Belt

Privacy Policy

Last Updated: May 22, 2018

1. Introduction This Privacy Policy explains what we do with your personal data in the framework of the provision of the services we offer in the Belt app www.beltsaving.com (hereinafter "Platform"), such as tracking wish lists, your creation of a profile in Belt, communications, etc. (hereinafter "Services"). We also explain the policy on the data we collect when you visit the Platform. For the purposes of the applicable legislation on data protection, you will have to take into account the following: If you reside in a country that is a member of the European Economic Area, the processing of your data and this Privacy Policy will be governed by the General Regulations for the Protection of Data or Regulation [EU] 2016/679) (the "RGPD"). If you reside in a country that is not a member of the European Economic Area, the collection of your personal data will be governed by the same privacy laws. The company responsible for personal data is Federico García with address in Sierra de Atapuerca, Madrid (hereinafter BELT) (hereinafter, "We" or "the Data Controller"). To contact the representative of the Treatment Manager, you can send an email to: support@beltsaving.com Failure to provide certain information indicated as mandatory may mean that it is not possible to manage your registration as a user or the use of certain Services available on the Platform. In order to register and navigate the Platform, you will have to be over 16 years of age. BELT may use your personal information to verify your age and guarantee compliance with this restriction.

2. Legal basis for processing personal data The collection and processing of your personal data is based mainly on the contractual and / or pre-contractual relationship that you have with us. When we send you our newsletters and Services or use the email you have provided us To contact you in a personalized way or recognize you on your next visit, we rely on informed consent. The treatment of the information that our cookies collect is based on the informed consent that you give us, in accordance with current legislation.

3. Personal information that we collect To register on the Platform and identify you, we will ask you to provide us with your email address. To create a profile on the Platform, you can include personal information such as your country or city of residence, photo, name and surname, education, professional experience , and any other complementary information that you want to share on your profile. The information in the profile helps you to get more out of our Services, such as helping to find recruitment professionals and finding business or project opportunities that interest you. In any case, if you do not want this information to be published, do not fill in the corresponding spaces within the profile or delete the information that you have already provided. We do not make automated decisions based on profiles, beyond advertising personalization and legitimate Internet fraud prevention. We receive information through other platforms such as if you register through Facebook or similar technologies. This could include personal text or images available on the external page.

4. Purposes BELT, as the Data Controller, will process your personal data for the following purposes: Manage your registration as a user of the Platform to identify you and give you access to the Services that are available to you as a registered user of the Platform. The development, fulfillment and execution of the contract for the provision of the contracted services such as the subscription of Belt Premium or any other contract with Us through the Platform. Contact you via email, in relation to updates or informative communications related to the functionalities, products or services contracted, including security updates of the Platform, whenever it is necessary or reasonable for its execution. Respond to the requests or requests that you make through the customer service channels available on our Platform. We also use your information to generate aggregate data that does not identify you. For example, generating statistics on our users, their profession or sector, the number of impressions or clicks on a given course or project, or the demographic distribution of visitors.

5. Options As part of the Service and when the user has expressly consented, BELT may use your personal data to provide you with personalized advertising related to our products and services, its own or those of third-party collaborators, through emails or other means of electronic communication. In order to improve the attention we provide you, we inform you that the personal data related to your purchases, interests and preferences may be used by BELT for the purposes of analysis, generation of use profiles, marketing studies, quality surveys and improvement of interaction with our clients. If you do not want to receive certain communications by email, simply access the Notifications section within the Profile Edition and you will be able to manage the emails and notifications that reach you. Likewise, you can unsubscribe from notifications by following the instructions that we provide in each communication.

6. Data retention period We will keep your personal data during the validity of the contractual relationship with us and, once terminated, during the limitation periods of the obligations that may have arisen from the data processing and / or the periods that legally established.

7. Recipients of the data To fulfill the purposes indicated in this Privacy Policy, it may be necessary for us to communicate or transfer your personal data to third parties for the following reasons: Business transfers: in relation to any reorganization, restructuring, merger or sale, or other transmission of assets, we will transfer information, including personal information, as long as the receiving party agrees to treat your personal information in a way that complies with our Privacy Policy. Service providers: to provide services on our behalf or to assist us with the services we provide to you. For example, we contract service providers to provide marketing, advertising, communications, infrastructure and IT services, to personalize and optimize our service, to process transactions with credit cards or other payment methods, to provide customer service services. customer, collect debts, analyze and improve data (such as data on user interactions with our service), and process and administer satisfaction surveys. For efficiency of the service, said collaborators and providers may be located in the United States or other countries or territories located outside the European Economic Area that do not provide a level of data protection comparable to that of their country or, where appropriate, that of the Union. European. By accepting this Privacy Policy, you expressly authorize us to process and communicate your personal data to the aforementioned companies and / or to transfer your personal data to the aforementioned service providers as processors located outside the European Economic Area for the purposes described here and give you a complete service. When, during an information exchange, we transfer personal information to countries outside the European Economic Area and to other areas that have data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and that it allows it. current legislation on data protection.

8. Data protection rights As the Data Controller, we undertake to respect the confidentiality of your personal data and to guarantee the exercise of your rights. At all times you can exercise the following rights: Right of Access. You have the right to confirm that we are treating your personal data and, if so, to obtain a copy of said data and complete information about the treatment. Right of rectification. You have the right to correct errors, modify inaccurate or incomplete data and guarantee the accuracy of the information being processed. Right of deletion. You have the right to request the deletion of your data without undue delay, in case the treatment is illegal or the purpose that motivated its treatment or collection has disappeared. Right to limitation of treatment. You have the right to request the suspension of the treatment in case it is illegal or the accuracy of the data has been contested. Right of opposition. You have the right to oppose the processing of your data when it is intended for direct marketing or when the processing must be stopped for reasons related to your personal situation, unless a legitimate interest is proven or is necessary for the exercise or defense of claims. Right not to be the subject of individualized decisions. You have the right not to be the subject of a decision based solely on automated processing, including profiling, that produces legal effects or affects you, unless it is necessary for the performance of a contract, is permitted by Law or you have given your consent. explicit consent. To exercise these rights please send an email to: support@beltsaving.com, clearly indicating (i) your identity, indicating, at least, your full name and the email address you used when buying or registering at SAVE as well as a document that allows you to prove your identity, and (ii) the right or rights you exercise. You can go to the Control Authority of your country for any claim such as to request the protection of your rights, if you consider it appropriate. The exercise of these rights is free, unless manifestly unfounded or excessive requests are made, in which case the interested party may be required to assume the cost of the processing.

9. Information about cookies We use cookies, which are small files with information about your browsing on this Platform and whose main purpose is to facilitate your browsing on it. Please read our Cookies Policy to learn more about the cookies we use, their purpose and other information of interest.

10. Modifications We will update this Privacy Policy from time to time and in response to requirements derived from legal, regulatory or operational changes. We will notify you of such changes (including their entry into force) in accordance with the law.