Personal Data Protection Policy

Personal Data Protection Policy of the company Televes, S.A.U.

In compliance with the existing regulation on data protection, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), Spanish Data Protection and Guarantee of Digital Rights Act (LOPDGDD, Act 3/2018 of 5 December), we hereby inform you of the Personal Data Protection Policy regarding the processing of personal data, as described below.

Personal data controller

The person responsible for the treatment is the legal entity that determines the intent and means of processing personal data. In other words, the person responsible decides how and for what purposes the personal data is processed.

For the intended use of this Data Protection Policy, the person responsible for the processing of personal data is:

Identity: Televes Italia, S.R.L. – VAT Nr: IT04301520963.
Address: Via Liguria 16. 20068 – Peschiera Borromeo (MI) – Italy
Contact phone number: 0251650604
Contact e-mail: dpo@televescorporation.com

Data Protection Officer contact

Televes Corporation has internally appointed a Data Protection Officer. Those interested may contact the Data Protection Officer at the following e-mail address:

Televes' Data Protection Officer: dpo@televescorporation.com

What personal information do we process and how do we protect it?

Personal data is all information about an identified or identifiable natural person.

For the purposes established in this Privacy Policy, the responsible party collects and treats the personal data that is explained in each type of treatment, and that will depend on the different services that you request or the contractual relationship that you maintain with our entity.

Our organization is committed to treat with total confidentiality and to apply the appropriate security measures, physical, technical and organizational, for the protection of your personal data.

You guarantee and respond, in any case, of the veracity, accuracy, validity and authenticity of the personal data provided and undertakes to keep them duly updated.

Processing of Clients' data

1. What kind of personal data do we treat?

Identification data: name, ID, address, telephone, email.
Financial data: bank account, credit card data.
Academic and professional data: profession, position, experience, degrees.
Data related to transactions: products and services provided.

2. What is the purpose of processing your personal data?

The personal data provided will be used for managing the data of the company's clients, for the maintenance of the business relationship, and for the accounting, administrative and billing management, as well as for tax compliance purposes.

We have also provided for publicity and market research, in which case express consent will be requested from the person concerned.

The submitted personal data will be stored for as long as there is a business relationship between both parties. Should you decide to erase your personal data, the data may remain in our databases within the time limits established by law, for us to be able to meet the accounting and tax obligations; the data will be erased once all the legal deadlines expire.

3. Why is it legitimate to process your data?

The legal grounds for the processing of your data are that processing is necessary for the performance of a contract and for the controller to comply with a legal obligation.

Communication of special deals and promotions which might be of interest to you is based on the express consent we will be requesting from you.

4. To whom may your data be communicated?

Data might be transferred to other companies in the Televes Corporation, insofar as it is required to meet the contractual relationship. Some of these companies might be located in third countries. An updated list of all the companies in the Televes Corporation can be found at the end of this document.

Data will also be transferred to public bodies as required by legal obligation.

No other international transfer of data is foreseen.

Processing of Contacts and potential customers' data

1. What kind of personal data do we treat?

Identification data: name, address, telephone, email.

2. What is the purpose of processing your personal data?

The processing of the personal data submitted in the contact form aims at managing the business and potential customers' contacts.

We have also provided for publicity and market research, in which case express consent will be requested from the person concerned.

The submitted personal data will be stored for as long as there is a business relationship between both parties. Should you decide to erase your personal data, the data will be removed from our contact database.

3. Why is it legitimate to process your data?

The legal basis for the processing of your data is the express consent we will be requesting from you.

4. To whom may your data be communicated?

Your data could be transferred to other companies within Televes Corporation, for which the express consent of the interested party is requested.

Neither do we foresee any international transfer of personal data.

Processing of Providers' data

1. What kind of personal data do we treat?

Identification data: name, address, telephone, email.
Financial data: bank account, credit card data.
Academic and professional data: profession, position, experience, degrees.
Data related to transactions: products and services provided.

2. What is the purpose of processing your personal data?

3. Why is it legitimate to process your data?

The legal grounds for the processing of your data are that processing is necessary for the performance of a contract and for the controller to comply with a legal obligation.

4. To whom may your data be communicated?

Your data could be transferred to other companies within Televes Corporation, for which the express consent of the interested party is requested.

Concessions to public governing bodies that are necessary due to legal obligations could also be made.

No international transfers of personal data are planned.

Processing of Job candidates' data

1. What kind of personal data do we treat?

Identification data: name, ID, date of birth, address, telephone, email address, image.
Personal characteristics data: Sex, marital status, nationality, age, date and place of birth.
Academic and professional data: profession, position, experience, degrees.

2. What is the purpose of processing your personal data?

The personal data you provide us is used for the management of the company's selection processes.

