Privacy policies and data protection

Leedeo Engineering, S.L. (hereinafter, "Leedeo Engineering") would like to inform you transparently, through this Privacy Policy, about all processing we carry out with your data, the purposes for which we process them, and the rights you can exercise over your personal data as a user, as well as how long we will retain your data.

We inform you that by accessing our Website you acquire the status of User. As a User, you declare that you have the legal capacity necessary to fully understand and accept this Privacy Policy. This Privacy Policy must be read together with our Cookies Policy at www.leedeo.es.

Thank you for visiting our website. We hope you enjoy learning about the services offered by Leedeo Engineering, S.L.

WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

This Privacy Policy governs the use of the website www.leedeo.es (hereinafter, the "Website"), owned by Leedeo Engineering, S.L. (hereinafter, "Leedeo Engineering"). The data controller is Leedeo Engineering, S.L., registered with the Companies Register of Barcelona, Volume 46,090, Page 24, Sheet B509105, Tax ID (NIF) B67057612, with registered office at Calle Viriat, 47, 2nd Floor, Barcelona, 08014, Barcelona.

Users agree to be bound by the terms and conditions set out in this Privacy Policy to the extent they apply to them.

WHAT IS PERSONAL DATA AND WHAT IS PERSONAL DATA PROCESSING?

Personal data are those that identify or can identify a person. For example, a person can be directly identified by first and last name, while an ID number can indirectly identify them. Personal data include information such as mobile phone number, email address, date of birth, and gender, among others. Numerical identifiers like your computer's IP address, as well as information obtained through cookies, can also be included.

Personal data processing is any operation or set of operations we carry out on your personal data, such as collection, recording, storage, use, and disclosure of your data.

As a User, whenever you provide personal data, you are obliged to ensure that such data are true, accurate, complete, and up to date. By providing us with your personal data and/or information, you guarantee that the data you provide correspond to your true identity and that they are current, truthful, and complete at the time you provide them. The User will be responsible for any direct or indirect damage or harm caused to Leedeo Engineering or third parties due to the User's failure to provide truthful, accurate, complete, and up-to-date information.

Leedeo Engineering will not share any personal data without the prior consent of the data subject, except for those communications necessary to process the request submitted by the User, limiting such communication to the purpose that justifies it.

WHAT TYPE OF INFORMATION DO WE COLLECT?

To carry out the data processing specified in this Privacy Policy, we need certain information about you. Therefore, we collect the information you provide through various interaction and communication channels, such as information and contact request forms, the newsletter subscription form, corporate profiles on social networks, etc.

The data we may collect through the above channels include your first and last name, company name, sector, mobile phone number, email address, responses you provide to satisfaction or product rating surveys, shipping address when it differs from your home address, your social media profiles (in cases where you consent to share this personal information with us), information about your use of and browsing on the Website (the web page from which you arrive at the Website, sections visited, processes started and abandoned, IP address, type of device used to access, internet browser used, time spent on the Website, etc.). We also store a "session ID" corresponding to an internal code that identifies you as a user, your experience, job position, etc.

THROUGH WHICH CHANNELS DO WE COLLECT YOUR PERSONAL DATA?

You do not need to register on our Website to enjoy and learn about all the services we offer at Leedeo Engineering. We only collect and process information that you provide to us through the following channels:

• Contact forms: where you provide us personal data to request information about our services, etc.

• Work with us: where you provide personal data so that we can assess your candidacy as an employee or for an internship at Leedeo Engineering.

• Interaction with the Website and with Leedeo Engineering on social networks: through your use of the Website while browsing it and through interaction you may have via the company's corporate profiles on various social networks.

WHAT PROCESSING DO WE PERFORM WITH YOUR PERSONAL DATA AND FOR WHAT PURPOSES?

To inform you transparently and in detail about the purposes for which we process your data, we have separated the information relating to each processing activity into separate tables. In this way, you will find all the specific information for each of the processing activities we carry out on your data in its corresponding table.

Each descriptive table for the corresponding processing sets out the following information:

For what purposes do we process your data?

Here we explain why and for what purpose we process your personal data.

On what legal basis do we process your data?

