ADDITIONAL INFORMATION ABOUT DATA PROTECTION

LEXPASSP S.L. aims to transparently inform you, through this Privacy Policy, about all the processing we carry out with your data, the purposes for which we process them, and the rights you, as a user, can exercise regarding your personal data, as well as the period during which we will retain your data.

We inform you that by accessing our website, you become a user. As a user, you declare that you have the necessary legal capacity to fully understand and accept the Privacy Policy. This Privacy Policy must be read together with our Cookie Policy.

Thank you for visiting our website.

WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

Identity: LEXPASSP S.L. (hereinafter referred to as LEXPASSP), with VAT number B44941896, is responsible for processing your personal data that you provide to us.
Postal address: Calle Luis Martínez Feduchi, 40, Madrid, 28055, Madrid.
Phone: 0034 689976710
Email: [email protected]

WHAT IS PERSONAL DATA AND DATA PROCESSING?

Personal data is any information that identifies or allows the identification of a person. For example, data that can directly identify a person includes their name and surname, while the D.N.I number (National Identity Document) can also be used for identification. Personal data includes information such as mobile phone number, email address, date of birth, and gender, among others. It could also include numerical identifiers such as your computer’s IP address, as well as information obtained through cookies.

Data processing refers to any operation or set of operations performed on personal data, such as collection, recording, storage, use, and communication of data.

WHAT TYPE OF INFORMATION DO WE COLLECT?

In order to properly carry out the data processing described in this Privacy Policy, we need to collect certain information about you. Therefore, we collect the information you provide to us through interaction and communication channels with LEXPASSP. The data we may collect about you through these channels includes name and surname, DNI number, email address, mobile phone number, address, characteristics, preferences, tastes, responses to satisfaction surveys, interaction with customer service, information about profiles on social networks, and information about website usage and navigation (the website you accessed our site from, visited pages, processes initiated and abandoned, IP address, time spent on the website).

HOW DO WE COLLECT YOUR PERSONAL DATA?

At LEXPASSP, we only collect and process information that you provide to us through the following channels:

Form to request any of our services;
Interaction with customer service;
Through the website’s chat;
Navigation through the website www.lexpassp.com; and
Interaction with LEXPASSP on social networks and employment portals.

WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

As a user of the website, you have the following rights that you can exercise:

Rights.

What do they mean?

Right of access

You have the right to have LEXPASSP confirm whether or not it is processing your personal data and, if so, the right to know what data is being processed.

Right of rectification.

This allows you to modify any data that is inaccurate or incomplete. In your request for rectification, you must specify which data you want to be modified.

Right of opposition.

You can object at any time to the processing of your personal data, except in cases provided by law. Therefore, unless there are legal grounds that prevent you from exercising this right (for example, when the legal basis for processing your personal data is the performance of a contract or compliance with a legal obligation on our part), you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you. This right can also be exercised when data processing is based on our legitimate interests. If you exercise this right, LEXPASSP will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

Right of erasure.

This right allows you to request the deletion of your personal data. Once you exercise this right, your data will not be immediately deleted but will be kept blocked to prevent further processing, without prejudice to making them available to public authorities, courts, and tribunals, for the attention to possible liabilities arising from the processing during its limitation period. Once this period has elapsed, your data will be duly anonymized or deleted.

Right to data portability.

You have the right to receive a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format and to transfer this data to another data controller, where technically feasible. This right can only be exercised when the processing is based on the performance of a contract or your consent, and the processing is carried out by automated means.

Right to restriction of processing.

This right allows you to request the suspension of the processing of your data when: • You contest the accuracy of the data, while LEXPASSP verifies its accuracy. • You have exercised your right of opposition to the processing of your data, while it is being verified whether LEXPASSP’s legitimate grounds override yours as the data subject.

