1. LAW ON INFORMATION SOCIETY SERVICES AND ELECTRONIC COMMERCE

In compliance with the provisions of Article 10 of Law 34/2002 of July 11, on Information Society Services (L.S.S.I.), the following General Information is provided:

The domain www.nesplora.com (hereinafter « Website ») is registered in the name of GIUNTI NESPLORA, S.L., with its registered office at Avda. de Europa 24 Edf A 1º D, Parque Empresarial La Moraleja, 28108 – Alcobendas (Madrid); a company registered in the Commercial Registry, Volume, Section, Folio, Sheet, entry one, with CIF B01955210, hereinafter referred to as THE OWNER.

2. TERMS OF USE

I. USERS
Accessing and/or using the Website www.nesplora.com grants the person doing so the status of user, fully accepting, from that moment on, without reservation, these general terms and conditions, as well as any specific terms and conditions that may complement, modify, or replace the general terms and conditions with respect to certain services and content of the Website.

II. USE OF THE WEBSITE, ITS SERVICES, AND CONTENT
The user agrees to use the Website and its services and content in compliance with current legislation, good faith, generally accepted practices, and public order.
It is also prohibited to use the Website for illegal or harmful purposes against THE OWNER or any third party, or in any way that may cause harm or prevent the normal operation of the Website.
Regarding the contents (information, texts, graphics, sound and/or image files, photographs, designs, etc.), the following is prohibited:
• Reproduction, distribution, or modification, unless authorized by the legitimate holders or legally permitted.
• Any infringement of THE OWNER’s or legitimate holders’ rights over them.
• Use for any commercial or advertising purposes, other than those strictly permitted.
• Any attempt to obtain the Website’s contents through any means other than those made available to the users or those commonly used on the web, provided they do not harm the Website.

III. UNILATERAL MODIFICATION
THE OWNER may unilaterally and without prior notice modify, whenever deemed appropriate, the structure and design of the Website, as well as modify or eliminate the services, content, and access and/or usage conditions of the Website.

IV. HYPERLINKS
The establishment of any « hyperlink » between a webpage and the Website will be subject to the following conditions:
• Reproduction, either in full or in part, of any services or content of the Website is not permitted.
• Unless with prior and express consent, the webpage establishing the hyperlink will not contain any brand, trade name, establishment signage, denomination, logo, slogan, or other distinguishing marks belonging to THE OWNER.
• Under no circumstances will THE OWNER be responsible for the contents or services made available to the public on the webpage from which the « hyperlink » is made, nor for the information and statements included on them.

V. EXCLUSION OF WARRANTIES AND LIABILITY
THE OWNER does not provide any guarantees nor is it responsible, under any circumstances, for any damages of any nature that may arise from:
• The lack of availability, maintenance, and effective functioning of the Website and/or its services or content.
• The lack of usefulness, adequacy, or validity of the Website and/or its services or content to meet specific needs, activities, results, or expectations of the users.
• The existence of viruses, harmful or malicious programs in the content.
• The receipt, acquisition, storage, distribution, or transmission, by the users, of the content.
• The unlawful, negligent, fraudulent use, or any use contrary to these General Conditions, good faith, generally accepted practices, or public order, of the Website, its services, or content by the users.
• The lack of legality, quality, reliability, usefulness, and availability of services provided by third parties and made available to the users on the Website.
• The failure of third parties to meet their obligations or commitments regarding the services provided to users through the Website.

VI. DURATION
The duration of the service provision for the Website and its services is indefinite.
Notwithstanding the above, THE OWNER reserves the right to interrupt, suspend, or terminate the provision of the Website service or any of the services it includes, under the same terms as set forth in the third condition.

VII. APPLICABLE LAW AND JURISDICTION
These General Conditions will be governed by Spanish law.
GIUNTI NESPLORA, S.L. and the user, expressly waiving any other jurisdiction that may correspond to them, submit to the jurisdiction of the Courts and Tribunals of the user’s domicile for any matters that may arise or actions that may be taken in connection with the provision of the Website service, its services and content, and the interpretation, application, compliance, or breach of the provisions hereof.
In the event that the user resides outside of Spain, GIUNTI NESPLORA, S.L. and the user, expressly waiving any other jurisdiction that may correspond to them, submit to the jurisdiction of the Courts and Tribunals of Alcobendas.

3. UNSUBSCRIBE FROM COMMERCIAL COMMUNICATIONS

In accordance with the Information Society Services Law 34/2002, the user is guaranteed the possibility of ceasing to receive commercial information within a maximum period of one month from the moment they communicate their wish by sending an email to info@nesplora.com.