This explains the legal basis that allows us to process your personal data. Data protection regulations require us to have a basis that legitimizes the processing of your data. Thus, to process your personal information we rely on four legal bases depending on the activity or processing we carry out on your data. The legal bases for processing your personal data may be:

• Legitimate interest: As a company, Leedeo Engineering has a legitimate interest in collecting and processing your personal data in order to study and analyze the suitability of our Website, products, and services—whether they meet the needs of our clients and users or, on the contrary, need to be modified in some specific aspect or can be improved to better adapt to those needs. We also have a legitimate interest in maintaining regular contact with you to keep you informed about promotional or advertising matters regarding our products and services. In any case, this legitimate interest is based on an analysis of the appropriate balance between our interests in processing your personal data and your rights and freedoms. The outcome of this analysis will determine whether we can use your personal information for the processing described in this Privacy Policy (except for segmentation and profiling processing for sending marketing communications, for which we require your explicit consent).
• Compliance with a legal obligation: As a company, Leedeo Engineering acts as the controller of your data, and therefore we must comply with a series of obligations imposed by accounting, tax, consumer, etc. regulations. In those cases where the legal justification for any of our processing is compliance with a legal obligation, your refusal to provide us with those personal data that are legally mandatory will make it impossible for you to contract products or services with Leedeo Engineering, since doing so would entail a breach of the regulations to which we are subject.
• Your consent: If Leedeo Engineering wishes to carry out any processing of your data whose legal justification cannot be based on any of the reasons explained above, we will first request your consent for such processing. In any case, please note that in such cases you may always withdraw your consent.

How long do we keep your personal data?

Here we provide an indicative period for how long your data will be kept. The retention time will in any case depend on the processing carried out on your personal information. Note that certain accounting, tax, consumer, data protection, and contract regulations may require us to retain certain data of clients and users for a specified period.

What are your rights?

This describes the rights you can exercise over your data, depending on the processing performed. You should bear in mind that depending on the legal basis legitimizing the processing of your data, your rights may be limited. We explain this in more detail in the following section.

Below you will find a more detailed description of the different processing activities Leedeo Engineering performs on your personal data:

1. Handling queries submitted via "Contact"

Purpose: Managing queries and resolving doubts submitted by the user.

Legal basis: Users' consent.

Retention period: Your personal data will be processed by Leedeo Engineering unless and until you exercise your right to object or erasure. If you exercise such rights, the personal data provided will be duly blocked for the legally stipulated limitation period for actions that may arise from the processing. Once the maximum processing period has been reached, Leedeo Engineering will anonymize or delete the user's personal data.

Your rights: You have the right to access, rectify and erase your data, as well as other rights, as explained in the additional information.

2. Handling applications submitted via "Work with us"

Purpose: Managing the job application. Managing the personal data necessary to become part of Leedeo Engineering's staff based on the profile we obtain from the information you provide us during the selection process.

Legal basis: Users' consent.

Retention period: Legitimate interest of the applicant (Candidate) to include them in Leedeo Engineering's selection processes once they have provided their academic information or applied for a specific position. Your personal data will be processed by Leedeo Engineering unless and until you exercise your right to object or erasure. If you exercise such rights, the personal data provided will be duly blocked for the legally stipulated limitation period for actions that may arise from the processing. Once the maximum processing period has been reached, Leedeo Engineering will anonymize or delete the user's personal data.

Your rights: You have the right to access, rectify and erase your data, as well as other rights, as explained in the additional information.

3. Analysis of customer and user data for statistical and business purposes

Purpose:

• Analyze how clients and users use and take advantage of the Website and the products and services offered by Leedeo Engineering.

• Prepare business reports and statistics.
• Improve the Website and the products and services offered by Leedeo Engineering and adapt them to changing trends in clients' and users' activity.
• Leedeo Engineering's legitimate interest in understanding and analyzing the efficiency of its activity and business.

Legal basis: Users' consent.

Retention period: Your personal data will be processed by Leedeo Engineering for the duration of the relevant promotion and its claim period. Subsequently, the personal data provided will be duly blocked for the legally stipulated limitation period for actions that may arise as a consequence of or in relation to the purchase contract or service agreement entered into by Leedeo Engineering and the client. Once the maximum processing period has been reached, Leedeo Engineering will anonymize or delete the user's personal data.

Your rights: You have the right to object to the processing of your data for statistical and business analysis purposes by emailing a request to: admin@leedeo.es. You also have the right to access, rectify and erase your data, as well as other rights, as explained in the additional information.

4. Maintaining updated suppression lists to avoid contacting you if you so request

Purpose: Maintain an up-to-date list of all clients and users who have requested the erasure of their data or have at some point objected to our sending of marketing communications.

