WEBSITE PRIVACY POLICY

www.spineflix.com

I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, Spinelix (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporating this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it respects the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights(LOPD-GDD).
• Royal Decree 1720/2007, of 21 December, approving the Regulations for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the treatment of the personal data collected in Spinelix is: Spinelix, S. L., provided with NIF: B16678153 and registered in: MERCANTILE REGISTRY OF VALENCIA with the following registry data: VOLUME XXX PAGE XXX, SHEET XXX. Your contact details are as follows:

• Address: C / SIN NOMBRE, 6
• Contact email: info@spineflix.com

Registration of Personal Data

In compliance with what is established in the RGPD and the LOPD-GDD, we inform you that the personal data collected by Spineflix, through the forms extended on its pages will be stored and processed in our file in order to facilitate, expedite and fulfill the commitments established between Spineflix and the User or the maintenance of the relationship established in the forms that this fill in, or to address a request or inquiry of the same. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in Article 30.5 of the RGPD applies, a register of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles contained in Article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of legality, loyalty and transparency: the consent of the User will be required at all times after completely transparent information of the purposes for which the personal data are collected.
• Principle of limitation of purpose: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always up to date.
• Principle of limitation of the period of conservation: the personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its treatment.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data that are processed in Spinelix are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Spinelix undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

In the occasions in which the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, you will be informed in case the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing to which the personal data are destined

The personal data are collected and managed by Spinelix in order to facilitate, expedite and fulfill the commitments established between the Website or App and the User or the maintenance of the relationship established in the forms that the latter completes or to respond to a request or query.

Also, the data may be used for a commercial purpose, personalization, operational and statistical purposes, and activities of the social object of Spineflix, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Retention periods of personal data

The personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 18 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be kept or, where this is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of their personal data in a lawful manner by Spinelix. If it is a child under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Spineflix undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in a way that guarantees the security of personal data and to avoid the destruction, loss or accidental or unlawful personal data transmitted, preserved or otherwise processed, or the communication or unauthorized access to such data.

However, because Spinelix cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a breach of the security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the RGPD, a breach of the security of personal data is understood to be any breach of security that causes the destruction, loss or accidental or unlawful alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication or access to such data.

The personal data will be treated as confidential by the controller, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom we make information accessible.

Rights arising from the processing of personal data

The User has over Spinelix and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the right of the User to obtain confirmation of whether or not Spinelix is processing their personal data and, if so, obtain information about their specific personal data and the treatment that Spinelix has carried out or is carrying out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned thereof.
• Right of rectification: It is the right of the User to modify their personal data that prove to be inaccurate or, taking into account the purposes of the treatment, incomplete.
• Right to erasure ("right to be forgotten"): the right of the User, provided that the current legislation does not establish otherwise, to obtain the deletion of your personal data when these are no longer needed for the purposes for which they were collected or processed; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User objects to such processing, and there is no other legitimate motive to proceed to the same; personal data have been processed ilícitamentemente; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Controller, taking into account the available technology and the cost of its implementation, shall take reasonable steps to inform the controllers who are processing the personal data of the data subject's request to delete any links to that personal data.
• Right to limitation of treatment: It is the right of the User to limit the processing of their personal data. The User has the right to obtain the limitation of the treatment when he challenges the accuracy of his personal data; the treatment is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Where technically possible, the Controller will transmit the data directly to that other controller.
• Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease the processing thereof by Spinelix.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "RGPD-www.spineflix.com", specifying:

• Name, surname of the User and copy of the ID. In cases in which representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be replaced, by any other means valid in law that proves the identity.
• Request with the specific reasons for the request or information you want to access.
• Address for notifications.
• Date and signature of the applicant.
• Any document that accredits the request made.

This request and any other attached documents may be sent to the following e-mail address: info@spineflix.com

Links to third party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Spinelix, and that are therefore not operated by Spinelix. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of any regulation in force in the way that you are treating your personal data, you have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which he has his habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and is satisfied with the conditions on the protection of personal data contained in this Privacy Policy, as well as accept the processing of their personal data for the controller to proceed with the same in the form, for the periods and for the purposes indicated. The use of the Website implies acceptance of the Privacy Policy of the same.

Spinelix reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated in order to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD) and the Organic Act 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights.



Updated: November 4, 2021