Similarly, this right allows you to request LEXPASSP to keep your personal data when: • The processing of data is unlawful, and as the data subject, you oppose the erasure of your data and request a restriction of its use instead. • LEXPASSP no longer needs your personal data for the purposes of processing, but you need them for the establishment, exercise, or defense of legal claims.

How to exercise these rights? You can exercise your rights by sending your request to the following email address: [email protected], or by postal mail, through a written and signed request, accompanied by a photocopy of your ID card or passport, addressed to the following address: Calle Luis Martínez Feduchi 40, 28055 Madrid.

Furthermore, we inform you that if you consider that LEXPASSP has not properly satisfied the exercise of your rights, you can file a complaint with the Spanish Data Protection Agency (AEPD) located at calle Jorge Juan nº 6, 28001 Madrid (Madrid). If you want to know more about how to request protection from the AEPD, you can visit their website http://www.aepd.es or contact them through the telephone numbers 901 100 099 and 91.266.35.17.

WHAT PROCESSING DO WE PERFORM WITH YOUR PERSONAL DATA?

We want to be transparent with you and inform you about the operations we carry out with your data and the purposes for which we process such data. For this reason, we have separated the relevant information into separate tables.

Each descriptive table for each processing of personal data includes the following information:

Purpose: In this column, we explain the purpose and the specific reason for processing your personal data.
Legal basis: Data protection regulations require that we have a legal basis to justify the processing of your personal data. Therefore, we rely on the following legal bases for processing:

Legitimate interest: As a company, LEXPASSP has a legitimate interest in collecting and processing your personal data in order to study and analyze the suitability of our Website and products, assess if they meet the needs of our customers and users or need modifications to better suit those needs or market trends. We also have a legitimate interest in maintaining regular contact with our customers and users to keep them informed about our news, promotions, and products, as well as to recommend or offer products that best fit their needs, characteristics, and preferences. In any case, this legitimate interest is based on a balancing test of our interests in processing your personal data and your rights and freedoms. The result of this analysis will determine whether we can use your personal information for the processing described in this Privacy Policy.
Contractual performance: When you explicitly accept the General Conditions of Contracting, you become a party to the purchase contract of the product subscribed with us. In order to fulfill the obligations under these General Conditions of Contracting, we need to collect and process your personal data. Therefore, your refusal to provide us with the necessary personal data to process the General Conditions of Contracting will result in the inability to purchase products with LEXPASSP.
Legal obligation: LEXPASSP acts as the data controller, and as such, it must comply with a series of obligations imposed by accounting, tax, data protection, consumer, and other regulations. Therefore, LEXPASSP will keep the confirmation of users who have requested the erasure of their data on a suppression list, in compliance with the legal obligation derived from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
Consent: In cases where LEXPASSP wants to carry out any processing of your data that cannot be justified by the legal bases mentioned above, such as contacting us through our customer service, we will request your consent for such processing. In any case, we inform you that in such cases, you can always withdraw your consent at any time.

Data retention: In this column, we provide indicative information about how long your data will be retained. The retention period will depend on the specific processing carried out on your personal information. Please note that certain accounting, tax, consumer, data protection, and contract regulations may oblige us to retain certain data from customers and users for a specific period.
Your rights: In this column, we describe the rights you can exercise regarding your personal data according to the specific processing performed on them. Please note that depending on the legal basis that justifies the processing of your data, your rights may be limited.

Below, you will find a more detailed description of the different processing operations that LEXPASSP carries out with your personal data:

Contact and Customer Service

Purpose: Provide customer service, resolving doubts, and responding to inquiries and information requests.
Legal basis: User consent.
Data retention: Your personal data will be processed by LEXPASSP for as long as necessary to effectively manage the user’s request or until you exercise your right to erasure or objection.
Your rights: You can exercise the rights described in section 5 of this Privacy Policy, as stipulated in that section.