Legal basis: Legal obligation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) requires us to respect your rights and maintain evidence of our compliance with your request to exercise the right to erasure.

Retention period: We will retain your personal data for the legally provided period for filing any claim related to our effective or deficient response to the right of erasure or objection you have exercised. Once the maximum processing period has been reached, Leedeo Engineering will anonymize or delete the user's personal data.

Your rights: The rights described in this privacy policy are limited here, as this processing is based on a legal obligation as explained above.

5. Analysis of website usage, operation, and improvement

Purpose:

• Recognize the user when they return to the Website.

• Facilitate sharing Website content via social networks and communication channels.
• Adapt the Website to the type of device used by the user.
• Adapt the Website to the personalization criteria chosen by the user and remember them.
• Study possible improvements to the Website to optimize usability and implement them.
• Display the correct Website content requested by the user at any given time.
• Enable the ability to share Website content on social networks.

Legal basis: Users' consent.

Retention period: We will retain your personal data for as long as each type of cookie requires or until you withdraw your consent or exercise your right to object. Once the maximum processing period has been reached, Leedeo Engineering will anonymize or delete the user's personal data.

Your rights: You have the right to access, rectify and erase your data, as well as other rights, as explained in the additional information.

WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

Below are the rights you can exercise as a user of the website:

You have the right to have Leedeo Engineering confirm whether or not we are processing your personal data, and, if so, the right to know which data we process.

You may modify any data that are inaccurate or incomplete. In your rectification request you must indicate which data you wish to have modified.

You may object at any time to our processing your data. You have the right to object at any time, on grounds relating to your particular situation, to personal data concerning you being processed based on the company's legitimate interest. Leedeo Engineering will stop processing personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

This right allows for the deletion of your personal data. The data will be kept blocked in a way that prevents their processing, without prejudice to making them available to public administrations, courts, and tribunals to address possible liabilities arising from the processing during the limitation period.

You have the right to copy and transfer data from our database to another controller. This right can only be exercised when the processing is based on the performance of a contract or on your consent and the processing is carried out by automated means.

This right allows you to request that we suspend the processing of your data when:

• You contest the accuracy of the data, while Leedeo Engineering verifies such accuracy.
• You have exercised your right to object to the processing of your data, while it is verified whether Leedeo Engineering's legitimate grounds override yours as the data subject.

Likewise, this right allows you to request that Leedeo Engineering retain your personal data when:

• The processing is unlawful and, as the data subject, you oppose the erasure of your data and request the restriction of their use instead.

Leedeo Engineering no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise, or defense of legal claims.

How to exercise these rights
You may exercise your right by sending your request to the following email address: admin@leedeo.es, or by postal mail, via a written and signed request accompanied by a photocopy of your ID or passport, addressed to: Calle Viriat, 47, 2nd Floor, Barcelona, 08014, Barcelona.

We also inform you that when Leedeo Engineering has not satisfactorily complied with your exercise of rights, you may file a complaint with the Spanish Data Protection Agency (AEPD). If you want more information about this right and how to exercise it, you can contact the AEPD:

https://www.agpd.es
Phone: 901 100 099 and 91 266 35 17
C/ Jorge Juan, 6, 28001 Madrid

TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

Leedeo Engineering does not disclose the personal information you provide through the channels described in section four, unless it is necessary for the provision of the contracted service, such as communication to payment platforms, banks, and companies so that transactions can be processed.

We may also disclose your personal data upon legal request or another basis that legitimizes disclosure to courts or public administration bodies.

Other possible third parties to whom we may disclose your data, upon legal request or another legitimizing basis:

• Legal advisers

• Courts

• Tax Administration

• Government bodies and public administration

• Law enforcement authorities

• Processors who, in order to provide the necessary services, must access certain information and/or personal data. Processors include, for example, transport and courier companies responsible for delivering your order to the requested address. Data may be transferred to vendors with access to data with whom obligations and responsibilities regarding data processing are formalized in their capacity as Processors. Leedeo Engineering signs the corresponding data processing agreements that include appropriate guarantees regarding the processing of personal data, confidentiality, and cancellation, destruction, or return.

ARE YOUR DATA SECURE?

To ensure fair and transparent processing of your personal information, we will adopt appropriate procedures that include the implementation of technical and organizational measures that take into account possible risks and correct any inaccuracies identified in the personal data processed, so that the risk of any error is minimized, and your data are processed fairly and securely.

