In accordance with the EC REGULATION 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereon, RGDP), the Social Data Privacy Policy below regulates the treatment of the personal data solicited/obtained by Xeerpa Marketing Solutions S.L. (hereon, Xeerpa) as a result of your registration in our website using your social media profile.

In this policy you will find Important information about the treatment and processing of your personal data, as well as your rights related to it. If you are in doubt or need any clarification you can contact us as described below.

Xeerpa reserves the right to modify this Social Data Privacy Policy at any time.

The data facilitated must be true, exact, complete and updated, being responsible of any damage, both direct or indirect, that could be caused by not fulfilling with this obligation. Also, you declare being at least 18 years old.

Important notice: Should you not agree with the treatment or purpose to be given to the data, described in this Social Data Privacy Policy, please do not continue with the registration process using your social media profile and opt instead for filling in the registration form provided.

1. 1. WHO IS RESPONSIBLE FOR THE TREATMENT GIVEN TO YOUR PERSONAL DATA?
   Entity: Xeerpa Marketing Solutions S.L.
   VAT: B-86556206D
   Postal address: C/Albarracín 58, local 15. 28037, Madrid, Spain
   Data Protection Officer (DPO): Guillermo Cediel Blanco
   Email: dpo_xeerpa@xeerpa.com

1. 2. WHAT WILL WE DO WITH YOUR DATA?

   a) Manage your registration: We will be using your personal data to complete the registration process, control user access and manage our relationship with you.

   b) Create your commercial profile: the personal data you decide to share with us will also be used to complement our database and create or improve your commercial profile, so we can better understand your preferences in order to design, plan and personalise our marketing and commercial actions. We will not however make any automated decision based on your commercial profile.

   c) Send marketing communications: If you expressly accept it in the registration process, your data will be used to send you personalised marketing communications, as explained below.

1. 3. CAN WE SEND YOU MARKETING COMMUNICATIONS?

   Xeerpa would like to keep you informed of our products and services, by sending you informative, commercial and marketing communications by email or other electronic channels based on the personal data you have shared with us. This will enable us to improve your user experience with us and to send you more personalised messages based on your preferences.

   By ticking the “I would like to receive marketing communications” checkbox you will be authorising the treatment of your personal data for this purpose.

   You can revoke this consent at any time by simply sending us an email to dpo_xeerpa@xeerpa.com, indicating in the subject “Exercising my GDPR rights – unsubscribe from Marketing Communications” and attaching a copy of your National ID, Passport or any other valid document proving your identity. Revoking this consent will not affect the other two purposes (Managing your registration and account and Creating your marketing profile).

1. 4. WHAT TYPE OF DATA WILL WE OBTAIN AND HOW DO WE TREAT IT?

   The data that Xeerpa will obtain and process may belong to any of these categories:

   •  Information about your “Public profile”: This information is required so we can identify who you are. It is the information you provided to the social network you are using to complete the registration process in our website: Your name, surname, social network id, profile picture, language and country.

   •  Other information that you agreed to share with Xeerpa, such as other means of contact, academic and/or professional data, etc.

   •  Email: This information is required to complete the registration process.

   During the registration process you will be able to select, within the different options we will be providing, precisely which personal data from your social media profile you explicitly consent to share with Xeerpa, before we have access to it.

   Some of the fields indicated in the listing will be requested during the registration process and some others at its completion, in a separate form, in which you will also be able to edit and modify some of the details provided. IMPORTANT: The additional information presented in this document also applies to the collection and treatment of these extended personal data.

   We require that you provide the personal data marked as mandatory so we can complete the registration with your social media profile. IMPORTANT: If you do not agree please do not continue the registration process with your social media profile; you can choose instead to register by filling in the form provided.

1. 5. WHO WILL BE SHARE YOUR DATA WITH?

   We will not share, rent nor sell the information you provide. Will be keep your data our marketing database for internal purposes only.

1. 6. IS THIS TREATMENT OF YOUR DATA LEGITIMITATE?

   The consent to process your personal data that we request from you in this registration process is the legal base that legitimates it.

1. 7. HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR?

   Your personal data will be kept for five years then will be submitted for revision and/or deletion.

1. 8. WHICH RIGHTS DO YOU HAVE WHEN SHARING YOUR DATA WITH US?

   •  Obtain confirmation regarding whether or not Xeerpa is treating personal data that concerns you.

   •  Access to your personal data.

   •  Request rectification of any inexact or incomplete information.

   •  Request the deletion of your personal data when, amongst other reasons, it is no longer necessary for the purposes it was collected.

   •  Request, under certain circumstances, the limitation in the treatment and processing of your data, in which case we will only keep the information required by law against any claim or third-party rights.

   •  Oppose to the treatment of your personal data with the purpose of receiving sales and marketing communications, including the creation of your commercial profile.

   •  Request, when treatment of the data is done by automated means, the portability of your data, which will be returned to you in an structured and easy to read manner, as well as requesting its transmission to another party responsible for its treatment, when this is technically possible.

   •  Revoke your consent in relation to one or more of the treatments given to the data, in which case we will cease treatment of your personal data for said purposes, without affecting the previous consent given to the treatment until its revocation.

   •  Make a claim at the corresponding Data Protection Authority (In Spain, AEPD https://sedeagpd.gob.es).

   To exercise one or several of these data protection rights, send us an email to dpo_xeerpa@xeerpa.com, indicating in the subject “Exercising my GDPR rights”, specifying your request and attaching a copy of your National ID, Passport or any other valid document proving your identity.