Chat

Purpose: Provide customer service, resolving doubts, and responding to inquiries and information requests.
Legal basis: Legitimate interest.
Data retention: Your personal data will be processed by LEXPASSP for as long as necessary to effectively manage the user’s request or until you exercise your right to erasure or objection.
Your rights: You can exercise the rights described in section 5 of this Privacy Policy, as stipulated in that section.

Management of Services Available on the Website

Purpose: Manage the unsubscription from the newsletter when requested by the user.
Legal basis: User consent.
Data retention: Your personal data will be processed by LEXPASSP until you exercise your right to objection or erasure or withdraw your consent.
Your rights: You can exercise the rights described in section 5 of this Privacy Policy, as stipulated in that section.

Marketing Actions

Purpose: Inform customers about news of interest.
Legal basis: The legal basis for processing your data is the user’s consent for cookies, and for sending commercial communications, it is the user’s consent or, in case of a pre-existing contractual relationship, LEXPASSP’s legitimate interest in maintaining direct and regular communication with its customers for marketing purposes.
Data retention: The personal data provided will be retained until you exercise your right to object or request deletion or withdraw your consent.
Your rights: You can exercise the rights described in section 5 of this Privacy Policy, as stipulated in that section.

Maintenance of Updated Suppression Lists to Avoid Being Contacted

Purpose: Maintain a suppression list with confirmation of users who have requested the erasure of their data or objected to the processing.
Legal basis: Legal obligation: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data requires us to respect your rights and maintain evidence of our compliance with your request to exercise the right to erasure.
Data retention: We will keep your personal data for the legally established period for filing any claims related to our effective or deficient response to your right to erasure or objection.
Your rights: The rights described in section 5 of this Privacy Policy are limited as this processing is based on a legal obligation.

Analysis of Usage, Functioning, and Improvement of the Website

Purpose: Recognize the user when they return to the corporate website. Facilitate sharing of corporate website content through social media and communication channels. Maintain the security and protect the corporate website from malicious use. Adapt the website to the type of device used. Adapt the website to the personalized criteria chosen by the user and remember them. Study possible improvements to the website to optimize the usability experience and implement them. Display the correct and requested content of the website for the user at all times.
Legal basis: User consent.
Data retention: We will keep your personal data for the period that each type of cookie requires or until you withdraw your consent or exercise your right to object.
Your rights: You can exercise the rights described in section 5 of this Privacy Policy, as stipulated in that section. You can also configure the use of cookies through the Internet browser you use to navigate the Website.

Images

Purpose: The images published on the website are intended to promote and showcase the services provided.
Legal basis: User consent.
Data retention: We keep your data, in this case, to promote services through the website. Your image or voice in audiovisual pieces will be kept until you object to the processing or withdraw your consent, as indicated in the legitimacy bases section. If you exercise your right to object or withdraw your consent, the images in which you appear will be immediately deleted.
Your rights: The rights described in section 5 of this Privacy Policy are limited as this processing is based on a legal obligation.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

LEXPASSP will only disclose the personal information you provide to us through the channels described in section four when it is strictly necessary for the provision of the online purchase service.

It is also possible that we may disclose your personal data to other third parties, upon legal requirement or basis that legitimizes the communication:

Legal advisors • Courts • Tax Authorities • Government agencies and Public Administration • State Security Forces and Bodies • Data Processors who, in order to provide the necessary services, need access to certain information and/or personal data. The data may be transferred to data processors who have access to data, and with whom obligations and responsibilities are formalized in the processing of data, as Data Processors. LEXPASSP signs the corresponding data processing agreements that include the necessary guarantees regarding the processing of personal data, confidentiality, cancellation, destruction, or return.

ARE YOUR DATA SECURE?

In order to ensure fair and transparent processing of your personal information, we will adopt appropriate procedures, including the implementation of technical and organizational measures that take into account the potential risk and correct any identified inaccuracies in the personal data processed, so that the risk of any error is minimized, and your data is treated fairly and securely.

