Below is the privacy policy (from hereon “web privacy policy” or “policy”) governing the Web Platform https://www.turitop.com/en/ (from hereon “the Platform”), under the ownership of TURITOP, S.L. (from hereon, “TURITOP” or “we”), an organisation with a registered office in Avenida Santa Cruz, 117, door 9, 38600, San Isidro, Santa Cruz de Tenerife, with CIF B-76534759, and registered in the Mercantile Registry of Santa Cruz Tenerife, volume 3177, Folio 40, Page TF-48330.

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WON’T TAKE LONG. WITH THIS WE WANT TO EXPLAIN IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE TREAT AND PROTECT PERSONAL INFORMATION AND RIGHTS. TURITOP TAKES SECURITY AND SAFEGUARDING PERSONAL DATA AS FUNDAMENTAL AND TAKES ITS ADEQUATE PROTECTION VERY SERIOUSLY.

WE ALSO RECOMMEND CAREFULLY READING OUR COOKIE POLICY.

TO WHOM THIS POLICY IS ADDRESSED AND APPLIED?

This policy applies to all users of the platform, whether they are customers of TURITOP or not, (from here on, equally, “the user” or “users”) who are considered physical people. By personal data, we mean any information about an identified or identifiable physical person.

Current clients of TURITOP with a subscribed contract with us, must also refer to the information contained in the contract about the specific terms of privacy.

This platform is aimed at users over 18 years of age, being prohibited its use to minors. In addition, that they responsibly recognise and have sufficient legal capacity to subscribe, if applicable, to the services offered by TURITOP.

IF BROWSING OR USING OUR WEB PLATFORM WHO IS RESPONSIBLE FOR PROCESSING PERSONAL DATA?

We are responsible for the processing of personal data:

Full name of the organinsation: TURITOP, S.L.

Registered office: Avenida Santa Cruz, 117, door 9, 38600, San Isidro, Santa Cruz de Tenerife (España)

Headoffice: Avenida Santa Cruz, 117, puerta 9, 38600, San Isidro, Santa Cruz de Tenerife (España)

Contact telephone/s: +34 922 394632

Contact email (general): help@turitop.com

For any questions regarding the protection of personal information please contact us by sending an email to help@turitop.com

WHAT KIND OF DATA DO WE PROCESS?

The processing of data is necessary to give access to the contents and/or functions of the platform or, should it be required, to be able to send information or provide services available through the platform. In that regard, we are firmly committed to treating personal data in a legitimate and coherent manner in accordance with the principles and legal obligations laid down by current legislation on the protection of personal data.

When browsing through our platform and, in particular, when interacting or registering with us, direct data is given, for example, filling in any form or request online, as part of the processing purposes indicated in each case (for example, the contact form).

The data given to us is in connection with the forms or applications made available through the platform and, which may also vary according to the type of form or application in question. Without prejudice to the above, different categories of personal data may be collected through the platform and its various forms/requests, although we will always ask only for data that is adequate, relevant and limited to what is necessary for the aforementioned processing purposes (principle of minimisation of personal data):

• Identifying personal data (e.g. name and surname)
• Personal contact details (e.g. e-mail address).

Similarly, when browsing our platform, be aware of the cookies that are installed on the terminal or device as this involves the processing of personal data according to the type of cookies reported and their specific purposes (see cookie policy). When accepting our cookie policy, analytical cookies will be used, which implies the processing of personal data associated with the browsing profile for analytical and/or statistical purposes. It is important to note that if browsing is continued on our platform, and having been previously informed of our legal policies on the processing of personal data, this means acceptance of the cookies that are used, although configuration the use of these analytical cookies is able at any time, as indicated in our cookie policy.

WHAT WE USE YOUR DATA FOR?

The personal data provided will be treated with the purpose particularly stipulated in this privacy policy and, in this case, in the various data forms provided therein. In this sense, the collection of data serves the following purposes of treatment:

