Introduction

The protection of personal data and compliance with current data protection regulations is a priority objective for our company.  With this policy, we want to explain how we will treat the personal data that you provide us through the different forms on our website and other input channels.

Responsible for the treatment

The person responsible for the processing of your personal data is:

Company name	ASTICKSO XXI SOCIMI, S.A.U
Email	dpo@astickso.com
Domicile	Goya 6, 2º, 28001 Madrid
Data Protection Officer (DPO)	PRODAT (PRODAT CUMPLIMIENTO, S.L.). CIF: B85564649. Address: C/ de Aguarón, 23, Edif B Planta 2-D-E, CP: 28023 Madrid.

Legitimation of the treatment

We will process your data in accordance with any of the following legal bases:

1. Consent of the interested party. If you give us your consent, we will carry out the treatments related to the scope of the consent and the informed purposes. The interested party may revoke the consent at any time.

2. Performance of a contract. We will process your data if this is necessary for the execution of a contract or for the implementation of pre-contractual measures, in order to provide our products or services, as well as to fulfill the obligations established in said contract.

3. Legal obligation. According to this basis of legitimacy, we may also process your data to comply with an obligation established by law.

4. Legitimate interest. We may process your data where it is necessary for the purposes of the overriding legitimate interests we have as a Data Controller. You can contact us if you want more information about the weighing of legitimate interest carried out in each case.

Purposes of processing

Our company uses your personal data for the following purposes:

1. Sending commercial communications. In the event that there is a previous commercial relationship with you, we may send you commercial communications about similar products and / or services that you have previously contracted. Basis of legitimation: legitimate interest.

Additionally, in the event that you have expressly authorized us, we may send you commercial communications (such as, for example, Newsletter) with information about products, services, events and promotional activities related to different matters. Basis of legitimation: express consent.

2. Contact. If the interested party wishes to contact us through the channels enabled, we will process their data in order to process and respond to their questions and / or requests. We may also contact you with any questions regarding our products or services, if necessary. Basis of legitimation: legitimate interest.

3. Cookies. For more information about the processing of your data that we carry out through the use of cookies, please refer to the Cookies Policy located on our website.

Any other purpose will be communicated to you before proceeding to the processing of your data.

Recipients of the data

The data may be communicated in case they were required by an administrative or judicial authority, or when you had previously authorized us to do so.  Likewise, we inform you that some of our data processors may have access to personal data, such as service providers belonging to the information systems and technology sector.  The data processors are contractually obliged to maintain the confidentiality of the personal data of the interested parties and not to use them for any purpose other   than those for which they were collected.

International transfers

The data controller will not carry out or plan to carry out international transfers. However, inthe event that any of our service providers processes personal data in a third country, our company will apply all measures and controls at its disposal to protect your personal data. The main measures adopted by our company when an international transfer of personal data is made are the signing of standard contractual clauses approved by the European Commission and the request for approved and recognized certifications or codes of conduct.

Storage periods

Your data will be kept for the period strictly necessary to achieve the purposes of the treatment, without prejudice to its conservation for the provision of the competent authorities and to deal with claims. In this case, the data will be kept blocked until the end of the limitation period, at which time they will be deleted.

Exercise of rights

You have the right to exercise the following rights:

1. Access: you have the right to know what data included in our files we treat in relation to your person.

2. Rectification: You have the right to be able to correct, complete or update your personal data at any time.

3. Deletion: You may request the deletion of your personal data from our systems and files.

4. Opposition: you may object to the processing of your data in relation to the sending of commercial communications or profiling, as well as for personal reasons, unless the basis of the treatment is the legitimate interest.

5. Portability: you will have the right to obtain a copy of all data you have provided to us and, where technically possible, you will have the right to request that your personal data be communicated to another controller.

6. Limitation of processing: you may request the limitation of the processing of your data when (i) the accuracy of your personal data is verified after you have contested its accuracy, (ii) the processing of your data is unlawful and you oppose the deletion thereof; (iii) the company no longer needs the personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims, (iv) you object to the processing for the performance of a mission in the public interest or necessary for the satisfaction of a legitimate interest, while verifying whether the legitimate grounds of the company prevail over yours.

You can exercise any of these rights free of charge, as well as withdraw the consent given at any time, by contacting our Data Protection Delegate through the dpo@astickso.com mailbox, including the reference “Data Protection” and, when necessary to prove your identity, accompanying a copy of your ID or equivalent document.

In the event that you need to make a query or suggestion in relation to the processing of your personal data, you can also contact the addresses provided for the exercise of rights.

You also have the right to file a claim with the Spanish Data Protection Agency (www.aepd.es) if you consider that your data has not been treated correctly.

Confidentiality and security in data processing

The data received by our company will be treated with the utmost reserve and confidentiality. Our company has established all the technical and organizational means at its disposal to prevent the loss, misuse, alteration, unauthorized access or copy of the data provided.