PRIVACY

Last Updated 01/05/2021

This Privacy Policy aims to protect and respect User privacy. To that subject, SREC SOLUTIONS, S.L. has adopted the principles set forth in this Policy which is part of ours General Privacy Conditions and applies to the following Services (hereinafter, the "Services"):

- Our "Web sites"

https://s-recsolutions.com

https://srec.solutions

-Our applications (hereinafter, the "APPs"):

Events4you

SINVAD

- Also:

APIs REST

SDKs

Budgets and commercial information

In accordance with the regulations on the protection of personal data, and with the provisions of Articles 13 and 14 of EU 2016/679, General Regulation on Data Protection ("GDPR"), and the Spanish Organic Law 3/2018, 5 of December, for the protection of personal data and the digital rights warranty, the purpose of this Privacy Policy, is to inform the User of the following:

CONTROLLER OF THE DATA PROCESSING:

SREC SOLUTIONS, S.L. (hereinafter "SREC", or "Data Controller"), with registered address at Arral de Tanxil 21, 4B, 15920 (Rianxo) and Tax Identification Number B70481577, is responsible for processing the data provided by users through the Web.

You can contact SREC by post mail at the above address, or by e-mail at info@s-recsolutions.com.

We reserve the right to modify or adapt this Privacy Policy at any time, so please review it.

PURPOSE OF DATA PROCESSING

a) APPS USERS, WEBS, WEBS AND EMAIL CONTACTS

The Data Controller will process the identification and contact data that the User provides through the contact form, registration forms and User accounts of the Websites or APPs, or when contacting the Data Controller via email, as well as other data that the User includes when contacting for the following purposes:

• Sign in, access and use of the APPs.
• Answer queries or requests.
• Manage the requested service, answer requests, or process requests.
• Inform by electronic means, concerning an application.
• Provide information to the Users about improvements and updates of SREC services.
• Carry out analysis and improvements on the Webs about SREC's products and services.
• Improve the business strategy.
• Analyze user experience and troubleshoot incidents at our Website.
• Proactive contact with SREC in order to provide technical and commercial support.

The data processing is based on the acceptance and consent of the User. In those cases, in which to make a request it is necessary to fill in a form and click on the submit button, its completion shall imply that the user has been informed and has expressly given his/her consent to the processing of his/her data in accordance with this Privacy Policy. We inform you that if you do not click the "checkbox" to accept the privacy policy, the submission of the information will not be allowed.

In addition, SREC can process the User contact data in order to provide technical support and commercial advice. In this case, the treatment is based on the rightful interest pursued by the Data Controller in order to engage in a commercial relationships or provide satisfying experience to the users who have difficulties operating with the platform.

b) SDKs and APIs REST

The User can access to SDKs and APIs REST functionalities that allow to download the platform information, the historic user data. We inform you by accessing to this functionality implies your given consent of the processing with the purpose of fulfil the user requests.

Also SREC provides SDKs and APIs REST that allow third parties to build their own applications. In this case, SREC acts as Data Processor when a third part integrates at their application a SREC software module. In this case, SREC is exempt from any kind of liability arising from the non-compliance of the current personal data protection regulations attributable to the Data Controller.

c) SOCIAL NETWORKS CONTACTS

The personal data available in the Social Networks profiles, as well as those that the User provides to the Data Controller when contacting him/her through this channel, will be treated with the purpose of:

• Answer the queries or requests.
• Manage the requested services, reply the requests, or process a request.
• Establish a user-Data Controller relationship, and create a community of followers.

In this case, the processing is based on the acceptance of a contractual relationship in the social network environment that applies, and in accordance with its privacy policies, so SREC recommend you the prior consultation.

SREC will only be able to consult or cancel the data in a restricted way as it has a specific profile. These data will be treated as long as the user allows it through the different interactions that each social network allows. The User must make any rectification of the data or restriction of information or publications through the configuration of his/her profile in the social network.

d) JOB SEEKERS/INTERNSHIPS

SREC provides the user with the e-mail info@s-recsolutions.com to manage recruitment processes. The Data Controller treats the received data, both identification and contact data, as well as those that are contained in the CV provided by the applicant, for the following purposes:

• Organization of recruitment processes for the hiring of new employees.
• Appointment for job interviews and evaluation of applications.

The legal basis for this treatment is the consent of the candidate by submitting the CV. SREC will process to safe destruction after one year from the receipt. Once this period has elapsed, the applicant who continues interested shall forward the updated CV.

e) WEBINARS AND ONLINE EVENTS

In the event that the User chooses to participate in a Webinar taught by SREC company members, we inform you that we will use the "Microsoft Teams" platform, owned by "Microsoft Corporation". Which will have access to the data that you have provided previously: email, name and surname. Therefore, by requesting the access, you accept the processing of your data by Microsot Teams as described in its privacy policy.

The registration for our Webinars can be done through our website or by the link to the corresponding platform. In addition, we carry out training or commercial events and meetings in collaboration with our Partners who, where appropriate, will also access to the data provided at the registration form and who will treat them in accordance with their privacy policy.

RIGHTS OF THE USER

The GDPR recognizes that the User has several rights, which SREC as Data Controller is obliged to guarantee the following rights:

• Information: to know if your data is being processed or not.
• Access: to access the personal data object of the treatment.
• Rectification: request a rectification of the data if it is are inaccurate.
• Withdraw consent: request the deletion of the data if it is no longer necessary for the purposes for which it was collected or if you withdraw the consent granted.
• Restrict Processing: request the limitation of the data processing, in some cases, in which case it will only be conserved in accordance with current regulations.
• Portability: the portability of the data, which will be provided in a structured, commonly used or machine-readable format; or they may be sent to the new designated Responsible. It is only valid under certain circumstances.
• Complain: File a claim with the Spanish Data Protection Agency or competent control authority.

In order to facilitate the process, and comply with the principle of accuracy of the data, if any data is modified, the Data Controller appreciates the User communicates that modification.

In order to exercise the aforementioned rights, the User can request a form at info@s-recsolutions.com, or use those provided by the Spanish Data Protection Agency or an authorized third party. These forms must be signed electronically and accompanied by a copy of ID card or passport in force. The user could send these forms by mail to info@s-recsolutions.com or postal mail at the address of the Data Controller indicated at the beginning of this text.

Depending on the exercised right, SREC will take a maximum of one month from the date of receipt the request to reply, and two months if the subject is very complex, in which case the User will be previously notified. In any event, SITUM will adopt the necessary measures to preserve the rightful interests of the User.

PROCESSING OF THIRD PARTY DATA

As a general rule, the Data Controller will only process the data provided by its owners. In the event of receiving data from third parties, such Users must first be informed and asked for their consent. SREC will be exempt from any liability for incompliances with this requirement.

DATA OF MINORS

SREC will not process data from minors under 14 years of age. Therefore, the User must refrain from providing them if he or she is under that age or, if applicable, from providing data from third parties under that age. SREC denies any liability due to failure to comply with this requirement by the User.

COMMERCIAL COMMUNICATIONS BY ELECTRONIC MEANS

If you give your express consent by checking the appropriate checkbox, SREC will send commercial communications to the email address provided by the User. The Data Controller will store the email in the database, and will send emails until the User requests the cancellation, an option that will be available in any communication. The purposes of this particular processing are as follows:

• Manage the requested service.
• Information by electronic means related to the application.
• Commercial or events information.
• Perform analysis and improvements in the delivery of emails, in order to improve the commercial strategy.

SECURITY MEASURES WE APPLY

SREC has adopted an optimal level of information security, adopting the appropriate technical and organizational measures according to the state of technology to avoid the loss, misuse, alteration, unauthorized access or substraction of Personal Data.

COMMUNICATION TO THIRD PARTIES

SREC do not disclose your personal data to third parties, except in the cases stated below:

• Legal obligation.
• court injuction.
• Public authorities, banks and financial entities for the collection of the service provided or product purchased; – Data Processors or Subprocessors in the extent necessary for the provision of the service, whom will have signed a contract for the provision of services that requires them to maintain the same level of privacy as the Data Controller in compliance with the GDPR. You can find a list of the Subprocessors used by SREC in the Annex II of our Master Subscrition Agreement (https://srec.solutions/documents/SMSA.pdf).

INTERNATIONAL TRANSFER OF PERSONAL DATA

Personal data about you may be transferred and processed on severs or computers located outside of the European Union/European Economic Area. Safeguards measures under the GDPR are applied to the transfer.

COOKIES

The Web uses Cookies, iy you wish to know more about them, you can do it by accessing our Legal Terms.

CONSERVATION OF PERSONAL DATA

Personal data will be kept at the SREC systems while the User are willing to use the services provided by SREC. Once the User decide to withdraw his/her consent, the data processed for each purpose will be maintained anonymized during the legally stipulated deadlines, including the period in which judicial authorities may request them, taking into account the limitation period for legal actions.

The data processed will be maintained as long as the aforementioned legal deadlines do not expire, if there is a legal maintenance obligation, or if the legal term does not exist, until the interested party requests their supression or revocation of the consent granted.

SREC will keep all the information and communications related to the provision of the service, while the guarantees of the products or services last, to attend to possible claims.

SREC mantendrá toda la información y comunicaciones relativas a la prestación del servicio, mientras duren las garantías de los productos o servicios, para atender posibles reclamaciones.

DATA RETENTION

SREC informs you that, as a service provider of data hosting and in accordance to 34/2002 Law, from 11th July, of Information Society Services and E-commerce (LSSI), will retain for a maximum period of 12 momths the essential information to identify the origin of the storage data and the starting date of the service provided. This retention aims to compliance with legal obligations which may arisen from the relationship with the User.

MODIFICATION AND UPDATED

SREC reserve the right to make modifications and updates of this Privacy Policy at any time.