All the information you provide to us is stored on secure servers. Unfortunately, the transmission or communication of information over the internet is not completely secure. Therefore, once we have received all your information, we will use strict security procedures to try to prevent unauthorized access.

Likewise, we ensure that our service providers also have appropriate security standards for the protection of personal data to which they have or may have access, in compliance with applicable data protection legislation.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may change over time due to possible changes in the criteria followed by the competent data protection authority at any time. LEXPASSP therefore reserves the right to modify this Privacy Policy to adapt it to such criteria, as well as to jurisprudential or legislative developments.

Last version: November 11, 2022.

CONTACT

If you have any questions about the processing we carry out regarding your personal data, you can contact us via email at: [email protected].

TERMS AND CONDITIONS OF USE OF THE WEBSITE

https://www.lexpassp.com/

CORPORATE INFORMATION
PURPOSE AND SCOPE OF APPLICATION
ACCESS AND ACCEPTANCE OF TERMS AND CONDITIONS
USER’S OBLIGATIONS OF THE WEBSITE
PROTECTION OF PERSONAL DATA AND COOKIE POLICY
LIABILITY REGIME
INTELLECTUAL AND INDUSTRIAL PROPERTY RIGHTS
LINKS TO THIRD-PARTY WEBSITES
DURATION AND MODIFICATION OF TERMS AND CONDITIONS
CONTACT
JURISDICTION AND APPLICABLE LAW
GENERAL CONCEPTS

1.CORPORATE INFORMATION.

The company Residencia y Ciudadanía, with registered address at C/ Luis Martínez Feduchi 40, 29055, Madrid, Spain, Tax Identification Number B44941896, and duly registered in the Mercantile Registry of Madrid (hereinafter referred to as “LEXPASSP S.L.” or the “Company” or “We” or “Us”), is the owner and legally responsible for the website www.lexpassp.com (hereinafter referred to as the “Website” or the “Web”). LEXPASSP S.L. provides the Web to Internet users (hereinafter referred to as the “User” or “Users” or “You”) so that they can learn more about ETL NEXUM, discover the services we offer, and contact us or request information.

2.PURPOSE AND SCOPE OF APPLICATION.

These general terms and conditions of use of the Website (hereinafter the “Terms and Conditions”) regulate, together with the Privacy Policy and the Cookie Policy, the use of the Website, as well as the relationship between LEXPASSP S.L. and the Users of its Website. These Terms and Conditions specifically establish the rules that Users using the Website must comply with. These Terms and Conditions will always be accessible to Users on the Website in the same language of the Website, so that you can check, review, download, or print them at any time. The Terms and Conditions, as well as the Privacy Policy and the Cookie Policy, have been drafted in accordance with the current regulations on consumer rights, the Internet and electronic commerce, and the protection of personal data in force in Spain and the EU.

3.ACCESS AND ACCEPTANCE OF TERMS AND CONDITIONS.

Access to the Website is free, except for the cost related to the connection through the telecommunications network provided by the Internet access provider contracted by You. Users can freely browse the Website and access it as many times as they wish. No registration is required. By accessing the Website, Users declare that they are of legal age and have the necessary legal capacity to browse the Website and fully understand and accept these Terms and Conditions.

4.USER’S OBLIGATIONS OF THE WEBSITE.

By accessing the Website, the User agrees to use the Website in accordance with these Terms and Conditions, good faith, and current legislation. Also, by using the Website, you declare and warrant that you are of legal age and that you understand and accept these Terms and Conditions fully. Any fraudulent, abusive, illegal, or contrary to good faith use of the Website and its functionalities by Users is strictly prohibited. In any case, the User must refrain from:

1.Reproducing, distributing, publicly communicating, transforming, or modifying the Website or any of its contents, including these Terms and Conditions, regardless of the purpose of such use, without the prior written authorization of LEXPASSP S.L.

2Introducing data programs into the Website or its network that may cause damage to the computer systems of LEXPASSP S.L., its suppliers, or third parties.

