Privacy Policy

ETHICAL CHANNEL

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What will we use your data for?

In general, your personal data will be used to interact with you and to provide you with our
services.

It may also be used for other activities, such as sending you advertising or promoting our
activities.

Why do we need to use your data?

Your personal data is necessary for us to be able to deal with you and to provide you with
our services. We will provide you with a number of check boxes to enable you to make a
clear and simple choice about the use of your personal information.

Who will know the information we ask for?

In general, only duly authorised staff of our organisation will have access to the information
we ask you for.

Similarly, those entities that need to have access to your personal information in order for us
to be able to provide you with our services may have access to your personal information.
For example, our bank will know your details if payment for our services is made by credit
card or bank transfer.

Likewise, those public or private entities to which we are obliged to provide your personal
data in order to comply with any law will be aware of your information. To give you an
example, the Tax Law obliges us to provide the Tax Agency with certain information on
economic transactions exceeding a certain amount.

In the event that, apart from the aforementioned cases, we need to disclose your personal
information to other entities, we will request your prior permission through clear options that
will allow you to decide in this regard.

How will we protect your data?

We will protect your data with effective security measures according to the risks involved in
the use of your information.

To this end, we have adopted a Data Protection Policy and annual checks and audits are
carried out to ensure that your personal data is secure at all times.

Will we send your data to other countries?

In the world there are countries that are safe for your data and others that are not so safe.
For example, the European Union is a safe environment for your data. Our policy is not to
send your personal information to any country that is not safe from a data protection point of
view.

In the event that, in order to provide you with the service, it is necessary to send your data to
a country that is not as secure as Spain, we will always request your prior permission and
we will apply effective security measures to reduce the risks of sending your personal
information to another country.

How long will we keep your data?

We will retain your data for the duration of our relationship and for as long as we are
required to do so by law. Once the applicable legal periods have expired, we will dispose of it
in a secure and environmentally friendly manner.

What are your data protection rights?

You can contact us at any time to find out what information we hold about you, rectify it if it is
incorrect and delete it after the end of our relationship, where this is legally possible.

You also have the right to request the transfer of your information to another entity. This right
is called “portability” and may be useful in certain situations.

To request any of these rights, you must make a written request to us, together with a
photocopy of your ID card, so that we can identify you.

We have specific forms available at our offices for requesting these rights and we offer you
our assistance in filling them out.

To find out more about your data protection rights, you can consult the website of the
Spanish Data Protection Agency (www.agpd.es).

Can you withdraw your consent if you change your mind at a later point in
time?

You can withdraw your consent if you change your mind about the use of your data at any
time.

For example, if you were once interested in receiving advertising for our products or
services, but no longer wish to receive advertising, you can let us know using the opt-out
form available at our offices.

If you feel that your rights have been disregarded, where can you make a complaint?

If you believe that your rights have been disregarded by our entity, you can make a
complaint to the Spanish Data Protection Agency, by any of the following means:

Electronic site: www.agpd.es
Postal address:
Spanish Data Protection Agency
C/ Jorge Juan, 6
28001-Madrid
By telephone:
Tel. 901 100 099
Tel. 91 266 35 17

Making a complaint to the Spanish Data Protection Agency does not entail any cost and it is
not necessary to have the assistance of a lawyer or solicitor.

Will we profile you?

It is our policy not to profile users of our services.

However, there may be situations where, for service delivery, marketing or other purposes,
we need to profile information about you. An example might be the use of your purchase or
service history to enable us to offer you products or services tailored to your tastes or needs.

In such cases, we will implement effective security measures to protect your information at
all times from unauthorized persons seeking to use it for their own benefit.

Will we use your data for other purposes?

It is our policy not to use your information for purposes other than those we have explained
to you. If, however, we need to use your data for other activities, we will always ask for your
permission beforehand by providing you with clear options to enable you to decide.

DATA PROTECTION POLICY

The Management / Governing Body of OLE COMUNICACIÓN SL (hereinafter, the

controller), assumes the utmost responsibility and commitment to the establishment, implementation and maintenance of this Data Protection Policy, ensuring continuous improvement of the controller with the aim of achieving excellence in relation to compliance with 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 repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and Spanish personal data protection regulations (Organic Law, specific sectoral legislation and its implementing rules).

The Data Protection Policy of OLE COMUNICACIÓN SL is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the regulatory and jurisprudential framework governing this policy, and is able to demonstrate it to the competent supervisory authorities.

In this regard, the controller shall be guided by the following principles which should serve as a guide and frame of reference for all its staff in the processing of personal data:

Data protection by design: the controller shall implement, both at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to effectively implement data protection principles, such as data minimisation, and to integrate the necessary safeguards into the processing.
Data protection by default: the controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only personal data that are necessary for each of the specific purposes of the processing are processed.
Data protection throughout the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire information lifecycle.
Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and transparently in relation to the data subject.
Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a way incompatible with those purposes.
Data minimisation: personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Accuracy: personal data shall be accurate and, where necessary, kept up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are erased or rectified without delay.
Limitation of the storage period: personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
Integrity and confidentiality: personal data shall be processed in such a way as to ensure appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical or organisational measures.
Information and training: One of the keys to ensuring the protection of personal data is the training and information provided to staff involved in the processing of personal data. During the life cycle of the information, all staff with access to the data shall be properly trained and informed about their obligations in relation to compliance with data protection regulations.

The Data Protection Policy of OLE COMUNICACIÓN SL is communicated to all staff of the controller and made available to all interested parties.

Consequently, this Data Protection Policy involves all staff of the data controller, who must know and assume it, considering it as their own, each member being responsible for applying it and verifying the data protection rules applicable to their activity, as well as identifying and providing opportunities for improvement that it deems appropriate in order to achieve excellence in relation to compliance.

This Policy will be reviewed by the Management / Governing Body of OLE COMUNICACIÓN SL, as many times as deemed necessary, to adapt, at all times, to the current provisions on the protection of personal data.

Information in compliance with personal data protection regulations

In Europe and Spain there are data protection regulations designed to protect your personal information that are mandatory for our company, so it is very important for us that you fully understand what we will do with the personal data we ask you for, so we will be transparent and give you control of your data, with simple language and clear options that will allow you to decide what we will do with your personal information, please do not hesitate to ask us if you have any questions after reading this information. Thank you for your cooperation.

NAME / COMPANY NAME: OLE COMUNICACIÓN, S.L.
CIF / NIF B30843106
ACTIVITY / SOCIAL PURPOSE: Provision of telecommunications services.
ADDRESS / BUSINESS ADDRESS Avda. Villamartín, Edif. Centro Zenial, local 7-8
TELEPHONE: 902 006 757
FAX: 902 006 758
E-MAIL ADDRESS: info@olecomunicacion.tv
WEB ADDRESS: http://www.olecomunicacion.tv
REGISTRATION DATA IN THE TRADING REGISTER / PUBLIC REGISTER: Registration in the Mercantile Register of Murcia, Section 8, Page 72354, Volume 2719, Folio 48.