1. Which is the scope of application of this policy?

NEWDOCK LP, S.L.U. (hereinafter, “NEWDOCK”) undertakes to protect the privacy of any clients and users accessing its website (hereinafter, the “Site”).

All Site contents are owned, run, licensed or controlled by NEWDOCK.

Use of this Site will endow user status (hereinafter, the “User”) to any individuals accessing it.

Users need not register in order to use the Site.

Users may browse the Site without needing to provide any personal data. The only personal data that NEWDOCK will access are those voluntarily provided by each User through the forms uploaded on the Site, or when NEWDOCK is contacted by e-mail or through any other means foreseen in the Site.

If personal data are collected through cookies, you will be duly advised through our Cookie Policy, and through any channels required by current law.

This document explains how NEWDOCK uses any personal data belonging to Users, collected through the Site or auxiliary devices such as mobile phones or tablets, as well as User rights in personal data protection matters. Furthermore, use of the Site constitutes User acceptance of the provisions contained in this Privacy Policy and its agreement to personal data processing as established therein.

Please note that although our Site may contain links to other websites, this Privacy Policy only applies to this Site, not to any others belonging to redirected companies or organisations. NEWDOCK does not control or approve third party website content, and hereby disclaims all liability derived from the content or privacy policies of third party websites.

In compliance with the provisions established in Regulation (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and in Spanish Act 3/2018, of 5 December, on Personal Data Protection and to guarantee digital rights, and pursuant to the provisions of current regulations, you are hereby informed as follows:

2. Who is the data controller?

Details of your personal data Controller are provided below:

NEWDOCK LP, S.L.U.

Spanish Tax ID (N.I.F.): B01834696

Address: calle María de Molina 6, 5º planta, Madrid

E-mail: lopd@newdock.com

Commercial Registry Record: recorded at the Commercial Registry of Madrid, in tome 40.384, Folio 33, Sheet M-724.395

3. Which categories of personal data are processed?

Each User may provide the following personal details in the contact form: name, surnames, e-mail, telephone number and company.

4. How do we obtain your personal data?

We will process any data directly provided by each User, when interacting with NEWDOCK, or through any other means, as a consequence of accessing and using the Site (such as cookies and other analysis or supervision technologies that may be used to collect certain information when visiting our Site at [….], or third party websites we may redirect you to, or those you may access in order to inform you about our products and services). For further information about our automatic data collection tools, please refer to our Cookie Policy at [….]

5. For what purposes do we process your personal data?

NEWDOCK will process your personal data in a legal, loyal, transparent, adequate, pertinent, limited, accurate and updated manner for the following purposes:

PURPOSE: To handle and resolve any User requests and petitions delivered through the contact e-mail posted on our Site.

LAWFULNESS OF OUR DATA PROCESSING: Your express consent, to the extent that each User expressly agrees by ticking the check-box. If a request is related to the exercise of rights, our lawfulness will be based on compliance with a legal obligation.

6. Will automated decisions be taken?

No automated decisions will be taken based on profiling, except for personalised advertising and the prevention of Internet fraud.

With the information collected on your preferences, based on your browsing patterns, a user profile is created to personalise and promote the quality of our communications and interactions. The logic underlying our profiling activities is to identify matters that may be useful or of interest to you, and to inform you about them more efficiently and specifically. Our algorithms follow this logic and automatically provide you with content or targeted information.

In accordance with the General Data Protection Regulation (Article 21(2)), all Users are entitled to object to the use of their personal data for direct marketing purposes, to include the profiling described above. Please refer to “Data owner rights” below for further detail about your rights and how to exercise them.

7. For how long will we keep your personal data

Your personal data will be stored for the duration of the services provided, and for the time necessary to fulfil our legal obligations. In any case, the information collected in our cookies will be kept for the period of time indicated in our Cookie Policy.

8. Will you data be transferred to third parties?

Our User information is very important to us, which is why we will only assign your data for the purposes foreseen. Without prejudice to the foregoing and if we need to assign your data to groups or persons not indicated herein, we will duly inform you with sufficient advance notice in order to allow you to object to such assignment.

Consequently, you are hereby informed that your data may be assigned to:

– Other companies belonging to the [Goldman Sachs] Group, worldwide, provided that this is necessary for the purposes allowed and is permitted by law. In such cases, these entities will use your Personal Data for these same purposes and in the same terms described in this Data Privacy Statement.

– In particular, your data will be assigned to the hosting provider SHAREPOINT. For further details of its privacy policy, please access the following link: https://privacy.microsoft.com/es-es/privacystatement.

– The necessary processors entrusted with providing the service for which a services agreement is signed, requiring that they uphold duties of confidentiality and apply security measures.

– Authorities or other third parties, if this is required by law or in the context of legal proceedings.

9. Are there international data transfers?

NEWDOCK is part of an international business group. In the course of our commercial activities, we may also transfer your personal data to recipients located outside the European Economic Area (“Third Countries”), where applicable law does not offer the same level of data protection as in your country of origin. When doing so, we will meet all applicable data protection requirements and will adopt adequate protection measures to guarantee the safety and integrity of your personal data, particularly by executing standard contractual clauses in the EU, available here:

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=ES

10. Which are your rights?

All Users may exercise their rights of rectification, limitation on processing, erasure, objection and the right to not be the object of automated individual decision-making, by sending a written and signed request, indicating your full name and enclosing a copy of your Spanish Identity Card (D.N.I.) or other valid identification document, to NEWDOCK LP, S.L.U., at the aforementioned address, or by contacting us by e-mail at lopd@newdock.com.