• To enable navigation through our platform, thereby allowing access to the information and content provided therein.
• To attend to requests or applications in accordance with the contact forms that are sent to us, in particular the registration form as a job candidate. If through such forms, the possibility of sending promotions is informed, advertising or offers of specific services, as they are associated with such requests or applications, and they consist unequivocally of sending them, that this this authorisation may be withdrawn or revoked at any time by writing to us at help@turitop.com, although this will not affect the prior processing of data for these purposes.
• Resolve questions about our services in an agile and effective way through the different means available for this purpose (contact form/queries).
• To allow and manage the registration as a user, if this is required.Cancelation of registration may be done at any time by writing to help@turitop.com.
• Enable client access, through the platform, the digital channel available to customers.
• Comprehensive management of the personal account a when becoming a client by formally subscribing to our contract conditions.
• Allow the associated uses with the Platform’s cookies as described in our cookie policy.
• Once accepted the cookie policy and for development purposes associated with the different types of cookies informed through it, in particular, those of an analytical nature (browsing profile/user), analysis and statistics associated with web browsing are carried out in order to improve our services and the quality of their performance. Configuration of the use of analytical cookies may be done at any time and also the right to revoke consent in respect to the purposes associated with these cookies. Please note that revoking consent to the processing of data in respect to certain types of cookies such as session or technical cookies may prevent browsing our platform (see cookie policy).
• Adopt all the protection measures that may be applicable in accordance with the regulations in force, including the possible anonymisation of personal data by applying the appropriate techniques available for this purpose. Therefore, in this area, anonymisation and pseudonymisation treatments may also be carried out for the best protection of personal data.
• Apply the relevant security, technical and/or organisational measures to personal data with a focus on risks that may exist at any given time, including pseudonymisation or encryption of personal data through our platform.

WHAT DE WE RELY ON TO TREAT DATA LEGALLY?

Purposes of treatment	Legitimate base of treatment
To enable navigation through our platform, thus allowing access to the information and content available on it.	Consent and, depending on the case, the satisfaction of the legitimate interest, own or of third parties, associated with the proper management, maintenance, development and evolution of the platform, tools, network and associated information systems, allowing its correct function, functionality, access to content and services, as well as the general security of all the above.
Attend requests or applications according to the forms or requests sent.	Consent
Solve doubts about our services in an agile and efficient way.	Consent and, as the case may be, implementation of pre-contractual measures at the request of the user/interested party
Allow and manage registration as a user if required.	Consent
Enable access, if you are a client, to the digital customer channel available through the platform	Implementation of the contract signed with TURITOP
Comprehensive management of the personal account as a client, if this is the case.	Implementation of the contract signed with TURITOP
Once accepted the cookie policy provided, to allow the development of processing purposes associated with them and, in particular, to perform the relevant analysis stemming from the web browser for analytical and/or statistical purposes.	Consent
To adopt any protection measures that may be applicable in accordance with current regulations, including the possible pseudonymisation and anonymisation of personal data, applying the appropriate techniques available for this purpose.	Compliance with the legal obligation (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 and repealing Directive 95/46/EC (hereion referred to as the “General Data Protection Regulation” or “GDPSR”) https://www.boe.es/doue/2016/119/L00001-00088.pdf. In the case of a processing intended to ensure the security of the platform, the network and the associated information system, the legitimate interest of TURITOP or, where appropriate, of a third party, maybe invoked (Recital 49 of the RGPD).
Apply the relevant, technical and/or security measures to personal data focusing on the risks that may exist at any given time.	Compliance with a legal obligation (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 and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPSR”) https://www.boe.es/doue/2016/119/L00001-00088.pdf In the case of a processing intended to ensure the security of the platform, the network and the associated information system, the legitimate interest of TURITOP or, where appropriate, of a third party may be employed (Recital 49 of the RGPD).

When the legitimate basis for the processing of personal data is consent, remember that withdrawal of this consent is possible at any time, simply and without justification by writing to help@turitop.com.

HOW LONG DO WE KEEP YOUR DATA?

Personal data associated with the purposes of processing informed	Deadlines or criteria for the conservation of your personal data
Data associated to the user’s navigation through our platform	-In general, data will be kept for these purposes for the time necessary to enable the browsing and use of our platform correctly and to access the content available through it specific needs. -regarding the data associated with the browsing profile, in relation to the analytical type cookies that have been accepted as indicated in TURITOP’s cookie policy, referring to the relative section on the temporary nature of the same (see cookie policy).
To attend requests or applications of the forms or requests sent to us.	-For the time necessary to correctly attend to requests and/or specific requests according to each case. -If these measures consist of the execution of pre-contractual measures at requests or the subscriptions to a contract with TURITOP, data will be kept for as long as is necessary to give due satisfaction to such pre-contractual measures or service contract between the parties.
Resolve doubts about our services in an agile and efficient way.	For the time strictly necessary to resolve or attend to them.
Allow and manage registration as a user if required.	Until such time as an effective termination of such registration is requested. As a customer of TURITOP, the periods of conservation of personal data described in these cases may apply as indicated further ahead.
Enabling access once a client, to the digital channel available through the platform.	During the periods necessary to give due satisfaction to the execution of the contract between the parties (duration of the contract between the parties).
Comprehensive management of the personal account as a client once becoming one.	During the periods necessary to give due satisfaction to the execution of the contract between the parties (duration of the contract between the parties).
To adopt any protection measures that may be applicable in accordance with the regulations in force.	While the user’s personal data are being processed, including the conservation of such data during the legal periods of time arranged, and regardless of the legitimate basis of the processing employed by TURITOP.
Apply the relevant security, technical and/or organisational measures to personal data, focusing on the risks that exist at any given time.	If the user’s personal data are processed, including the conservation of such data during the legal periods of time arranged, and regardless of the legitimate basis of the processing employed by TURITOP.

