July 11, of Information Society Services and Electronic Commerce (LSSICE), The following legal aspects are reported:

Identification of the web: www.aptabel.com Responsible for the web: GASPAR BERBEL / ASSERTIS, SL Address: Agramunt 31 1-2 08023 Barcelona Contact email: info@aptabel.com Tel.: 934 153 530 Fiscal Data: 46601138X / B63041644

PRIVACY POLICY

USER ACCEPTANCE

This document (hereinafter called "PRIVACY POLICY") is intended to regulate the use of the web space that APTABEL makes available to (www.aptabel.com)

The intellectual property rights of this web space, its source code, the databases and the different elements it contains are the property of those responsible for APTABEL, to whom corresponds the exclusive exercise of exploitation of the rights of the website itself and, especially, those of reproduction, distribution, public communication, maintenance and transformation.

The use of the web space for a third party attributes the condition of user and implies the complete acceptance of this user of each and every one of the conditions established in this Privacy Policy.

CORRECT USE OF THE WEB SPACE

The user agrees to use the web space, content and services in accordance with the Law, this Privacy Policy, good practices and public order. In the same way, the user undertakes not to use the web space or the services provided through it for purposes or effects that are illicit or contrary to the content of this Privacy Policy, that harm the interests or rights of third parties, or that in any way it may be damaged, disable it, deteriorate the web space itself or its services or prevent other users from using the web space satisfactorily.

Likewise, the user expressly agrees not to destroy, alter, disable or, in any other way, damage data, programs or electronic documents and others found in this web space.

The user agrees not to obstruct the access of other users to the service through the massive consumption of computer resources through which APTABEL provides the service, as well as not taking actions that damage, interrupt or generate errors in the aforementioned systems.

The user agrees not to introduce programs, viruses, macro instructions, applets, controls of any kind or any other logical device or sequence of characters that cause or may cause any type of alteration in the computer systems of APTABEL or third parties or, where appropriate, violate the rights of intellectual or industrial property.

The user undertakes not to misuse the information, messages, graphics, drawings, sound and / or image files, photographs, programs and, in general, any kind of material accessible through this website or the services offered.

APTABELConsequently, it also declines all responsibility derived from the damages that any visitor to this web space may suffer in its technological resources (computer or telematic) as a result of the production of any of the circumstances or events mentioned in the previous paragraph. Equally, APTABEL does not guarantee that the web space and the server are free of viruses and is not responsible for damages caused by access to the web or the inability to access.

APTABEL is not responsible for the information that can be obtained through links to external systems from this web space.

INTELLECTUAL AND INDUSTRIAL PROPERTY

This web space and all its contents, including texts, documents, photographs, drawings, graphic representations, databases, computer programs, as well as logos, brands, commercial names and other distinctive signs are property of APTABEL or from third parties that have authorized you to use it.

All rights reserved.

LIABILITY REGIME

Responsibility of APTABEL for the use of the web

The user is solely responsible for the infractions that may be incurred and for the damages that may be caused or caused by the use of this web space on their part. APTABEL is exempt from any liability that may arise from the actions of the user.

The user will be solely responsible for any claim or legal, judicial or extrajudicial action initiated by third parties against APTABEL based on the use of the web space by the user. Where appropriate, the user will assume all expenses, costs and compensation claimed from APTABEL due to claims or legal actions attributed to it.

Responsibility of APTABEL for the operation of the web

APTABEL excludes any liability that may arise from transfers, omissions, interruptions, undesirable interference, telecommunications deficiencies, computer viruses, telephone breakdowns or disconnections in the operational functioning of the electronic system, motivated by causes other than APTABEL

Responsibility of APTABEL for links from the web

APTABEL declines all responsibility regarding the information (content) or risks (technical, moral or economic damages) that are outside the web space and which can be accessed by link from it; since the function of the links that appear is only to inform about a specific topic.

COMMITMENT TO DATA PROTECTION AND COMPLIANCE OF THE LSSICE

In compliance with the RGPD (General Data Protection Regulation) and Organic Law 3/2018 on the Protection of personal data and guarantee of digital rights,  APTABEL informs users that the personal data they provide when using the forms or contract requirements will be collected in files that are the responsibility of APTABEL and they will be treated in order to be able to provide and inform about the services or products that APTABEL offers. The fact of filling in a form on this web space implies that the user acknowledges that the information and personal data that he indicates to us are his, exact and true.

  1. Who is responsible for the processing of your personal data?

Responsible for the treatment: APTABEL

Email: info@aptabel.com

  1. What are the purposes to continue treating your personal data?

We process the personal data of our contacts, clients and suppliers in order to manage the legal and commercial relationship with our organization and, especially, the legislative aspects related to consulting, publications, training and other similar services, contractual aspects, sending information about our organization, campaigns or events and sending informative and commercial communications (including electronic means).

