PRIVACY POLICY

EFFECTIVE AS OF MAY 17, 2018

This website is managed by PROMOSISTEM (Doley Craw Associats, sl) on behalf of us and our Group.

Your privacy

We understand that when you choose to provide us with information about yourself, you trust us to act responsibly. This privacy notice explains who we are, how we collect, share and use personal information about you and how you can exercise your privacy rights.

This affects the personal information we collect through the website or when we enter into a relationship, potential or not, with you (or your company) as a supplier, customer or business partner.

What do we do?

We are a company dedicated to the design and development of exclusive business gifts for the evolution of our costumers’s brands. For more information about us, please refer to the section of our website: www.promosistem.com.

What information we collect?

Depending on your relationship with PROMOSISTEM, we may collect personal information about you which, broadly speaking, may fall into the following categories:

Information you voluntarily provide to us

Information about the website. You can visit our website without providing us with any information about yourself. However, in some situations we may ask you to provide us with some personal information. For example, you may be interested in signing up to receive our emails, want to read research reports, attend an event or participate in an online forum that we provide to you from time to time, or register for an account with us online, or contact us via the website (in which case we will collect information such as your name, email address, organization, country, zip code, title, phone number(s), comments or questions, as well as your username and password).

When we receive your personal information, we will treat it securely, legitimately and honestly.

- Candidates. When you contact us regarding employment opportunities at PROMOSISTEM, we collect some information about you as part of the selection (and, hopefully, hiring) process. Further information can be obtained from marketing@promosistem.com.

- Information related to the position of the client, supplier or business partner, or their representatives (such as position, responsibilities, department, academic background or professional experience);

- Financial information (such as information about financial accounts of individuals related to a particular business) or proprietary information relating to those individuals if necessary to make payments or meet contractual obligations or for other related and necessary purposes.

- Tele-surveillance images / access control. We may implement telemonitoring and/or access control procedures in POMOSISTEM's offices (such as the processing of telemonitoring images of visitors and/or personal information, such as name, organisation and time of access), for security and law enforcement purposes, to exercise, establish or defend the rights or protect the fundamental interests of any person.

Information automatically collected

When you visit our website, we may collect certain information automatically from your device. In some countries, including some in the European Economic Area, this information may be considered personal information under current data protection legislation.

Specifically, the information we automatically collect may include information such as your IP address, device type, cookie identifier, browser type, wide geographical area (e.g. country or city) or other technical information. We may also collect information about how your device has interacted with our website, including the pages you have accessed and the links you clicked. The collection of this information allows us to better understand the visitors who visit our website, where they come from and what content on our website is of interest to them.

We use this information to conduct internal analysis and to improve the quality, relevance and experience of our website for our visitors. Some of this information may be collected through the use of cookies and similar tracking technologies, including web beacons. For more information about the types of cookies we use, why we use them, and how you can control your use of them, please see our Cookies Policy. Ask for it at: marketing@promosistem.com.

Information we obtain from other third parties

In order to comply with various regulations, or to perform various background checks according to our internal requirements (where permissible and in accordance with applicable law), we may sometimes receive personal information from you from third party sources, such as credit check databases, databases of politically exposed persons, parties denied by the government, sanctions and watch lists, your employer, other real estate institutions or companies, such as real estate agents, buyers, suppliers, borrowers, creditors, architects, engineers, experts, developers, owners, tenants and financial institutions, and online databases or public records.

We will only obtain this information when we have verified that these third parties have your consent or are legally authorized, or have been asked to disclose your personal information to us.

The type of information we collect from third parties includes, for example, information about whether you have been subject to any regulatory actions or legal proceedings. We use the information we receive to maintain and improve the accuracy of the records we keep about you, as well as to evaluate any risks that may arise from any relationship or potential relationship with you or your organization.

Confidential personal information

Some of the information you provide to us or that we obtain from third party sources (to the extent permitted by applicable law) about you or your organization may be confidential, such as any criminal convictions you have been charged with or details of your political activities or religious affiliations (e.g., in determining whether you are a politically exposed person). We need this information in order to be able to carry out what we call "knowledge of your counterparty" checks and to assess the risk under current law of working with you and/or your organisation as a potential customer or supplier.

You may also provide us with information about your health status or a possible medical condition so that, for example, we can help you access our offices or attend our events.

