The legal basis for the processing of your personal data are the following (i) your consent (ii) the performance of a contract to which you’re a party or the prior steps to entering into a contract; (iii) compliance with legal obligations; and (iv) the performance of the legitimate interest of the Joint Data Controllers, where the legitimate interest could be in particular: (a) managing our relationship and contact; (b) analyzing the information about our interaction with you to improve our engagement; and (c) establishing, exercising, or defending legal claims or as required whenever courts are acting in their judicial capacity. We will never process your data where these legitimate interests are overridden by your own interests, rights and freedoms.

Your data will be kept during the course of our relationship and once it has terminated, they will be kept blocked for the period legally required for the compliance of our legal obligations and the attention of possible liabilities and responsibilities arising from the processing, during the limitation period of the same. Once this period is over, we will erase your data, removing it from our systems and records.

Regarding the processing of your data for the purpose of contacting you by email, phone call or another electronic messaging, if you have consented to this processing, the data will be retained until you exercise your right to object or unsubscribe.

We will not disclose to any third parties your personal data without adequate organizational and technical measures in place in order to protect your personal data. For that matter, FENIX GROUP might share your data with:

• Intra-group transfers: On the basis of the proper functioning of the corporate group and based on the legitimate interest pursued by all the entities of FENIX GROUP, it is necessary to transmit personal data within the corporate group for internal administrative purposes, which may include your personal data. Because the Parent company, FENIX GROUP INTERNATIONAL, LLC is located in the United States, a third country that doesn’t provide an adequate level of protection, all transfers of personal data to the United States and/or from the United States to the European Economic Area, will have as a legal ground the European Commissions’ Standard Contractual Clauses. In particular, Decision 2001/497/EC, of 15th June 2001, and Decision 2004/915/EC, of 27th December 2004, providing contractual clauses for the transfer of personal data to third countries between Data Controllers.

• Third parties to respond to requests of government or data protection authorities, or where required or permitted by applicable laws, court orders, or government regulations; or

• Any other entity or service provider, or other third party who has been permitted access to your personal data is required to enter into a Data Processing Agreement, in compliance with article 28 of the GDPR.

You have the right to access your personal data, as well as to request the rectification of inaccurate data, where appropriate and when the data is no longer necessary for the purposes for which it was collected you can request its erasure, in addition you can exercise the right to restrict the processing, also the right to object and to request data portability and allo, the right to oppose and limit the processing, the portability of the data and not to be subject to automated decisions.

In order to exercise those rights, you may contact us by email: dataprivacy@fenix.group.

In the event that you have not obtained satisfaction in the exercise of your rights, you may file a complaint with the Spanish Data Protection Agency through its website https://www.aepd.es/.

We inform you that your personal data will not be incorporated into any automated procedure or otherwise automatically processed.

The personal data collected will be processed for the following purposes: (i) managing our relationship and contact; (ii) collaborate with you to arrange visits or phone calls to engage in market research; (iii) provide our professional services; (iv) execute honoraria payment, when necessary, in exchange for occasional services; (v) analyze the information about our interaction with you to improve our engagement; and (vi) contact with you by email, phone call or another electronic messaging, such as SMS or fax, seeking information or professional engagement with you, only if you give your consent. Accordingly, we would like to ask you to provide your consent for the before mentioned purpose: