For this purpose, we will collect the following specific personal data about you: the data that you provide us in possible forms, the data that you can send us when using the contact sections that may exist, and data related to the downloaded and used application.

This information may be provided directly by you (e.g. by filling in a web form or interacting with a website or application), provided by third parties or obtained through trusted public sources after obtaining your consent to provide this personal information when necessary according to the applicable legislation.

We will use the collected information with the following specific purposes:

• Manage our users.
• Manage and improve our websites and apps.
• Measure the use of our websites and apps.
• Improve and personalize your user experience
• Send customized services and content based on your location.
• Improve the quality of our products and services and expand our commercial activities.
• Control and avoid fraud, infractions and other possible improper uses of our websites and apps.
• Career or job seeker: if this functionality is activated, your data will be used for the main purpose of management and selection of personnel.
• In the event that you request it, and it is allowed by the legal regulations in force, we will send you commercial communications about our own or third parties’ products and/or services.
• Social networks: we will treat your data with the purpose of correctly managing your presence in the corresponding social network, informing you about our activities, products and/or services, or of third parties that may be related to our activity, as well as for any other purpose that the regulations of social networks may allow.
• Respond to an official request from a public or judicial authority that has the necessary authorization.
• Manage our IT resources, including the infrastructure management and the business continuity.
• Preserve the economic interests of the company and guarantee the compliance and generation of reports.
• Archiving and preservation of records.
• Any other purpose imposed by the law and the authorities.

We will share your personal data with third parties that can provide us with services, always with the legal guarantees corresponding in each case.

Please note that we may also have to share your data with other recipients (e. g. another entity of Xesol Innovation, S.A. if the entity that collects data is not the same as the one that uses it), but always under strict conditions, as it is explained in more detail in the Part II.

Specific types of cookies and other tracking technologies are used as explained in Part II. In the event that the website has another specific cookie policy, the provisions this policy will prevail.

Please note that we also use cookies and other technologies for the standard purposes stated in Part II (e. g. to guarantee the correct functioning of our website or app).

We will not handle your personal data if we do not have an appropriate justification contemplated in the legislation for such purposes. Therefore, we will only handle your personal data if:

• We have previously obtained your consent;
• The treatment is necessary to comply with the contractual obligations we have acquired with you or to adopt pre-contractual measures if requested,
• The treatment is necessary to comply with our legal or regulatory obligations; or
• The treatment is necessary for our legitimate interests and does not unduly affect their interests or fundamental rights and freedoms.

Keep in mind that, when dealing with your personal data based on the latter assumption, we always try to maintain a balance between our legitimate interests and your privacy. Examples of these “legitimate interests” are the data processing activities carried out to:

• Benefit from profitable services (e. g. we can choose to use certain platforms offered by providers to process data);
• Offer our products and services to our clients;
• Prevent fraud or criminal activity, improper use of our products and services, as well as the security of our networks, architecture and IT system.
• Sell any part of our business or assets or to allow the acquisition of all or a part of our business or assets by a third party;
• Meet our corporate and social responsibility objectives.

We commit to not sell, diffuse, or otherwise transmit your personal data to third parties, except in the cases indicated in this Privacy Policy.

During the course of our activities and for the same purposes as those described in this Privacy Policy, your personal data may be accessed by the specific third parties identified in Part I of this Privacy Policy, or transferred to them and to the following categories of recipients, in case they have to know them, to fulfill such purposes:

• Our personnel (including personnel, departments, or other subsidiary companies of Xesol Innovation, S.A.).
• Our other suppliers and service suppliers that provide us with products and services.
• Our computer systems suppliers, cloud service and database suppliers, and consultants.
• Our business partners that offer products or services jointly with us.
• Any third party to whom we cede or innovate any of our rights and obligations.
• Our external advisors and attorneys in the context of sale or transfer of any part of our business or assets.

The aforementioned third parties are obliged by contract to protect the confidentiality and security of their personal data, in compliance with the applicable legislation.

Your personal data can also be consulted by regulatory, police or public bodies, or national and international courts, or may be transferred to them, provided that we have the obligation to do so in compliance with applicable legislation or regulations, or when requested.

The personal data that we collect from you may also be subject to processing, access or storage in a country other than that in which Xesol Innovation, S.A. is located, which may not offer the same level of protection of personal data.

If we transfer your personal data to external companies in other jurisdictions, we will guarantee the protection of your personal data (i) applying the required protection level according to the local legislation on data protection/privacy applicable to Xesol Innovation, S.A., (ii) acting in accordance with our rules and policies, and (iii) for Xesol Innovation, S.A. located in the European Economic Area (i. e. the EU member states plus Iceland, Liechtenstein and Norway, the “EEA”), unless the contrary is ordered, transferring your personal data exclusively according to standard contractual clauses approved by the European Commission. You may request additional information in relation with international transfers of personal data and obtain a copy of the relevant protection measures implemented, exercising your rights as detailed below in section 6.

For transfers of personal data within a group, Xesol Innovation, S.A. has adopted binding corporate standards, a system of principles, standards and tools provided by the European legislation, in order to ensure effective levels of data protection related to personal data transfers outside the EEA and Switzerland.

We have implemented appropriate technical and organizational measures to provide a high level of security and confidentiality to your personal data. These measures take into account: 

(i) The latest advances in technology and the costs of its implementation;

(ii) The nature of the data;

(iii) The handling risk.

Its purpose is to protect data against accidental or undue destruction or alteration, accidental loss, unauthorized disclosure or access and any other undue form of treatment. 

In addition, when dealing with your personal data, we will comply with the following obligations: 

• We only collect and process appropriate, relevant and not excessive personal data, as required to fulfill the above purposes; 

• We guarantee that your personal information is up-to-date and accurate (for this last purpose, we may ask you to confirm the personal data we have about you and we also encourage you to spontaneously inform us if a change in your personal circumstances occurs so that we can guarantee that your data is updated); 

• We can treat confidential data voluntarily provided by you in compliance with the applicable data protection rules and as strictly necessary for the relevant purposes mentioned above, and only relevant personnel will access and process the data, under the responsibility of one of our representatives who has the obligation to maintain professional secrecy or confidentiality. 

We will only keep your personal data the time necessary to fulfill the purpose for which they were collected or to comply with regulatory or legal requirements.

5.1 Cookies 

Cookies are small text files that are sent to your computer when you visit a website. We use cookies for the purposes mentioned above and in accordance with this Privacy Policy.

We do not use cookies to control individual visitors or identify you, but to obtain practical knowledge of how our websites and app are used in order to improve them for users. The personal data generated through cookies are collected in a pseudonymized format and are subject to your right to object to this treatment of the data, as detailed below.

In particular, we can use the following habitual cookies:

• Custom user interface cookies (i. e. cookies that remember your preferences).
• Authentication cookies (i. e. cookies that allow you to leave our pages and return without having to identify yourself again).
• Video player cookies (i. e. Cookies that store data necessary to play audio or video content and save your preferences).
• First-party analytical cookies (i.e. Cookies that memorize the pages visited by you and provide information about your interaction with these pages).
• Third-party analytical cookies (i. e. Third-party supplier cookies that control the statistics of our website and vice versa).

Please note that you can modify your browser to notify you of the sending of cookies. If you do not wish to receive cookies, you can also reject them by defining the appropriate settings in your browser. Finally, you can also delete the cookies already sent to you.

For more information on how to manage cookies on your device, see the Help function in your browser or visit www.aboutcookies.org, which contains comprehensive information on how to do it in a variety of browsers (the link is external).

5.2 Other technologies 

We may also use other technologies in our websites and apps to collect and treat your personal data for the same purposes mentioned above, including:

• Internet tags (such as action tags, one-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs, which are technologies that allow us to track user results).

You can exercise the following rights under the conditions and limits stipulated by law:

• The right of access to your personal data as we treat it and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or update;
• The right to request that your personal data be deleted or restricted to specific categories of treatment;
• The right to withdraw your consent at any time, without affecting the validity of the treatment prior to withdrawal;
• The right to refute, in whole or in part, the processing of your personal data;
• The right to object to direct marketing communications;
• The right to request your portability, that is, that the personal data you have provided to us is returned or transmitted to the person you choose, in a structured format, usually used and readable by machine, without any impediment on our part and with according to the confidentiality obligations.