  1. How long will we keep your personal data?

Personal data will be kept for a period of six (6) years, in accordance with current accounting regulations and, if applicable, for ten (10) years according to the regulations on the prevention of money laundering.

In any case, APTABEL will keep your personal data as long as they are necessary for the contractual provision of our relationship, unless you request its deletion. Likewise, it will keep them for the period of time necessary to comply with the legal obligations that correspond in each case according to the type of data.

  1. What is the legitimacy for the processing of your personal data?

The legitimate basis for the processing of personal data is the mutual interest and consent of the user.

  1. To which recipients will your personal data be communicated?

The data may only be communicated to third-party organizations linked to APTABEL in the field of managing its products and / or services for the same purposes referred to above, as well as the competent Public Administrations, when required by current regulations.

The staff of APTABEL who have authorized access rights in accordance with the internal security structure of APTABEL, can access your personal data with the objectives and purposes described in this Privacy Policy. All the personnel involved have been trained and informed of their responsibilities in this regard and sign the corresponding confidentiality agreement. Likewise, third-party organizations whose intervention is required and / or necessary for the proper management of the provision of the service can access your data.

APTABEL has established contracts or contractual agreements and security measures with third parties, to guarantee the adequate level of security and protection of personal data throughout the related chain.

  1. What are your rights in relation to your personal data?

You can request access, rectification, deletion, limitation to treatment, portability and opposition to the processing of your personal data at any time.

You can revoke your consent to the sending of commercial communications and exercise the rights referred to above, by sending an email to info@aptabel.com accompanied by documentary proof of your identity. With the exception that you have already indicated it to us previously through the unsubscribe option that is at the bottom of the electronic shipments, in which case, we already have such information.

If you do not get a satisfactory answer and want to make a claim or obtain more information regarding any of these rights, you can contact the Spanish Data Protection Agency (www.agpd.es).

  1. What is the relationship of stored personal information?

The basic identification and relationship data are kept for sending proposals, commercial information, to create invoices, such as name, shipping address, NIF / CIF, bank account number, if direct debit is required.

  1. What is the data storage / availability / backup policy and its location?

No information is deleted, unless deletion is requested by the user and this deletion proceeds (see point 3). It is always available, although it may be blocked for informational marketing / commercial shipments, if the rights of deletion, limitation to treatment or opposition by the user have been exercised.

Backup copies of the servers that contain data are made, duly controlled and guarded.

  1. What is the privacy and security policy of the information and its access?

Access to the database is protected by username and password.

In the case of remote access, this is done via VPN connection and SSL protocol

  1. What is the Policy for responding to security incidents and impact analysis?

APTABEL has adopted appropriate technical and organizational protection measures and these measures have been applied to personal data affected by the potential breach of personal data security. There is no access to customer / user data for people who are not authorized to access it.

APTABEL has carried out and keeps updated a Risk Analysis of the vulnerability of personal data and its impact on the security of the privacy of customers / users.

  1. What is the policy for deleting information in the event of termination of service?

APTABEL deactivate the accounts of customers / users who decide to unsubscribe and who have exercised their right to deletion. In this case, the customer / user data will be blocked and kept for the time required by regulations, exclusively to account for the legal obligations that justify the past relationship between the parties.

  1. Who is our Data Protection Security Officer?

APTABEL has appointed an RS (Data Security Manager), in accordance with current legislation, in order to ensure the correct functioning of this Privacy Policy and to ensure that its requirements are preserved in relation to the personal data of internal users and external to the organization. You can contact our Data Security Manager at info@aptabel.com

If APTABEL identifies a personal data security breach, users will be notified as soon as possible in relation to it and, in the event of a significant risk, the competent authority will also be notified.

The registered user retains at all times the possibility of exercising their rights of access, rectification, opposition, deletion, limited treatment, portability or opposition to the treatment of their data. Likewise, and in accordance with Law 34/2002, of July 1, on services of the information society and electronic commerce, you can revoke at any time the consent given to the receipt of commercial communications. In case of doubt, as well as for exercising the aforementioned rights, you can contact APTABEL by email info@aptabel.com

APPLICABLE LEGISLATION AND JUDICIAL JURISDICTION

Any controversy arising in the interpretation or execution of this Privacy Policy will be interpreted based on Spanish legislation. Likewise, APTABEL Through their legal representation and the user, they renounce any other jurisdiction and submit to that of the courts and tribunals of the user's domicile for any controversy that may occur. The case that the user has his domicile outside of Spain APTABEL and the user submit to the courts and tribunals of the city of Barcelona.