Data protection

In accordance with Organic Data Protection Law 15/1999 (hereinafter LOPD) and its implementing regulations, approved by Royal Decree 1720/2007 of 21 December (hereinafter RLOPD), CLEVEROX hereby informs users of its Data Protection Policy, so that they can freely and voluntarily decide whether they wish to provide the personal data which may be required of them in connection with subscription or registration for any of the services offered. Save in the fields where indicated otherwise, replies to questions relating to personal data are voluntary.

CLEVEROX reserves the right to change this Policy to adapt it to innovations or requirements of the legislation and case law and to trade practices, taking into account at all times the legitimate interests of consumers or users. A number of services provided on the Portal may contain special conditions with specific terms relating to data protection.

Confidentiality in the automated processing of users’ personal data

The personal data gathered by CLEVEROX via the Portal shall be processed secretly and confidentially.

CLEVEROX has adopted the levels of data protection security required by statute and has put in place all the resources and technical measures available to it to prevent the loss, misuse, alteration and theft of and unauthorised access to the personal data provided in accordance with the RLOPD. Notwithstanding the foregoing, users must be aware that Internet security measures are not inviolable. The personal data gathered shall be the subject of automated processing and included in the corresponding automated files owned by and under the responsibility of CLEVEROX, which have been duly registered at the Registro General de Protección de Datos (Data Protection Registry).

CLEVEROX shall provide users with the appropriate technical resources so that, prior to providing their personal data, they can access this notice about the Data Protection Policy or any other relevant information, and can give their consent so that CLEVEROX can then carry out automated processing of users’ personal data. Users’ acceptance of their personal data being processed is revocable

at all times, without retroactive effect.

Purpose of gathering and automated processing of personal data

The purpose of the gathering and automated processing of the personal data requested is the management, administration, provision, expansion and improvement of services offered by CLEVEROX on the Portal from time to time. They are also intended for quantitative and qualitative research into users’ visits and use of the services, the design of the new services related to CLEVEROX’s services and updates to them, and the sending by conventional or electronic means of technical or operational information and

information relating to the specific profiles selected by the user in the Subscription Form, survey forms or commercial or advertising information about the products or services offered by CLEVEROX or third party partners.

Users are not obliged to receive that advertising or survey forms, and can so indicate using the means provided by CLEVEROX for that purpose in the Subscription Form for the services offered, by written communication or directly using the procedure referred to in each commercial communication.

CLEVEROX, may, as the result of the existence of a previous contractual relationship, send commercial communications relating to products or services similar to those initially contracted by users, without requiring their authorisation or making any express request. However, users shall in any event have access to the means described above to express their objection to receiving such commercial communications.

CLEVEROX will under no circumstances employ users’ personal data for purposes other than those referred to above, save with prior warning given on the Portal giving a reasonable period for the user to object.

Users represent that all data supplied by them are true and accurate, and undertake to inform CLEVEROX of changes in those data.

Users are entitled to oppose the processing of any of their data which are not strictly necessary for conclusion of the contract and to their use for any purpose other than the maintenance of their contractual relationship.

User also represent that they are over 14 and have acknowledged sufficient legal capacity to contract for the services offered by CLEVEROX, in accordance with the applicable rules.

Where the user supplies third party data, CLEVEROX cannot be held liable for compliance with the principles of disclosure and consent, and it must therefore be the user who represents that it has previously informed and obtained the consent of the data owner for disclosure of that data.

Transfer of users’ personal data to third parties

Users’ personal data shall not be transferred to third parties without the prior consent of the users. Where that occurs, CLEVEROX shall expressly inform the user of the transfer of his or her personal data to third parties, stating the identity of the transferees and the purpose of the transfer of personal data.

Notwithstanding the preceding paragraph, users consent to information in their personal data being used when so required by the competent administrative authorities or by court order.

Users’ acceptance to their data being transferred shall be revocable at all times, without retroactive effect.

Users’ rights in relation to their personal data

Users have by law and shall be entitled to exercise the rights of access, rectification, cancellation and opposition to the processing, use and transfer of their data and to do so must send a letter or e-mail to the following address:

3rd Floor

207 Regent Street

London

W1B 3HH

Or

cleverox@cleverox.com

Use of cookies and activity files

CLEVEROX may use cookies when a user browses through the sites and pages on the Portal. Cookies are files sent to a browser by means of a web server to record the user’s activities on the Portal.

When users browse through the Portal they may receive cookies on their computer sent from the CLEVEROX server or, on our behalf, from servers of third party undertakings engaged by us to provide advertising and audience tracking services. The undertakings from which cookies are sent may not under any circumstances know users’ personal data. Where users allow receipt of cookies, they can find out the server from which they were sent, by consulting the instructions for use of their browser.

They do not provide any personal data about the user and allow the server on which the Portal is installed to recognise the browser on the computer used by the user in order to make browsing simpler. They may also, provided the user has registered previously, allow access to exclusive content for registered users of the Portal without having to register on each visit.

Users may configure their browser to warn them on screen that it has received cookies. Users may also prevent cookies from being installed on their computer, and to do so must consult the instructions of the use of their browser.

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