3.Carrying out any kind of unlawful, fraudulent, or contrary activity to these Terms and Conditions, current legislation, and/or good faith or that prevents and/or hinders the proper use of the Website or its contents.

4.Inserting on third-party websites, platforms, forums, chats, blogs, or social networks any kind of link that allows linking or reproducing the Website or any of its content with said websites, platforms, forums, chats, blogs, or networks outside social media, unless the link only directly links to the main page of the Website without reproducing it in any way.

5.Linking to or reproducing the Website or its content from websites, platforms, forums, chats, blogs, or external social networks that are contrary to the law, offensive, or detrimental to human dignity, fundamental rights, or LEXPASSP S.L. itself and/or may be considered illegal.

6.Introducing and/or disseminating on the Website content that violates human rights and the dignity of individuals, such as, for example, racist, xenophobic, pornographic content, or content advocating terrorism.

5.PROTECTION OF PERSONAL DATA AND COOKIE POLICY .

As established in our Privacy Policy, LEXPASSP S.L. undertakes to treat Users’ data while always respecting their confidentiality and privacy and in accordance with the purposes for which such data is collected. LEXPASSP S.L. complies with its obligation to keep and treat the personal data of Users of the Website securely, applying all necessary security measures to prevent alteration, loss, processing, or unauthorized access by third parties, in accordance with the provisions of current legislation on the protection of personal data.

6.LIABILITY REGIME.

Users must use the Website and its content in accordance with these Terms and Conditions, current legislation, and good faith. Any use of the Website or its content contrary to these Terms and Conditions, the law, or good faith is expressly prohibited, regardless of whether such use has an economic purpose. The User shall be responsible for any damage or harm caused to LEXPASSP S.L. or third parties, directly or indirectly, from any use made of the Website or its content contrary to these Terms and Conditions, the law, public order, and/or good faith. LEXPASSP S.L. requires services provided by third parties to make the Website and its content accessible to Users. Despite the efforts made by LEXPASSP S.L. to keep the Website available and accessible, it may be suspended, interrupted, or canceled due to reasons beyond LEXPASSP S.L.’s control. Therefore, LEXPASSP S.L. does not guarantee the absence of interruptions or errors in accessing the Website or its content, nor that it is always up-to-date or displayed in its latest version. Consequently, LEXPASSP S.L. declines any responsibility for damages that may affect the User as a result of the suspension, interruption, lack of continuity, network failure, or disconnection of the Website. Under no circumstances will LEXPASSP S.L. be liable for damages or harm caused to the User arising from causes not attributable to LEXPASSP S.L., such as, by way of example and not limited to, natural disasters, force majeure situations, viruses, harmful components, browser malfunctions, computer intrusions, or third-party attacks.

7.INTELLECTUAL AND INDUSTRIAL PROPERTY RIGHTS

The Website and its content are subject to protection under Intellectual and Industrial Property regulations. LEXPASSP S.L. is the owner and/or has duly licensed all Intellectual and Industrial Property rights over the Website and its content.

Any form of reproduction, distribution, public communication, transformation, and, in general, any other act or form of exploitation, whether for commercial purposes and/or free, of the Website and/or its contents, without the prior and express consent of LEXPASSP S.L., is strictly prohibited.

LEXPASSP S.L. reserves all Intellectual and Industrial Property rights over the Website and its content. Under no circumstances does accessing the Website or browsing the Website imply the assignment and/or license of any kind by LEXPASSP S.L. of the Intellectual or Industrial Property rights of the Website and its content.

By reproducing, disseminating, publishing, sharing, or sending any content on or through the Website to the User, LEXPASSP S.L. guarantees that it is the legitimate owner of such content or that it holds the image rights, Intellectual and/or Industrial Property rights, or any other necessary for its use, reproduction, and public communication. Likewise, by reproducing, disseminating, publishing, sharing, or sending any content, regardless of its nature or content, on or through the Website, you grant LEXPASSP S.L. a free, non-exclusive right to all exploitation rights of intellectual property in all its forms, including the right to sublicense such rights to third parties, until the works enter the public domain and irrevocably.

