PRIVACY POLICY

1.- GENERAL INFORMATION

Below we explain the Personal Data Protection Policy that will govern the use of this Website and any applications or services that are accessed through it.

In compliance with the duty of information contained in article 5 of Directive 2000/31 /EC of the European Parliament and of the Council, of June 8 2000 and in article 10 of 34/2002 Law, of 11 July, on services of the information society and electronic commerce, provides that CROWDFUNDING BIZKAIA PLATAFORMA DE FINANCIACIÓN PARTICIPATIVA, S.L.U. (hereinafter Crowdfunding Bizkaia ), is the owner and /or publisher of the Website https://crowdfundingbizkaia.com (hereinafter "Web page").

Crowdfunding Bizkaia is a company established in 2017 and fully owned by the Provincial Council of Bizkaia with registered office in Bilbao (48011), Gran Vía 25, provided with Tax ID number (CIF) B95895298 and registered in the Commercial Registry of Bizkaia to Volume 5730, Page 130, Sheet BI-70634, Inscription 3, owns the Website.

2.- ADDRESSEES OF THE PRIVACY POLICY

This Privacy Policy applies to anyone who accesses, uses or browses the Website and to any person who, by any remote communication channel (email, telephone, etc.) uses any of our services, asks us for information or contacts us in any way.

Our Privacy Policy can be updated and /or modified at any time, so we advise you to review it frequently, especially before using any functionality of the Website or using any service offered by the same.

3.- RESPONSIBLE FOR DATA PROCESSING AND PRIVACY

In accordance with the provisions of the 3/2018 Constitutional Law, of December 5, on the Personal Data Protection and the guarantee of digital rights and 2016/679 Regulation (EU), of the European Parliament and of the Council, of April 27 2016, regarding the protection of individuals with regard to the processing of personal data and the free circulation of these data (EU Regulation), as well as in the current provisions of 15/1999 Constitutional Law, of December 13, Protection of Personal Data and its Development Regulation, that is, Royal Decree 1720/2007, you are informed that by entering your data through the electronic forms enabled on the Website, you are supplying certain personal data that will be processed in an automated way and that will be incorporated into the databases, registration of process activities and /or the corresponding files in order to carry out their management of which Crowdfunding Bizkaia is the owner and responsible.

The Data Protection Officer (DPO) of Crowdfunding Bizkaia is the Head of the Section of Legal Advice, Information Security and Data Protection, directly attached to the Cabinet of Modernization, Good Governance and Transparency of the Provincial Council of Bizkaia

Users can contact the DPO of Crowdfunding Bizkaia by ordinary mail addressed to CROWDFUNDING BIZKAIA Plataforma de Financiación participativa S.L. Plaza del Sagrado Corazón nº5, 7ª, CP 48011, Bilbao-BIZKAIA or sending an email to the following address: crowdfundingbizkaia@bizkaia.eus.

The Website browsing of a User is carried out in an entirely anonymous way, except for those private sections restricted to Users, which are accessed prior to requesting their identification key. The User is solely responsible for the conservation and non-disclosure of their identification data. Therefore, it is your responsibility to keep it secret and not reveal your password to anyone. No personal data is collected, except when the User expressly and freely provides such information.

4.- CATEGORIES OF PERSONAL DATA

Through the Web Page and the different forms established in it, the following categories of personal data can be collected, stored and used:

• Contact information, including, first and last names, mobile phone, email or address.
• Information to identify you, including, ID document, date of birth, gender or photograph.
• Asset information, including, the accreditation of your annual income or your financial assets.
• Bank information, including the bank account number.
• Information about your Web browsing and behavior on the Website, such as the number of visits and clicks on the Website (including, the date and time of visit), the sections visited, the response times of the Website, information on interaction with the Website or other data collected through cookies.

Each form on the Website specifies what the optional data is and what the mandatory minimums are (identified by an asterisk), without which it will not be possible to register and /or make use of any of the services provided by Crowdfunding Bizkaia on the Website.

5.- DEADLINE CONSERVATION PERIOD

The data of the User will be kept for the time necessary for the purpose that justified its collection and processing, and once this purpose has been completed, the personal data will be deleted, as long as it is not necessary to block them in order to respond to possible responsibilities, for the formulation, exercise or defense of claims for the expiry period provided by law.

Given the above, Crowdfunding Bizkaia will not store the data of the User for more time than necessary to comply with the purposes of the processing established in this Privacy Policy, or in accordance with the periods established in the applicable legislation.

Therefore, when the purpose for which it was collected has been fulfilled in relation to a specific type of information, it will be deleted or anonymized the relevant personal data that it includes as soon as reasonably possible.

In general, we will store your data while you use our Website and /or have a user account on the Website. In any case, we will delete your data if you stop using our Website:

• And it has been 5 years since the last use of our Website, if you did not delete your user account.
• And 3 years have passed since the deletion of your user account.

These deadlines will not be applicable in the following cases:

• Regarding banking, payment and billing information. In this case, your information will be kept for the period stipulated in the applicable tax and accounting legislation.
• Regarding the information that we must keep to demonstrate compliance with our legal obligations, such as for the fulfillment of our data protection obligations. In this case, the strictly necessary information will be kept during the expiry period of said obligations.
• When we process information based on your consent. In this case, we will keep this information until you revoke that consent or, failing that, for the time strictly necessary taking into account the purpose for which we collected this information.

6.- SECURITY MEASURES

Crowdfunding Bizkaia undertakes to implement all security measures of a technical and organizational nature that are adequate and sufficient to guarantee the security of personal data as well as to prevent them from being altered, treated, accessed or eliminated by not authorized third parties, in accordance with the legal provisions cited above. These measures will be adapted to the nature of the data that is being processed at all times.