All information you provide to us is stored on secure servers. Unfortunately, the transmission or communication of information via the Internet is not completely secure. Thus, once we have received all your information, we will use strict security procedures to try to prevent any unauthorized access.

We also ensure that our service providers maintain appropriate security standards for the protection of personal data to which they have or may have access, in accordance with the applicable data protection legislation.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may vary over time due to possible changes in the criteria followed by the competent supervisory authority in data protection at any given time. Leedeo Engineering therefore reserves the right to modify this Privacy Policy in order to adapt it to such criteria, as well as to new case law or legislation.

Latest version: February 2019.

CONTACT

If you have any questions about the processing we perform on your personal data, write to us at admin@leedeo.es.

SECURITY

Leedeo Engineering uses information security techniques commonly accepted in commercial practice, such as firewalls, access control procedures, and cryptographic mechanisms, all with the aim of preventing unauthorized access to data. To this end, the user/client agrees that the supplying party may obtain data for the recognition of these access controls.

INDUSTRIAL AND INTELLECTUAL PROPERTY

This website is owned by Leedeo Engineering. The intellectual property rights and exploitation rights of this website, its pages, screens, the information they contain, its appearance and design, and any hyperlinks to other web pages belonging to any subsidiary and/or company in which Leedeo Engineering holds an interest are its exclusive property, unless otherwise expressly specified. Any name, design and/or logo, and any product or service offered and shown on this website are duly registered trademarks of Leedeo Engineering, its subsidiaries and/or companies in which it has an interest, or of third parties. Any improper use by persons other than their legitimate owners and without their express and unequivocal consent may be reported and pursued with all legal means available under the Spanish and/or European Union legal system.

Third-party intellectual property rights and trademarks will be clearly indicated and must be duly respected by anyone accessing this website; Leedeo Engineering declines all responsibility for how users may use them; responsibility will rest solely with the user.

Content may only be downloaded, or pages of this website copied or printed, for personal and private use. Reproduction, transmission, modification, or deletion of any information, content, or warnings on this website is prohibited without the prior written consent of Leedeo Engineering.

The content offered by Leedeo Engineering is subject to intellectual and industrial property rights and is the exclusive property of Leedeo Engineering or of the natural or legal persons about whom we provide information. With the purchase of a product or service, Leedeo Engineering does not grant the buyer any right of alteration, exploitation, reproduction, distribution, or public dissemination thereof; Leedeo Engineering reserves all such rights. Any assignment of the aforementioned rights must be made with the written authorization of the holder, so that the client may not make the contents available to third parties.

Intellectual property also includes, in addition to the content included by Leedeo Engineering, all graphics, logos, designs, images, and source code used in its programming.

Leedeo Engineering has obtained the information and materials included on the website from sources considered reliable and, although sufficient measures may have been taken to ensure that the information contained therein is correct, Leedeo Engineering cannot guarantee that the information is accurate, complete, and up to date at all times and in all circumstances; therefore, it should not be assumed to be so. Leedeo Engineering expressly declines all responsibility for errors or omissions in the information contained on the pages of this website.

Leedeo Engineering reserves the right to modify, suspend, cancel, or restrict, without prior notice, the content of the website, the links, or the information obtained through them. Under no circumstances will it assume any liability arising from incorrect use of the website by the user, whether in terms of the information or services contained therein.

Under no circumstances shall Leedeo Engineering—its branches and/or workplaces, directors and/or lawyers, employees, and, in general, its authorized personnel—be held liable for any kind of damages, losses, claims, or costs resulting, directly or indirectly, from the use and/or dissemination of the website or the information acquired or accessed through it, nor for any computer virus, operational failure, or interruption of service or transmission, or connection failures while using the website, whether directly or through links or other means. This serves as a warning to all users that the aforementioned events could occur.

Leedeo Engineering is not responsible for websites not owned by it that users may access via links, nor for any content made available by third parties. Any use of links or access to a website other than our own is done at the user's own will and risk. Leedeo Engineering neither recommends nor guarantees any information obtained via any link and will not be responsible for any potential losses, claims, or damages resulting from the use—or misuse—of a link, or of the information obtained through it, including other links or web pages, any interruption of service or access, or any attempt to use—or misuse—a link, whether when connecting to Leedeo Engineering's website or when accessing information on other websites from it.

APPLICABLE LAW AND JURISDICTION

The applicable law in the event of a dispute or conflict related to the interpretation of the conditions of this legal notice, as well as any other matter related to the services of this website, shall be Spanish law.