If you provide us with information about someone else, you confirm that you have been asked to act on their behalf, that you have informed them of our identity and the purposes (as set out in this privacy notice) for which your information will be treated and that you have obtained the necessary consent for the processing of their personal information. When we first contact them, we may tell them where we got the information from.

We use your personal information for the following purposes (or as otherwise described at the time of collection):

- create and manage reports about your account online (if any), to provide you with online services, such as facilitating your participation in discussion forums or for system or website administration purposes;

- improve our website(s), products and services;

- carry out internal audits, in accordance with applicable law, to assess financial, reputational, credit or insurance risks arising from any existing or potential relationship with you and/or your organisation and to carry out any money laundering checks;

- provide you and/or your organization with the information, products or services you have requested and be able to manage the billing and payment processes;

- send you communications related to the services, to manage communications that we send you and about which we ask for your opinion;

- facilitate your participation in events or competitions in which you wish to participate;

- identify trends in the real estate sector;

- ensure that the content, services and advertising we offer are tailored to your (or your organisation's) needs and interests and for business development purposes;

- contact you directly or through our agents by mail, telephone, fax, e-mail, SMS or any other electronic messaging service with good offers of services or information that might be of interest to you (including information about goods and services of other organizations). If you do not wish to receive marketing information from us, please indicate so in the registration or contact form, or contact us at marketing@promosistem.com. We will ask your consent to send you direct marketing material if required by law.

With whom do we share your personal information?

We may disclose your personal information to the following categories of recipients:

- To the companies or divisions of our group or subsidiaries, suppliers and third-party service partners:

- that provide us with data processing services (for example, to improve the security or functionality of our website or other IT infrastructure, to help us perform audits, marketing, analysis or research on our behalf or to support services to our customers, in general or in fulfilment of a particular commitment);

- with whom we organize joint promotional events (to ensure that you do not receive direct marketing information about the same event from multiple sources); or

- to groups of companies or affiliates that process personal information for the purposes described in this notice or that you were told when we collected your personal information.

If you wish, you can ask us for more information about our group companies, divisions, affiliates and third-party service providers that may process your personal information (including your location) by contacting us at marketing@promosistem.com.

- To our clients and participants in tenders, in relation to the tenders and transactions to which it has been submitted.

- To any competent law enforcement or regulatory body, government agency, court or other third party to whom we deem it necessary to disclose information (i) to comply with any applicable law or regulation, (ii) to exercise, establish or defend our rights, or (iii) to protect your interests or those of any other person.

- To an existing or potential purchaser (and its agents and advisors), in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the purchaser that it should use his or her personal information only for the purposes indicated in this privacy notice.

- To any other person, if we have your consent to disclose your information.

Legal basis for the processing of personal information

According to European Union data protection law, our legal basis for collecting and using the personal information described above will depend on the relevant personal information and the specific context in which we collect it.

However, we normally collect personal information about you only (i) where we need the personal information to fulfill a contract with you, (ii) where the processing is in our legitimate interest and is not invalidated by your rights, or (iii) where we have your consent to do so. In some instances, we may have a legal obligation to collect personal information about you or we may need it to protect your or someone else's important interests.

When we treat confidential personal information, we do so: (i) to conduct reviews to learn about our counterpart under applicable law; (ii) when treatment is necessary for reasons of public interest of great relevance; (iii) because you have given us your explicit consent; or (iv) to establish, exercise or defend legal claims.

You may choose not to provide us with personal information. However, unless you tell us otherwise, the information we require is necessary for the purposes of signing and fulfilling the contract we have signed with you or your organization and/or for providing services to you or your organization. If you do not provide it to us, this will impede the contracting process and/or the provision of the relevant services.

If we collect and use your personal information in connection with your (or a third party's) legitimate interests, under normal circumstances, these interests will be: to provide you with our services, to answer your questions, to improve our website(s), to perform marketing tasks, or to detect or prevent illegal activities.

Given the B2B context in which we process your personal information, as well as the security measures we take to protect your personal information (as outlined in the How We Protect Your Information section below), our legitimate interests do not undermine your individual rights and freedoms. We may have other legitimate interests and, if necessary, we will clarify them for you where appropriate.