The submitted personal data shall be retained as long as the person concerned has not withdrawn his/her consent, for us to be able to use the curriculum vitae in future selection processes. Should you decide to erase your personal data, the data will be removed from our database of job candidates.

3. Why is it legitimate to process your data?

The legal basis for the processing of your data is the express consent we will be requesting from you.

4. To whom may your data be communicated?

Your data might be transferred to other companies in the Televes Corporation, to be included in other staff selection processes. Some of these companies may be established in third countries, this is why we shall request express consent from the person concerned prior to any international transferring of the data if this should be the case. An updated list of all the companies in the Televes Corporation can be found at the end of this document.

No other international transfer of data is foreseen.

Processing of Product users' data

1. What kind of personal data do we treat?

Identification data: name, ID, address, telephone, email.
Data related to transactions: products and services provided.

2. What is the purpose of processing your personal data?

The personal data you provide us is used for the management of data pertaining to the users and owners of products from the company, to provide them with after-sales and technical support services.

We have also provided for publicity and market research, in which case express consent will be requested from the person concerned.

3. Why is it legitimate to process your data?

The legal basis for the processing of your data is the performance of a contract.

Communication of special deals and promotions which might be of interest to you is based on the express consent we will be requesting from you.

4. To whom may your data be communicated?

Your data could be transferred to other companies within Televes Corporation, for which the express consent of the interested party is requested.

No international transfers of personal data are planned.

Processing of Course attendees' data

1. What kind of personal data do we treat?

Identification data: name, ID, address, telephone, email address.
Academic and professional data: profession, position, degrees.

2. What is the purpose of processing your personal data?

The personal data you provide us is used for the recording of the attendees to the courses the company gives about its own products and the technologies used.

We have also provided for publicity and market research, in which case express consent will be requested from the person concerned.

The submitted personal data will be stored for as long as you don't request the erasure of your data. Should you decide to erase your personal data, the data will be removed from our database of course attendees.

3. Why is it legitimate to process your data?

The legal basis for the processing of your data is the express consent we will be requesting from you.

4. To whom may your data be communicated?

Your data could be transferred to other companies within Televes Corporation, for which the express consent of the interested party is requested.

No international transfers of personal data are planned.

Processing of Instructors' data

1. What kind of personal data do we treat?

Identification data: name, ID, address, telephone, email address.
Financial data: bank account.
Academic and professional data: profession, position, degrees.

2. What is the purpose of processing your personal data?

The personal data you provide us is used for the management of the instructors that teach the company's courses.

3. Why is it legitimate to process your data?

The legal grounds for the processing of your data are that processing is necessary for the performance of a contract and for the controller to comply with a legal obligation.

4. To whom may your data be communicated?

Data is transferred to entities such as Xunta de Galicia, Fundación Tripartita, the National Agency for Tax Administration or the Social Security Administration, as required to comply with legal obligations.

Other data transfers may be carried out for legitimate purposes relative to the company's activities: Bank data (Tax identification number, full name and bank account number) will have to be transferred to the financial institutions in charge for the payment process of the instructors' fees.

Your data could be transferred to other companies within Televes Corporation, for which the express consent of the interested party is requested.

No international transfers of personal data are planned.

What are your rights when you provide us your personal data?

In accordance with the applicable regulations on data protection, you have a series of rights in relation to the processing of your personal data. The exercise of these rights will be free of charge for you, except in cases where manifestly unfounded or excessive requests are made, especially for repetitive ones.

These rights are the following:

a. Right to information: You have the right to be informed in a concise, transparent, intelligible and easily accessible way, with a clear and simple language, about the use and treatment of your personal data.

b. Right of access: You have the right to ask us at any time to confirm if we are treating your personal data, to provide you with access to them and to information about your treatment and to obtain a copy of said data. The copy of your personal data that we provide will be free of charge, but the request for additional copies may be subject to the collection of a reasonable amount based on administrative costs. For our part, we can ask you to prove your identity or require more information that is necessary to manage your request.

c. Right of rectification: You have the right to request the correction of inaccurate, non-updated or incomplete personal data concerning you. You may also request that incomplete personal information be completed, including through an additional statement.

d. Right of withdrawal: You have the right to request the deletion of your personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected. However, this right is not absolute, so that our organization may continue to keep them duly blocked in the cases foreseen by the applicable regulations.

e. Right to limit treatment: You have the right to request that we restrict the processing of your personal data which means that we can continue to store them, but not continue treating them if any of the following conditions are met:

You dispute the accuracy of the data, for a period that allows the responsible to verify the accuracy of the same;
the treatment is unlawful and you object to the deletion of the data and request instead the limitation of its use;
our entity no longer needs the data for the purposes of the treatment, but you need it for the formulation, exercise or defense of claims;