PRIVACY POLICY

At GIUNTI NESPLORA, S.L., we understand that it is essential to maintain a transparent relationship with you. Therefore, below we present our Privacy Policy, so that you are always properly informed about how we collect and securely process any data you provide us.

Your data will be processed in accordance with current legislation and, in particular, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR) regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data. Also, in relation to Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights.

A thorough reading of our Privacy Policy will provide you with the necessary information to understand how we will handle the data you provide.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

If you, or an authorized person, have provided us with your data, we inform you that GIUNTI NESPLORA, S.L., with CIF: B01955210, is responsible for the processing of your data. This data will be processed in accordance with the applicable regulations on personal data protection.

There may be other parties responsible for the processing of the data we handle. In such cases, we will always inform you about who is responsible for the processing of the data, as well as their identification details.

The Website may include hyperlinks or links that allow access to third-party websites other than www.nesplora.com, and therefore are not operated by GIUNTI NESPLORA, S.L. The owners of such websites will have their own data protection policies, and they are, in each case, responsible for their own data processing and privacy practices.

At GIUNTI NESPLORA, S.L., we are committed to maintaining the confidentiality of personal data and ensuring their security. To this end, we take the necessary measures to prevent their alteration, loss, unauthorized processing, or access, in accordance with the provisions set forth in the regulation.

2. DO WE HAVE A DATA PROTECTION OFFICER?

Yes, due to the nature of the data we process, we have a Data Protection Officer to ensure compliance with current data protection regulations. Our Data Protection Officer is: CONVENCE ABOGADOS, with CIF/NIF: .

You can contact them at giuntinesplora.dpo@convenceabogados.es

3. WHERE DO WE INFORM?

At GIUNTI NESPLORA, S.L., we provide information through the website www.nesplora.com in the section corresponding to the privacy policy. More information is available in the « Legal Notice » section.

4. WHAT PERSONAL DATA DO WE PROCESS?

The personal data we process are: • Those that you voluntarily provide to us. • The data derived from communications you have with us. • Information related to your own browsing in the case of Online Services (IP address or information derived from cookies or similar devices — you can see our Cookie Policy on the website). • Information available in publicly accessible sources, which we can lawfully access. • Data derived from the contractual or pre-contractual relationship you have with us, including your image, always informing you in this case of the possibility of capturing your image. • Data provided by third parties about you, where there is a legitimate basis for doing so or where you have given your consent. • Third-party data that you provide to us, with prior consent from the third party in question.

You can consult more information in the « Activity Log » section of this privacy policy.

5. HOW DO WE PROCESS THE DATA?

At GIUNTI NESPLORA, S.L., we process your personal data always in strict compliance with current legislation. Additionally, we inform you that we have the appropriate technical and organizational measures to ensure an optimal level of security, ensuring that only authorized individuals have access, that we maintain the integrity of your data, preventing any intentional or accidental loss, and that we have strengthened our data processing systems and services.

However, since GIUNTI NESPLORA, S.L. cannot guarantee the invulnerability of the internet or the total absence of hackers or others who may fraudulently access personal data, we are committed to informing you without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data breach means any security breach that leads to the destruction, loss, or accidental or unlawful alteration of personal data transmitted, stored, or processed in any other way, or unauthorized communication or access to such data.

The operations, management, and technical procedures that we perform either automatically or non-automatically, which enable the collection, storage, modification, transfer, and other actions on personal data, are considered personal data processing.

6. WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

The legal basis for the processing of Personal Data will be the contractual or pre-contractual relationship, the employment relationship, or any other basis required for data processing, such as express consent.

7. HOW DO WE MANAGE ELECTRONIC COMMUNICATIONS?

In accordance with the provisions of Law 34/2002 of July 11, on Information Society Services and Electronic Commerce, and Directive 2002/58/EC, we inform you that you may receive communications and commercial information through this electronic communication system (emails, automated response messages from forms, and other communication systems) when you have granted your consent or when it concerns commercial communications about products or services similar to those previously provided by the data controller.

If you do not wish to receive such communications, you can notify us via this same means by indicating « UNSUBSCRIBE FROM COMMERCIAL COMMUNICATIONS » in the subject line, so that your personal data is removed from our database. Your request will be processed within one month from its submission. If we do not receive an explicit response from you, we will assume that you accept and authorize our entity to continue sending these communications.