If you have any questions or need more information about the legal basis that we respect when collecting and using your personal information, please contact us at marketing@promosistem.com.

How do we protect your information?

We use appropriate technical and organizational measures to protect the personal information we collect and treat about you. The measures we implement are designed to provide an appropriate level of security at the risk of processing your personal information. We are very careful to allow access to personal information only to those individuals who require such access in order to perform their jobs and obligations, and to third parties who provide services to us or who have a legitimate purpose for accessing that information (see section With whom do we share your personal information?).

When we allow a third party access to personal information, we implement appropriate measures to ensure that the information is used in a manner consistent with this privacy notice and that the security and confidentiality of the information is maintained.

International data transfers

Your personal information may be submitted or processed in countries other than your country of residence. These countries may have different data protection laws than their own (and in some cases lower level of protection).

Specifically, our web servers may be located in the U.S. and our group companies, subsidiaries and third-party providers operate worldwide. This means that when we collect your personal information, we may treat it in one of these countries. For example, we use an external customer management platform that involves the processing of personal information in the United States.

However, we take steps to safeguard your personal information in accordance with this privacy notice. These include, for example, relying on a register of external providers with EU-US Privacy Shield security level (under paragraph 45 of the General Data Protection Regulation). If you would like more information about the level of protection we provide to your personal information, you can request it from us in the Contact Us section below.

Storage of data

We store personal information that we collect when we have a legitimate business need to do so. If you are a customer or supplier (or a representative of a customer or supplier), the information will be retained for a period of time so that we can provide our services to you, to comply with necessary legislation, taxation or accounting and, if necessary, to establish, exercise or defend legal claims.

Where there is no such legitimate business need to process your personal information, we will delete or make it anonymous, or, if this is not possible (for example, because your personal information has been stored in backup files), then we will securely store your personal information and isolate it from further processing until its deletion is possible.

Your data protection rights

Under European data protection law, you have the following rights:

If you wish to access, correct, update or request the deletion of your personal information, you can do so at any time, through the section* How to contact us.

In addition, you may refuse to process your personal information, request that we restrict the processing of your personal information, or ask us to make your personal information portable. Again, you can exercise these rights by contacting us using the contact form included in the section How to contact us.

You have the right to opt-out of receiving marketing communications from us at any time. You can exercise this right by clicking on the "unsubscribe" or "unsubscribe" link in the marketing emails we send you or by sending us an email at marketing@promosistem.com to unsubscribe from other forms of marketing (such as postal marketing or telemarketing), please contact us via the section* How to contact us.

Similarly, if we have collected and processed your personal information with your consent, you may withdraw it at any time. This will not affect the lawfulness of any processing we have carried out prior to your departure, nor will it affect the processing of your personal information by virtue of lawful grounds other than consent.

You have the right to address your complaint to a competent data protection authority about our collection and use of your personal data. For more information, please contact your local data protection agency.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with the law.

Links to other websites

Our website links to other websites. We are not responsible for the content or privacy policies of these websites or the way they treat their users' information. Please note that, unless otherwise stated, we are not agents or advertisers of these websites, nor are we authorized to make any representations on their behalf. In any event, you should be aware of the privacy policy of these third party sites.

Passwords

In order to provide you with more personalized services, we may ask you to set one or more passwords to access certain services or sections of our website. You are solely responsible for your control and use of each password you create and we recommend that you do not reuse old passwords and create a secure password.

Updates to this Privacy Notice

We may update this privacy notice from time to time in response to legal, technical or business changes. When we update our privacy notice, we will take appropriate steps to inform you accordingly, depending on the relevance of the changes implemented. We will seek your consent to any changes to the privacy notice where required by applicable data protection laws.

You can find out when this notice was last updated by checking the date at the top.

How to contact us

If you have received an email or emails from PROMOSISTEM that you no longer wish to receive, please contact us at: marketing@promosistem.com. Or by phone: +34 934447654

If, however, you have any questions or concerns about how we use your personal information, you can also contact us at the same email address.

The person responsible for processing your personal information is the entity Doley Craw Associats, sl, PROMOSISTEM (i) with which you or your organization works as a supplier or customer; (ii) that you are considering entering into a relationship with you or your organization; and/or (iii) that you are a user of a particular Doley Craw Associats, sl - PROMOSISTEM- website.