However, please note that, in certain circumstances, the fact of not accepting cookies or the configuration of your browser may affect your browsing experience and prevent you from using certain functions in our website or apps.

If you have a question or wish to exercise the aforementioned rights, you can send an email to [email protected] together with a scanned image of your national identity document for identification purposes.

In any case, you also have the right to submit a claim to the competent data protection authorities, in addition to your prior rights.

7.1 Categories of technical and transactional data 

In addition to the information collected about you in accordance with the Part I of this Privacy Policy, we may collect several types of habitual personal technical and transactional personal data about you during the use of our websites and apps that are required for the correct functioning of our websites and apps, including:

• Information about your browser and device (e. g. domain of internet service provider, browser type and version, operating system and platform, screen resolution, device manufacturer and model)
• Statistics regarding your use of our websites and apps (e. g. Information about the visited websites, the searched information, visit duration to our website).
• Usage data (i. e. Access date and time into our website and apps, downloaded files).
• The location of your device when using our app (unless you deactivate this feature in your device settings).
• At a more general level, any information you provide us when using our websites and apps.

Please note that we will not intentionally collect, use or disclose personal data of people under 18 without obtaining the prior consent of a parent or legal guardian.

7.2 Why do we collect technical and transactional data?  

We always treat your personal data with a specific objective and only the personal data relevant to meet that objective. In addition to the purposes that have already been communicated to you in Part I of this Privacy Policy, we also treat your personal data collected during the use of one of our websites or apps for the following habitual purposes:

• Manage our users (e. g. Registration, account management, answering questions and offering technical assistance).
• Manage and improve our websites and apps (e. g. diagnose server problems, optimize traffic, integrate and optimize websites where appropriate).
• Measure the use of our websites and apps (e. g. generating traffic statistics, gathering information about the users’ behavior and the pages they visit).
• Improve and personalize your experience and better adjust the content to you (e. g. remembering your selections and preferences, by the use of cookies).
• Send you personalized services and content based on your location.
• Improve the quality of our products and services and expand our commercial activities.
• Control and avoid frauds, infractions and other possible improper uses of our websites and apps.
• Career or job seeker: if this functionality is activated, your data will be used for the main purpose of management and selection of personnel. This section, once you click it, you will see that it is inside the web of Xesol Innovation, S.A., so it will be governed by the legal and privacy conditions established there. In any case, you consent that the information provided by you on this website is communicated to us for the purposes just explained.
• If requested, and permitted by current legal regulations, we will send you commercial communications electronically about our products and services or those of third parties related to the automotive, IT, Iot, manufacturing and commercialization sectors of our products.
• Social networks: we inform you that we are in social networks. The treatment of the data of the people who become followers (and/or perform any link or connection action via the social networks) of the responsible for the treatment of official webs, in social networks, will be governed by this section, the rest of the present Privacy Policy and the conditions of use of the web, as well as those conditions of use, privacy policies and other regulations for access, use and similar that belong to the corresponding social network. We will treat your data in order to correctly manage your presence in the corresponding social network, inform you about our products and services, activities, or of third parties that may be related to our activity, as well as for any other purpose that the regulations of the social networks can allow.
• Respond to an official request from a public or judicial authority with the duly authorization.
• Manage our IT resources, including infrastructure management and business continuity.
• Preserve the economic interests of the company and ensure the compliance and generation of reports (such as compliance with our policies and local legal requirements, taxation and deductions, management of alleged cases of misconduct or fraud, the performance of audits and defense in litigation).
• Archiving and preservation of records.
• Any other purpose imposed by law and authorities.

Any future changes or addition to the handling of your personal data as described in this Privacy Policy will be communicated to you in advance by individual notification via our usual communication channels (e. g. by email), as well as via our websites or apps (by banners, pop-up messages or other notification mechanisms).