We may request additional proof of identity to protect your personal data against unauthorised access. Your request will be carefully examined and we will mutually reach the best solution for you.

You may exercise these rights at no cost, unless unfounded or excessive requests are made, in which case the User will bear the cost of processing his/her request.

If in doubt about how we process your personal data, or if you wish to file a complaint about how we have processed your personal data, please contact us at the contact address indicated below to allow an investigation of the matter. If you are dissatisfied with our response or consider that your rights have not been duly upheld, you are entitled to bring a claim before the Spanish Data Protection Agency at www.aepd.es.

11. What happens in case of users under 16 years of age?

If a User is under 16, he/she will need to obtain his/her parents or tutors’ consent before providing any personal data. Persons under 16 may not provide any personal data to us without such consent.

12. Social Networks

Furthermore, NEWDOCK may use social networks, such as Instagram, Facebook and Twitter. For further information, please refer to their Privacy Policies at these links:

– Twitter: https://help.twitter.com/en/rules-and-policies/update-privacy-policy

– Facebook: https://www.facebook.com/privacy/explanation

– Instagram: https://myshadow.org/lost-in-small-print/instagrams-privacy-policy

13. How do we protect your personal data?

NEWDOCK hereby informs you that it has adopted the necessary technical and organisational measures to maintain the necessary level of security regarding the personal data it processes, and has also implemented the necessary devices to avoid any unauthorised access, misappropriation, illegal changes and loss of data.

We have physical, electronic and procedural security systems in place to collect, store and distribute our Users’ personal data.

In compliance with current regulations, NEWDOCK undertakes to fulfil its duty of secrecy towards any personal data provided by our Users during Site browsing, and its duty to save such data on a confidential basis.

In the event of a personal data security breach endangering User rights, NEWDOCK will take the necessary steps to remedy the situation and to mitigate any possible negative effects that such breach may have caused.

14. Which cookies are used?

Without prejudice to our Cookie Policy , this Site uses Google Analytics, an analytical web service provided by Google, Inc., a Delaware-based corporation with headquarters in 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, i.e. text files placed in your computer, to help the Site analyse the use made by its Users. Any information generated by a cookie on your Site use (IP address included) will be directly transferred and stored by Google in its servers in the U.S. Google will use this information on our behalf in order to trace your Site use, issuing reports on Site activity and providing other services related to Site activity and Internet use. Google may transmit such information to third parties if required by law, or if such third parties process information on Google’s behalf. Google will not associate your IP address to any other Google data. You may dismiss the processing of your data or information by blocking cookie use, accordingly setting your browser. However, please be advised that if you do so you may not have access to full Site functionality. By using this Site you agree to Google’s processing of your information in the manner and for the purposes indicated above.

15. How do we protect our site concerning Intellectual and/or industrial property rights?

All our Site contents are protected under intellectual property rights. As a mere example without limitation, this includes graphic design and source codes (except for logos, text, diagrams, illustrations, photographs, language code, software and other Site components). Consequently, the User has recognised that the reproduction, distribution, marketing, transformation and, in general, any other form of exploitation, through any procedure, of all or part of these Site contents, constitutes a breach of NEWDOCK’s intellectual and/or industrial property rights, or of their owner.

Any trademarks or distinctive signs whatsoever contained on the Site are also protected by law.

In no event may the User change or use this intellectual or industrial property in such a way as to be detrimental to NEWDOCK. In such case, NEWDOCK will be entitled to sue for loss and damage derived from third party misuse of its intellectual and industrial property.

NEWDOCK has not granted any licence or authorisation to use its industrial and/or intellectual property rights, or any other property or right related to the Site, its services or contents.

16. Which automatic information do we collect through Site?

These are some examples of the information we collect and analyse: your Internet IP address, used to connect your computer on-line; details of your computer and Internet connection; browser version and type; time zone configuration; types and versions of browser connection to the operating system and platform; browsing history of any URL pages visited from, through and to our Site (date and time included); number of cookies; any telephone number used to call our customer help desk. We may also use browser data such as cookies, Flash cookies (also known as Local Shared Objects) or similar data located in certain areas of our Site to prevent fraud, amongst other purposes. During your Site visits, we use software tools to measure and collect session details, including page response times, downloading errors, duration of visits to certain pages, information on page interaction (mouse clicks, page movements or number of times the mouse passes over certain items) and types of Site log-out. Furthermore, we may also collect technical information to help us identify your device for a diagnostic analysis and to prevent fraud.

17. How to contact NEWDOCK?

If the User has any doubt about NEWDOCK’s privacy, please send us an e-mail at lopd@newdock.com, explaining the reasons for your query. We will do our best to resolve it.

18. Changes in NEWDOCK’s Privacy Policy

NEWDOCK may change and update this Privacy Policy as necessary, to reflect any change in the way in which we use User data or new legal requirements. Consequently, the User will ensure that it has the latest version of our Privacy Policy, Cookie Policy and the Terms and Conditions of Use, in order to be aware at all times of the content collected through the Site, how we use it and the circumstances in which such information may be disclosed to third parties. Any change in our Data Privacy Statement/Policy will be effective as of the date it is posted on our Site.

Without prejudice to the foregoing, any changes that may affect the parties’ business relationship will be notified.