WHO IS THE DATA CONTROLLER?

Company name: BETAPACK, S.A.U

Tax ID: A20497616

Business Address: Oianzabaleta, 3, 20305 Irun (Gipuzkoa)

Registered in the Mercantile Register of Gipuzkoa, Sheet SS.9187, Folio 195, Volume 1461, Section 8,

1st entry.

Telephone: 943639010

Email: soporte@betapack.com

FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

In accordance with the provisions of Regulation (EU) 2016/ 679 and Organic Law 3/2018 of 5 December on the protection of personal data and guarantee of digital rights, we inform you that the personal data you provide us with and those that are generated during the development of the relationship with you, are processed for the following purposes:

• To respond to your requests.

• To provide you with information about BETAPACK, S.A.U, products, for which you grant your consent to send commercial communications via e-mail or via any other means of electronic communication (such as SMS) that you have provided to us.

• To allow your participation in draws or commercial promotions.

• If you send us your CV, your application will be assessed during recruitment processes.

• The sending of communications by any means that you have provided us with, related to the activities carried out by the entity and which may be of interest to you.

• Responding to queries, complaints and suggestions, and carrying out all kinds of communication activities.

• Accounting, tax and administrative management of the entity.

For how long will we keep your data?

The personal data provided shall be kept for as long as their deletion is not requested by the data subject, or whoever legally acts as their legal representative, and for as long as they are necessary – including the need to keep them during the applicable expiry periods – or relevant for the purpose for which they were collected or recorded. The conservation of the data will be conditional on the legal obligation that BETAPACK, S.A.U has to conserve them. After these deadlines, the data shall be destroyed or erased, and the deletion, elimination or destruction shall be carried out in such a way that the information contained on the media is not recoverable.

Legal basis

The legal basis for the processing of your data is the consent given by the data subject. This is obtained expressly and unequivocally by filling in and, where appropriate, sending the paper or electronic documents and forms in which your data are collected. In all of the entity’s documents, which are used to collect data for the different uses, there are informative clauses in accordance with the provisions of the data protection regulations and consent is given expressly by the signature of the data subject, or by sending the existing forms on the website. Processing is also legitimate when it is necessary for the performance of a contract, or the provision of a service to the data subjects, to which they are party, or for the application of pre-contractual measures at their request (art. 6.1.a and b of the GDPR). BETAPACK, S.A.U is also legitimised to process your data in order to comply with the legal obligations to which it is subject and for the satisfaction of legitimate interests, provided that the interests or fundamental rights of the persons concerned do not prevail over these. Whatever the legal basis, consent may be withdrawn at any time.

Who will receive your data?

Your data will not be transferred to any entity without your prior consent, except for those transfers required by law. In this respect, your explicit consent will be requested for the transfer of your data to any other entity. As a consequence of the management of the authorised purposes, your data may be communicated to entities or persons directly related to BETAPACK, S.A.U and with the services provided by the same. Likewise, your personal information will be at the disposal of the public Administrations, Judges and Tribunals, to provide for the possible liabilities arising from the processing and provided that these transfers are protected by law.
Your data may also be transferred to companies that provide us with consultancy, IT maintenance, marketing, training or auditing services. These entities only have access to personal information that is necessary to carry out these services, and are required by a “data processing contract” to maintain confidentiality, not to use the information for other purposes, and to take measures to ensure the integrity and availability of the information. No international transfers of data outside the European Union or to entities that do not comply with the data protection standards set forth in Regulation (EU) 2016/ 679 are foreseen.

What is the origin of your data?

The personal data processed by BETAPACK, S.A.U are provided by the data subject, or obtained from sources accessible to the public.

What categories of data does BETAPACK, S.A.U process?

BETAPACK, S.A.U will process the data you provide us with, which may fall into the following categories:

• Identification and contact information

• Academic and professional data

• Employment details data

• Economic, financial and insurance data

• Commercial information

What are your rights?

Any person has the right to obtain confirmation on whether or not BETAPACK, S.A.U processes personal data pertaining to them. The data subjects are entitled to access their personal data and obtain a copy of the personal data undergoing processing, to update them, and to request the rectification of inaccurate data or, where applicable, request that they be erased when they are no longer necessary for the purposes for which they were originally collected, among other reasons. Furthermore, the data subjects may object to the processing of their data under certain circumstances and for reasons related to their particular situation. In this case, BETAPACK, S.A.U will cease to process their data, except where legally required to do so or for the purposes of exercising or defending possible complaints.

Also in certain circumstances, provided for in article 18 of the GDPR, data subjects may request the restriction of the processing of their data, in which case BETAPACK, S.A.U will process them, with the exception of their storage, with the consent of the data subject or for the formulation, exercise or defence of claims, or for the protection of the rights of another natural or legal person or for reasons of public interest of the Union or of a specific Member State.

As a consequence of the application of the right to erasure or objection to the processing of personal data in the online environment, data subjects have the right to be forgotten according to the case law of the Court of Justice of the EU.

Under the right to portability, data subjects have the right to obtain the personal data concerning them in a structured, commonly used and machine-readable format and to transmit them to another controller. Every data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, subject to the exceptions provided for in article 22.1 of the GDPR.

The data subject has the right to the erasure of their data, due to the disappearance of the purpose for which the data were processed or collected, due to revocation of consent when this is the legal basis for the processing, or for the other reasons contained in article 17 of the GDPR. The erasure will be carried out by proceeding to the top-level deletion of data contained on automated media and by the physical destruction of non-automated media.

How can these rights be exercised?

In writing, always accompanied by a copy of the ID card or other document that accredits the identity of the data subject, sent to the addresses indicated in the heading.

What avenues of complaint are available?

If you consider that your rights have not been properly addressed, you are entitled to lodge a complaint with the Spanish Data Protection Agency, whose contact details are:

Telephone Numbers: 901 100 099 / 912 663 517. Postal address: C/ Jorge Juan, 6 Madrid.