8.LINKS TO THIRD-PARTY WEBSITES

Third-party websites, platforms, forums, chats, blogs, or social networks that link to the Website must clearly inform that they do not have the authorization or supervision of the Company, and that such link does not imply any kind of association between LEXPASSP S.L. and third-party websites, platforms, forums, chats, blogs, or social networks that link to the Web.

In any case, any link that targets the Website must be directed directly to the home page of the Web by clicking on the URL address of the Web, covering the entire screen of the home page of the Web.

LEXPASSP S.L. is not responsible, under any circumstances and under any concept, for the contents, information, or data related to the Website, its content, or any other matter contained on third-party websites, platforms, forums, chats, blogs, or social networks that link or link to the Web.

It is expressly prohibited to link to or link to the Website from websites, platforms, forums, chats, blogs, or social networks contrary to law, morals, and good customs, especially those with pornographic, illegal, unlawful, or violative content of human rights.

On the other hand, the Website may contain links to third-party websites, platforms, forums, chats, blogs, or social networks. Despite LEXPASSP S.L.’s efforts, we do not have the human and/or technical means to know or control the information and/or content that appears on third-party websites. Therefore, LEXPASSP S.L. will not be responsible, under any circumstances, for the content of linked third-party sites from the Website, and such links cannot be considered as effective knowledge of the content of the sites they link to.

Third-party websites, platforms, forums, chats, blogs, or social networks that link or link to the Web must clearly inform that they do not have the authorization or supervision of the Company and that such link or linking does not imply any kind of association between LEXPASSP S.L. and third-party websites, platforms, forums, chats, blogs, or social networks that link or link to the Web.

DURATION AND MODIFICATION OF TERMS AND CONDITIONS

These Terms and Conditions will be valid for as long as they are available to Users on the Web. Once the Terms and Conditions are modified or updated, in whole or in part, these conditions will cease to be valid, and the new Terms and Conditions will govern the use of the Web and the relationship between LEXPASSP S.L. and the Users.

LEXPASSP S.L. informs Users that these Terms and Conditions may change over time. Therefore, LEXPASSP S.L. reserves the right to modify these Terms and Conditions when they occur due to changes in the Website, corporate changes of LEXPASSP S.L. or its corporate group, economic, operational, or commercial circumstances, or changes in the business model of LEXPASSP S.L. and/or legislative or jurisprudential developments. In the event of a modification of these Terms and Conditions, LEXPASSP S.L. will inform Users on the home page of the Website about such circumstance so that Users are duly informed and can consult the revisions, modifications, or updates to their full satisfaction.

10.CONTACT

Users can contact LEXPASSP S.L. via email ([email protected]) to resolve any issues or doubts they may have.

11.JURISDICTION AND APPLICABLE LAW

These Terms and Conditions, along with the Privacy Policy and the Cookie Policy, are governed by current Spanish regulations. In the event of a dispute, LEXPASSP S.L. and the User will submit to the jurisdiction that corresponds to the User in accordance with applicable regulations.

12 GENERAL CONCEPTS

Under no circumstances will the lack of exercise of its rights by LEXPASSP S.L. be understood as a waiver of them.

The headings contained in these conditions are merely indicative or informative, in such a way that they do not affect, burden, or extend the interpretation of the conditions.

If any of the clauses contained in these Conditions were declared null, abusive, or inapplicable, in whole or in part, by a judicial or administrative body, such declaration will individually affect the clause in question, taking it as null and void, and the declaration of nullity, abuse, or inapplicability will not extend under any circumstances to the rest of the conditions, which will remain in force.

Current version from: November 11, 2022.