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(Current wording effective 12/17/2019)

At Ternua Group SL we take care to secure the personal data that we process, and ensure strict compliance with the relevant regulations in effect.

This Privacy Policy (hereinafter, the “PRIVACY POLICY”) which in general terms governs Ternua Group SL’s collection and processing of the personal data you provide us as a user of the website available at the domain https://www.lorpen.com (hereinafter, the “WEBSITE”), including any services available through the WEBSITE at any time. The above is notwithstanding the specific provisions established in certain sections, forms, or services available on the WEBSITE for the purpose of providing you with relevant information and, where applicable, to request your consent.

Ternua Group SL reserves the right to modify the PRIVACY POLICY in order to adapt it to new legislation, case law, and/or administrative changes, as well as practices that Ternua Group SL may engage in via the WEBSITE at any point, while taking your rights and interests into account at all times.

Ternua Group SL shall provide you with suitable technical resources so that you may access the PRIVACY POLICY in order to ensure proper compliance with the relevant data obligations we are required to meet pursuant to current data protection law.

1. Who is the Controller of your data?

The Data Controller is Ternua Group SL, a company with registered address in Arrasate-Mondragón (Gipuzkoa, Spain), Polígono Kataide Musacola, Pabellón 25, listed in the Commercial Register of Gipuzkoa under volume 1230, folio 104, sheet SS-4588, with tax identification number (C.I.F.) B-20212775.

If you have any questions regarding the PRIVACY POLICY and/or how we process your personal data, you can contact us at the aforementioned postal address or by sending an email to lopd@ternuagroup.com.

2. How have we obtained your personal data?

The data we process at Ternua Group SL has been obtained from you by means of (i) the various forms which you complete while browsing our WEBSITE and/or via other channels (e.g. registering as a WEBSITE user, where applicable, contact forms, job vacancy and/or hiring process forms, etc.); (ii) email queries sent by you.

In the event that you have provided data belonging to a third party, you guarantee that you have informed said third party of the PRIVACY POLICY and that you have obtained their authorization to provide their data to Ternua Group SL for the purposes indicated below.

3. What type of data do we process?

The data we process at Ternua Group SL are those provided by you while browsing the WEBSITE, via the relevant forms we use to formalize our contact with you and/or via email.

In particular, at Ternua Group SL we process the following types of data:

• Identifying and contact details (e.g. full name, national identity number [DNI], postal and email addresses, phone number, etc.).
• Usernames and passwords for registered users of the WEBSITE.
• Internet browsing data (e.g. IP address, web page visits, connections to Wi-Fi networks, etc.).
• Personal data, details on training, employment history, etc. (in the case of Ternua Group SL job applications/offers and/or hiring processes in which you participate voluntarily).

4. For what purpose do we process your personal data and on what legal grounds?

Your data is processed for the following purposes:

• Manage and process your registration as a user of the WEBSITE, where possible.
• Manage your access to, and use of the content and services Ternua Group SL provides you through the WEBSITE, including blogs, social networks or any other functionality that may be accessible from the WEBSITE at any time.
• Process and manage requests for information, suggestions, complaints, or claims made through the WEBSITE or by email.
• Manage your job application or registration for a job offer and participation in the corresponding hiring process.

Ternua Group SL's processing of your personal data, pursuant to applicable regulations, is based on the consent you granted at the time you voluntarily provided us with your personal data, which was collected through the corresponding tools of the WEBSITE.

You may withdraw your consent to processing based on said consent freely, at any time, and at no cost, under the terms set out in section 7 below.

5. Who do we share your data with?

Your personal data may be shared with the following third parties:

• To public authorities and agencies to which Ternua Group SL is legally required to provide your data, where applicable.
• To entities of the corporate group of which Ternua Group SL is a member (duly identified in the link below), provided your consent has been granted, for the purposes of addressing requests and queries and/or sending you marketing communications related to said entities and their respective activities or products.

There are no plans for your data to be subject to international transfer.

6. How long will your data be kept?

In general, your personal data shall be kept until such time as you withdraw your consent to the processing of your data or request its erasure, and for as long as necessary to meet Ternua Group SL’s legal obligations.

In any case, Ternua Group SL has internal data wiping policies to control the length of time during which it holds personal data. Said data may be erased when it is no longer required and/or suitable for its original purpose.

For managing job applications, your data will be stored for a maximum of 2 years.

7. What are your rights?

Current data protection law grants you a series of rights relative to your personal data. You may exercise these rights while your data is being processed. Your rights are as follows:

• Access to your data: you have the right to access your data to find out what personal data pertaining to you we hold.
• Request rectification or erasure of your data: under certain circumstances, you have the right to rectify any inaccurate data pertaining to you that we process, or to request its erasure when, among other reasons, the data are no longer necessary for their original purpose.
• Request restriction to the processing of your data: under certain circumstances, you have the right to request restriction to the processing of your data. If you exercise this right, we will only store your data for the purposes of exercising or defending complaints pursuant to current data protection law.
• Portability of your data: under certain circumstances, you have the right to receive the personal data pertaining to you that you have provided to us. The data will be provided to you in a structured, commonly used, machine-readable format that can be shared with another data controller.
• Object to the processing of your data: under certain circumstances, and for reasons related to your particular situation, you have the right to object to the processing of your data. If you exercise this right, we will cease to process your data except where it must be held on compelling legal grounds, or for the purpose of filing or defending possible complaints.

You also have the right to revoke your consent at any time, notwithstanding the legality of any processing based on the consent you provided prior to revoking it.

You may exercise these rights via written request to Ternua Group SL at the address indicated in Section 1 or by emailing lopd@ternuagroup.com.

Lastly, you may submit a complaint to the competent supervisory authority (in Spain, the Spanish Data Protection Agency), particularly when you have been unable to exercise these rights to your satisfaction. You can contact the aforementioned authority via their website: www.aepd.es.

8. Security measures

Ternua Group SL will process your data in a strictly confidential manner at all times, and will uphold the mandatory duty of secrecy, pursuant to the provisions of the relevant data protection legislation. Ternua Group SL will adopt the technical and organizational measures necessary to guarantee the security of your data and to avoid alteration, loss, or unauthorized access thereto or processing thereof, taking into account the state of technology, the nature of the data stored, and the risks to which they are exposed.

9. Cookies policy

You can also access Ternua Group SL’s Cookies Policy via the following link.