7.- PURPOSES OF THE TREATMENT AND LEGAL BASES

The purposes of the data processing provided by the users to Crowdfunding Bizkaia are the following:

• Provide the services offered by the Website to the Users. Legal basis of the processing: The legitimate interest of Crowdfunding Bizkaia in the improvement of its Website and its services.
• The creation and management of Promoter and Investor profiles. Legal basis of the processing: The execution of the contractual relationship established between Crowdfunding Bizkaia and the User.
• The management of business projects. Legal basis of the processing: The execution of the contractual relationship established between Crowdfunding Bizkaia and the User.
• Resolve any doubt or incident related to the use of the Website.
• The collection, if applicable, of the corresponding commissions. Legal basis of the processing: The legitimate interest of Crowdfunding Bizkaia in perceiving its fees for the services provided on the Website.
• Prevent any activity that violates the Terms of Service. Legal basis of the processing: Compliance with obligations, facilitate the exercise of rights and ensure the security of the Website.
• Customize and improve the services and contents. Legal basis of the processing: The legitimate interest of Crowdfunding Bizkaia consisting in the improvement of its Website and its services and, where appropriate, its consent.
• Inform the users of our services and updates. Legal basis of the processing: The legitimate interest of Crowdfunding Bizkaia consisting in the improvement of its Website and its services and, where appropriate, its consent.

• Compare the information to ensure its accuracy and verify it with third parties. Legal basis of the processing: The legitimate interest of Crowdfunding Bizkaia consisting in the improvement of its Website and its services.

  Sending commercial communications, advertising, newsletters and other communications by Crowdfunding Bizkaia. Legal basis of processing: Your consent.

  In no case, the User is required to receive the aforementioned communications, opting not to mark the corresponding boxes of the form, or using the channels enabled in each communication. In this context, if at any time you do not wish to continue receiving communications of this nature, you can revoke your consent by sending the relevant notification to the address crowdfundingbizkaia@bizkaia.eus, or using the link enabled for this purpose in received commercial communications. The request will be answered as soon as possible.

• And all those other purposes that Crowdfunding Bizkaia implements and offers to its Users as an improvement of the services of the Website. The legitimate interest of Crowdfunding Bizkaia consisting in the improvement of its Website and its services.

8.- COMMUNICATION OF DATA AND INTERNATIONAL TRANSFERS

The recipients of the data collected are exclusively the employees of Crowdfunding Bizkaia or third companies that provide services to this entity.

We inform you that for the fulfillment of the purposes described above, in some cases it is essential to access your data by third parties responsible for the treatment that provide services to Crowdfunding Bizkaia. These third parties are usually related to services such as maintenance, the development of computer tools and servers, services or payment gateway, third party applications to identify you, among others.

In this case, the service providers will be bound by a contract for the provision of services, which will expressly include equivalent privacy and data protection obligations to those required for the employees of Crowdfunding Bizkaia and will be expressly prohibited from assigning them of that data to any third party, unless otherwise provided in this Privacy Policy or its assignment is required by applicable law.

In any event, when the communication of data to third parties, other than those in charge of processing, is not necessary for the correct provision of the contracted service, we will expressly require your consent in the data collection forms, in which we will inform you of the purpose of the treatment and of the identity or activity sectors of the possible assignees of the personal data, offering you previously the possibility of accepting or not accepting this assignment. In another case, when the transfer of the data derives, for example, from a legal obligation, we will inform you expressly and prior to the assignment, of which data is subject to transfer, as well as what is the legal basis for such transfer of data.

In general, we try to get all your information located in the European Economic Area, therefore, we do not carry out international transfers of data to third countries, except in those cases where there is a legal obligation or the owner of the data has expressly consented.

9.- RESPONSIBILITY OF THE USER

The User is responsible for the personal data provided to Crowdfunding Bizkaia, for which he/she declares, under his responsibility, that the data provided to it is true, truthful and correct, reserving the right to exclude, limit or suspend access to the Website or the services to any User who has provided false, incorrect or inaccurate information, without prejudice to any other actions that may be required by Law.

The User expressly declares that:

• All the information provided is true and will be updated to date. In the event that the information varies over time, the User is obliged to modify that information or to communicate it to Crowdfunding Bizkaia.
• He/She will not use the personal data to which he/she has access through the Website incorrectly or illegally, using them for purposes other than those foreseen, reproducing them, transferring them, modifying them and /or transforming them where appropriate.

10.- USER RIGHTS

Finally, the User may exercise their rights of access, rectification, cancellation and deletion of their data, as well as the opposition and limitation of the processing and portability of their data, by going to the following address : CROWDFUNDING BIZKAIA PLATAFORMA DE FINANCIACIÓN PARTICIPATIVA, S.L.U., Bilbao (48011), Plaza Sagrado Corazón de Jesús 5, 7th floor, or at the following email address: crowdfundingbizkaia@bizkaia.eus

To exercise the aforementioned rights, the User has at his/her disposal standard forms provided by the Spanish Agency for Data Protection through the following link: https://www.aepd.es/reglamento/derechos/index.html

Without prejudice to any other administrative appeal or legal action, the User shall have the right to file a claim with a Control Authority, which in the case of Spain is the Spanish Data Protection Agency, in particular in the Member State in which he/she has his/her habitual residence, place of work or place of the alleged infringement, in case he/she considers that the processing of his personal data is not adequate to the regulations, as well as in the case of not seeing the exercise of their rights. The supervisory authority to which the claim was filed will inform the claimant about the course and result of the claim.

The Control Authority in Spain is:

Spanish Agency for Data Protection

C/Jorge Juan nº 6, 28001 - Madrid

Any claim can be made electronically in https://sedeagpd.gob.es/venue-electronic-web/views/formNuevaReclamacion/nuevaReclamacion.jsf