In the case of receiving such communications, we inform you that the messages are addressed exclusively to the intended recipient and may contain privileged or confidential information. If you are not the designated recipient, we notify you that the use, disclosure, and/or copying without authorization is prohibited under current legislation.

8. HOW LONG DO WE KEEP YOUR DATA?

Personal data related to individuals collected by GIUNTI NESPLORA, S.L. by any means will be kept until the interested party requests their deletion. Also, they will be kept as long as the relationship that led to the data processing remains, always respecting legal retention periods. Once this period ends, the personal data will be deleted from all systems of GIUNTI NESPLORA, S.L.

9. WILL YOUR DATA BE COMMUNICATED TO THIRD PARTIES?

There will be no transfer, transmission, or sharing of personal data, except for those already informed, unless it is due to a legal obligation. If requested by the Public Administration or Autonomous Institutions in the scope of the functions expressly assigned to them by law, we will transmit your data.

In the event of a transfer, transmission, or sharing of personal data outside the cases previously stated, you will be informed beforehand so that, if applicable, you can grant your consent.

However, to properly organize ourselves, maintain good operations, and procedures that guarantee good management, GIUNTI NESPLORA, S.L. may need to hire the services of advisors, professionals, or other service companies to process data under our instructions.

This third-party processing is regulated by a contract in writing or another legally accepted form, ensuring that the data processor processes the data according to our instructions and does not use or disclose it for any purpose other than specified in the contract, nor share it, even for its storage, with other individuals.

10. WHAT ARE YOUR RIGHTS?

Data protection legislation grants you the following rights:

• Right of access: The right to obtain confirmation of whether GIUNTI NESPLORA, S.L. is processing your personal data, and if so, to obtain information about your specific personal data and the processing that GIUNTI NESPLORA, S.L. has performed or will perform, including, among other things, the origin of the data and the recipients of any communications made or expected regarding those data.

• Right of rectification: The right to have your personal data corrected if they are inaccurate or, considering the purpose of the processing, incomplete.

• Right of deletion (« right to be forgotten »): The right to obtain the deletion of your personal data when they are no longer necessary for the purposes for which they were collected or processed; if you have withdrawn consent for processing and no other legal basis exists; if you oppose processing and there is no other legitimate reason to continue; if the data were processed unlawfully; if the data must be deleted to comply with a legal obligation; or if the data were obtained from a direct offer of information society services to a minor under 14 years old. In addition to deleting the data, the data controller, considering available technology and the cost of its implementation, must take reasonable steps to inform those processing the personal data about the request for deletion of any links to those personal data.

• Right to restriction of processing: The right to limit the processing of your personal data. You have the right to obtain the restriction of processing when you dispute the accuracy of your personal data; when the processing is unlawful; when the data controller no longer needs the data, but you need it to make claims; or when you have objected to processing.

• Right to data portability: If processing is carried out by automated means, you have the right to receive your personal data from the data controller in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the data controller will directly transmit the data to that other controller.

• Right to object: The right to prevent or stop the processing of your personal data by GIUNTI NESPLORA, S.L.

• Right not to be subject to decisions based solely on automated processing, including profiling: The right not to be subject to an individualized decision based solely on automated processing of your personal data, including profiling, unless the current legislation provides otherwise.

If you would like more information regarding the processing of your data, to rectify any inaccuracies, object to and/or limit any processing you believe is unnecessary, or request the cancellation of processing when the data are no longer needed, you can contact GIUNTI NESPLORA, S.L. in writing at Avda. de Europa 24 Edf A 1º D Parque Empresarial La Moraleja, 28108 – Alcobendas (Madrid), or by email at info@nesplora.com.

• Your communication should include the following information: Full name, request details, address, and proof of identity.

• The exercise of rights must be carried out by the user themselves. However, they may be exercised by an authorized person as the user’s legal representative. In that case, the documentation proving the representation must be provided.

We also want to inform you that you can withdraw the consent given without affecting the lawfulness of processing carried out prior to the withdrawal, by sending your request to the same address mentioned above. In this case, you should include a copy of your ID card or a document proving your identity.

If you consider that there is an issue or violation of the current regulation in the way your personal data is being processed, you have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the country of your habitual residence, workplace, or place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/) – C/ Jorge Juan, 6 28001-Madrid – FAX: 914483680- TEL: 901 100 099- E-mail: ciudadano@agpd.es.

11. WHAT IS THE PURPOSE AND LEGAL BASIS FOR THE PROCESSING OF DATA, AND HOW LONG WILL THE DATA BE KEPT?

Below, we detail the purposes of the data processing carried out by one or all of the Data Controllers listed above.