In any case, and without prejudice to the above, the user is also informed of the following

• In accordance with current regulations on personal data protection, in all matters concerning the correct processing of personal information by TURITOP, this organisation may also keep the information for three years in a secure manner from the time of collection/recruitment (limitation periods for infractions in this area).
• Regarding the conservation time of the cookies, it is recommended the user consult our cookie policy (section: temporality)
• In general, when personal data is no longer necessary for the purposes for which they were collected, they will be blocked, remaining available only to the competent authorities for the possible purging of legal responsibilities during the processing, always in accordance with the applicable regulations, and cannot be used for any other purposes than these. After the legal deadlines in the case of blocking, such personal data will be deleted in accordance with the applicable regulations and, if applicable, may also be securely anonymized by TURITOP (anonymized/non-personal data).

WHAT ARE THE CONSEQUENCES OF NOT PROVIDING DETAILS?

We try to request or obtain the minimum and essential data to carry out the processing of personal data that we need for the full development of our object and social purposes. All this in accordance with the principles contained in the applicable regulations.

However, failure to provide personal data could result in the impossibility of

1. being able to correctly navigate our website (not accepting technical or session cookies);
2. being able to process your specific request or application (for example, due to the lack or inadequate completion of the corresponding form or application).

Regardless, the information, and personal data provided, according to each case, must be:

• Sufficient, although adjusted, limited and proportionate to the legitimate purposes of processing informed in each case, with maximum respect for the principles of limitation and minimization of personal data.
• Accurate, updated and truthful, in order to be able to adequately validate the identity, capacity and, where appropriate, representation, as well as to be able to adjust, in each case, the data processing carried out to the specific needs and actual situation. All of this is in consideration of the principle of personal data accuracy.

Users will be fully responsible for the data and personal information they provide to TURITOP within the framework of the platform and, where appropriate, the services they require or contract from us.

DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

Generally, we do not share, sell or offer your data to third parties. However, it is possible that certain third parties may have access to your personal information while providing services to TURITOP. For example, in the case of third-party cookies that are applied in the platform (see cookie policy).

TURITOP has various people in charge of the processing of personal data under its control, allowing access to them, as trusted suppliers, and as a strict necessity measure to allow service supply contracted with them. Such data processors operate under a service contract in the terms, conditions and guarantees contained in article 28 of the RGPD, and TURITOP carries out the corresponding controls, inspections and audits in this field to verify that such data processors strictly comply with the contracts signed for this purpose and the applicable regulations.

IS YOUR PERSONAL DATA TRANSFERRED INTERNATIONALLY?

We notify that, in general, international transfers of personal data are not foreseen, TURITOP adopting the necessary measures and guarantees in this area and in) accordance with current regulations on personal data protection.

Notwithstanding, our cookie policy informs of the existence of possible international transfers of personal data, in connection with the services provided to us by certain companies (third-party cookies). All these international transfers are fully guaranteed in accordance to the applicable regulations, as being organisations included in the list of certified entities in the framework of Privacy Shield (see cookie policy).

WHAT RIGHTS DO YOU HAVE, WHAT DO THEY MEAN AND HOW CAN YOU EXERCISE THEM?