You have opposed the treatment, while verifying if the legitimate reasons of our entity prevail over yours.

f. Right to data portability: You have the right to have your data transmitted to another data controller in a structured, commonly used and machine-readable format. This right applies when the processing of your personal data is based on the consent or execution of a contract and this treatment is carried out by automated means.

g. Right of opposition: This right allows you to oppose the processing of your personal data, including the preparation of profiles. We will not be able to attend to your right only when we process your data in the event that we accredit legitimate reasons for the treatment or for the formulation, exercise or defense of claims.

h. Right not to submit to automated decisions, including profiles: This right allows you not to be the subject of a decision based solely on automated processing, including the preparation of profiles, which produce - said decisions - legal effects or affect you in a similar way. Unless such decision is necessary for the execution or execution of a contract, is authorized by law or is based on consent.

i. Right to withdraw consent: In cases where we have obtained your consent for the processing of your personal data in relation to certain activities (for example, in order to send you commercial communications), you can withdraw it at any time. As such, we will stop performing that specific activity for which you had previously consented, unless there is another reason that justifies the continuity of the processing of your data for these purposes, in which case, we will notify you of this situation.

j. Right to file a claim with a control authority: You have the right to file a claim with the Spanish Agency for Data Protection, C / Jorge Juan, 6, 28001 Madrid, +34 901 100 099 - 912 663 517 https://sedeagpd.gob.es/sede-electronica-web/vistas/formQuejasSugerencias/seleccionarQuejaSugerencia.jsf

You may exercise the aforementioned rights by sending a communication to the Customer Service Department, or by sending an e-mail to dpo@televescorporation.com, attaching a document certifying your identity and providing the necessary details to process your request.

Those interested can obtain additional information about their rights on the website of the Spanish Agency for Data Protection, www.agpd.es.

Companies in Televes Corporation

The list below shows all the companies currently in the Televes Corporation:

Company	Tax Identification Number	Address
TELEVES, S.A.U.	A15010176	RUA B.DE CONXO, 17 - 15706 SANTIAGO (A Coruña). Spain
INGENIERIA DE SISTEMAS DE FUNCIONAMIENTO S.L.U.	B15577166	RUA B.DE CONXO, 17 - 15706 SANTIAGO (A Coruña). Spain
GALLEGA DE CIRCUITOS ELECTRONICOS S.L.U.	B15675101	RUA B.DE CONXO, 17 - 15706 SANTIAGO (A Coruña). Spain
TELCOR, S.A.	A15229156	RUA B.DE CONXO, 17 - 15706 SANTIAGO (A Coruña). Spain
SISTEMAS INTEGRADOS DE SERVICIOS DE TELECONTROL, S.L.	B15782550	VOLTA DO CASTRO S/N - 15706 SANTIAGO (A Coruña). Spain
TREDESS 2010, S.L.	B15874183	VOLTA DO CASTRO S/N - 15706 SANTIAGO (A Coruña). Spain
ARANTIA 2010, S.L.U.	B70035019	VOLTA DO CASTRO S/N - 15706 SANTIAGO (A Coruña). Spain
ASSAMBLIA 2010, S.L.U.	B70039672	VOLTA DO CASTRO S/N - 15706 SANTIAGO (A Coruña). Spain
GALLEGA DE INFORMATICA, S.A.	A15025422	RUA B.DE CONXO, 17 - 15706 SANTIAGO (A Coruña). Spain
GALLEGA DE MECANIZADOS ELECTRONICOS, S.A.	A1506454	P.I.TAMBRE-VIA EDISON 16 15890 SANTIAGO (A Coruña). Spain

TELEVES’ EUROPEAN BUSINESS UNITS	VAT NR.
Televes Electrónica Portuguesa, LDA.	PT500972311
Vía Dr. Francisco Sa Carneiro. Lote 17, Zona Ind. Maia 1 Sector-X. 4470 – Barca-Maia-Oporto (PO) – Portugal
Televes UK, LTD	GB484096518
11 Hill Street Industrial Estate. NP44 7PG – Cwmbran, Gwent. United Kingdom
Televes France, S.A.R.L.	FR45414385369
1 Rue Louis de Broglie Parc d’Activités de l’Esplanade. 77400 – St. Thibault Vignes – France
Televes Italia, S.R.L.	IT04301520963
Via Liguria 16. 20068 – Peschiera Borromeo (MI) – Italy
Televes Deutschland, GmbH.	DE162380827
Kuferstraße 20. 73257 – Kongen – Germany
Televes Polska	PL8992689284
ul. Jana Długosza 48, 51-162 Wrocław – Poland
Televes Scandinavia	SE556207728801
Vannhögsgatan 7, 23 166 – Trelleborg – Sweden