Your rights	What is it?	How to exercise it?
Right to information	The user has the right to be provided by TURITOP with the appropriate information, both at the time personal data is collected (whether it is obtained from the user or from a third party), and at any time thereafter in regard to the processing of personal data. The user can decide on your personal information. Please refer to Articles 12 to 14 of the RGPD.	TURITOP tries to provide all the necessary information regarding the treatment of personal data in application of articles 12 to 14 of the RGPD. However, should there be any questions or doubts about our privacy and cookie policies, please do not hesitate to write to us, via e-mail: help@turitop.com and we will attend to any additional requests for information.
Right of access	The right to obtain confirmation from TURITOP as to whether or not personal data is being processed, and basic information regarding such processing (Article 15 of the RGPD), as well as to obtain a copy of the personal data being treated.	Writing to us by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right of rectification	The right to obtain without undue delay from TURITOP the rectification of personal data under the terms of article 16 of the RGPD.	By sending a written communication by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right of withdrawal	The right to obtain without undue delay from TURITOP the deletion of personal data under the terms of Article 17 of the RGPD.	By sending a written communication by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right to limitation of treatment	Right to obtain from TURITOP the restriction of the treatment of data when: -Challenge the accuracy of personal data, for a period that allows TURITOP to verify its accuracy. -The processing is unlawful, and its removal is opposed (and instead request its limitation) -TURITOP no longer needs the personal data, but user needs it for the formulation, exercise, or defence of claims. Its exercise will be limited to the provisions of Article 18 of the GPRS.	By sending a written communication by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right to data portability	The right to receive the personal data concerning the user and that has been provided in a structured, common and machine-readable format, or to transmit them to another data controller when technically possible in the terms described in article 20 of the RGPD.	By sending a written communication by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right of opposition	The right to object at any time to the processing of personal data, including profiling, when this is based on the satisfaction of the legitimate interest of TURITOP or a third party as described in Article 21 of the RGPD.	By sending a written communication by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right to not to be subjected to a decision based solely on automatic processing (including profiling)	The right yo not to be subjected to a decision based solely on automated processing, including profiling, which produces judicial consequences or significantly affects the user in a similar way under the terms of Article 22 of the GPRS	By sending a written communication by e-mail to help@turitop.com with the reference “Exercise of rights”, accompanied, if necessary, by proof of identification, a copy of a national identity card or equivalent document (passport, N.I.E….).
Right to revoke the consent given	The user has the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing by TURITOP based on consent prior to withdrawal.	Through the forms, contents and privacy settings arranged by TURITOP, in accordance to each case, such revocation may be articulated (for example, request the cancellation of the newsletter service requested through the link provide). However, a communication to this effect can be sent to the following e-mail address: help@turitop.com so that rights can be duly attended to as described in the applicable regulations.
Right to lodge a complaint with the competent supervisory authority (AEPD)	This implies the possibility of appealing to the supervisory authority in case personal data protection rights are deemed to have been violated (Articles 13 and 14 of the RGPD)	We recommend that before submitting any complaint or claim to the Spanish Data Protection Agency (AEPD), contact is made to us to analyse the specific situation and try, if necessary, to find an efficient and amicable solution. In addition, the above, you can also refer to the AEPD website www.aepd.es

ARE SECURITY MEASURES AND PROTECTION OF YOUR PERSONAL DATA USED?

Bearing in mind the nature, scope, context and the specified aim of the processing, as well as the probable risks of rights and freedom of diverse and important nature, TOURITOP applies and will continue to apply technical and organisational measures in order to guarantee the proper security and protection of personal data attending to privacy criteria from the design and also by default, as well as a system of focus on alike risk which will be revised and updated by TOURITOP when necessary.

VALIDITY AND MODIFICATION OF THE PRIVACY POLICY

This policy is effective as from 05 of August of the year 2020

TURITOP reserves the right to modify this policy in order to adapt it to future legislative, doctrinal or legal developments that may apply, or for technical, operational, commercial, corporate and business reasons, informing beforehand and reasonably of the changes that occur when this is possible. In any case, it is recommended that every time this platform is accessed, this policy is read in detail, as any modification will be published through this means.

Furthermore, TURITOP may inform personally and in advance of any planned changes to this policy, before they come into effect, provided that this is technically and reasonably possible, particularly being a registered user or a client of TURITOP.

DO YOU NEED TO CONTACT US?

If there are any questions or suggestions regarding this policy, please do not hesitate to contact us at help@turitop.com

JURISDICTION AND COMPETITION

In general, any dispute or conflict shall be submitted to the parties for their consideration to reach an amicable solution by mutual agreement, using the channel and e-mail provided in paragraph 13 of this policy.

In case of this not being possible and attending to the criteria contained in the RGPD for the decision of competency of the leading or main authority in the acknowledgment, conflict, controversy or claim around this present privacy policy, at least, clerically, we notify this authority will be the Spanish Agency of Protection of Information (AEPD), or the competent control authority of your place of residence, being able to govern, the procured in the article 56 of the RGPD. Concerning the right to receive effective judicial protection against TURITOP, in these cases, the provisions of Article 79.2 of the RGPD will also apply, and the corresponding action may be brought before the Judges and Courts of the City of Madrid insofar as the responsible organisation is a company based in Spain. The current Spanish and European regulations in this area will be applicable.