Below is the privacy policy (hereinafter, “web privacy policy” or “policy”) that governs the Web Platform https://www.turitop.com/es/ (hereinafter, “the Platform”), under the ownership of TURITOP, SL (hereinafter, “TURITOP” or “we”), an entity with address at Avenida Santa Cruz, 117, door 9, 38600, San Isidro, Santa Cruz de Tenerife, with CIF B-76534759, and registered in the Commercial Registry of Santa Cruz Tenerife, volume 3177, Folio 40, Sheet TF-48330.

PLEASE SPEND A FEW MINUTES TO READ OUR PRIVACY POLICY, IT WON’T TAKE YOU LONG. WITH IT WE WANT TO EXPLAIN TO YOU IN A SIMPLE, CLEAR AND TRANSPARENT WAY HOW WE TREAT AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. YOUR SECURITY AND THAT OF YOUR PERSONAL DATA IS FUNDAMENTAL FOR TURITOP AND WE TAKE ITS ADEQUATE PROTECTION VERY SERIOUSLY.

WE ALSO RECOMMEND YOU READ OUR COOKIE POLICY CAREFULLY.

TO WHOM IS THIS POLICY ADDRESSED AND APPLIED?

This policy applies to all users of the platform, whether or not they are clients of TURITOP (hereinafter, without distinction, “the user” or “the users”) who are considered natural persons. And by personal data, we refer to any information about an identified or identifiable natural person.

If you are already a TURITOP client, having signed a contract with us, you must also refer to the information contained therein regarding the specific privacy terms.

This platform is aimed atusers over 18 years of age, and its use is prohibited for minors under this age. Furthermore, the user responsibly acknowledges that they have sufficient legal capacity to be able to subscribe, where appropriate, to the services offered by TURITOP.

IF YOU BROWSE OR USE OUR WEB PLATFORM, WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

We are responsible for the processing of your personal data:

Full name of the entity: TURITOP, SL

Domicilio social: Avenida Santa Cruz, 117, door 9, 38600, San Isidro, Santa Cruz de Tenerife (Spain)

Physical location/headquarters: Avenida Santa Cruz, 117, door 9, 38600, San Isidro, Santa Cruz de Tenerife (Spain)

Contact telephone number(s): +34 922 394632

Correo electrónico de contacto (general): ayuda@turitop.com

For any question related to the protection of your personal information, send a contact email to: help@turitop.com

WHAT TYPE OF DATA DO WE PROCESS?

The processing of your data is necessary to give you access to the contents and/or functionalities of the platform or, if you require it, to be able to send you the information or provide you with the services provided through it. In this regard, we maintain a firm commitment to treating your personal data legitimately and consistently in accordance with the principles and legal obligations established by current personal data protection regulations.

When you navigate through our platform and, in particular, when you interact or register with us, you provide us with data directly, for example, when you complete any form or request provided online in accordance with the processing purposes indicated in each case ( for example, the contact form).

The data you provide us is in relation to such forms or requests provided through the platform and, in addition, may vary depending on the type of form or request in question. Without prejudice to the above, through the platform, and its different forms/requests, different categories of personal data may be collected, although we will always ask you for appropriate, relevant and limited data to what is necessary with respect to the aforementioned processing purposes ( principle of minimization of personal data):

• Personal identifying data (for example, your name and surname).
• Personal contact information (for example, email).

Likewise, when you browse our platform you must be attentive to the cookies that are installed on your terminal or device since this implies the processing of your personal data according to the type of cookies reported and their specific purposes (ver política de cookies). If you accept our cookie policy, analytical cookies will be served, which involves the processing of personal data associated with your browsing profile for analytical and/or statistical purposes. It is highlighted that continuing to browse our platform, with prior information about our legal policies for the processing of personal data, will imply that you unequivocally accept the cookies that are served, although you can configure the use of such analytical cookies at any time as set forth. indicated in said cookie policy.

FOR WHAT PURPOSES DO WE USE YOUR DATA?

The personal data that you provide us will be processed for the purposes specifically stipulated in this privacy policy and, where appropriate, in the different data forms provided therein. In this sense, the collection of data serves the following processing purposes:

• Enable you to browse our platform, thereby allowing you access to the information and content provided therein.
• Respond to your requests or requests in accordance with the contact forms that you send us, in particular, the registration form as a job candidate. If through such forms you are informed of the possibility of sending you specific promotions, advertising or offers of services, because they are associated with such requests or requests, and you unequivocally agree to their sending, we inform you that you can withdraw or revoke at any time. such authorization by writing to us at: help@turitop.com, although this will not affect the prior processing of your data for these purposes.
• Quickly and efficiently resolve your doubts about our services through the different channels available for this purpose (contact/questions form).
• Allow and manage your registration as a user, if required. You may unsubscribe from such registration whenever you wish by writing to us at help@turitop.com.
• Enable you to access, if you were a client, the digital client channel available through the platform.
• Comprehensive management of your personal accountas a client when you are one by formally signing our contract conditions.
• Allow the uses associated with cookies on the Platform según se describe en nuestra política de cookies .
• If you have accepted the cookie policy, for the development of the purposes associated with the different types of cookies reported through it, in particular, those of an analytical type (browsing/user profile), perform such analysis and statistics associated with web browsing in order to improve our services and the quality of their provision. At any time, if you wish, you can configure the use of analytical cookies, having the right to revoke your consent regarding the purposes associated with these cookies. We inform you that revoking your consent to the processing of your data with respect to certain types of cookies such as session or technical cookies may prevent you from browsing our platform (see Política de Cookies ).
• Adopt whatever protection measures are applicable in accordance with current regulations, including the possible anonymization of your personal data by applying, for this purpose, the appropriate techniques available for this purpose. Consequently, in this area, anonymization and pseudonymization treatments may also be carried out for the best protection of your personal data.
• Apply the relevant security, technical and/or organizational measures on your personal data with a focus on the riskthat exists at all times, including pseudonymization or encryption of personal data through our platform.

WHAT DO WE BASED ON TO LEGITIMATELY PROCESS YOUR DATA?

Fines del tratamiento	Legitimate basis for processing
Enable you to browse our platform, thereby allowing you access to the information and content provided therein.	Your consent and, as the case may be, satisfaction of the legitimate interest, your own or that of third parties, associated with the proper management, maintenance, development and evolution of the platform, tools, network and associated information systems, allowing its correct functioning, functionalities, access to content and services, as well as the general security of all the above points.
Respond to your requests or requests in accordance with the forms or requests that you send us.	Your consent
Quickly and efficiently resolve your doubts about our services.	Your consent and, where appropriate, execution of pre-contractual measures at the request of the user/interested party
Allow and manage your registration as a user if you require it.	Your consent
Enable you to access, if you were a client, the digital client channel available through the platform	Execution of the contract that you have signed with TURITOP.
Comprehensive management of the personal account as a client, if this is the case.	Execution of the contract that you have signed with TURITOP.
If you have accepted the cookie policy provided for this purpose, allow the development of the processing purposes associated with them and, in particular, perform the pertinent analysis derived from your web browsing for analytical and/or statistical purposes.	Your consent
Adopt whatever protection measures are applicable in accordance with current regulations, including the possible pseudonymization and anonymization of your personal data, applying, to this end, the appropriate techniques available for this purpose.	Compliance with a legal obligation (REGULATION (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of these data and repealing Directive 95/46/EC (hereinafter, the “General Data Protection Regulation” or the “GDPR”) https://www.boe.es/doue/2016/119/L00001 -00088.pdf. In the case of treatments intended to guarantee the security of the platform, the network and the associated information system, when appropriate, the satisfaction of the legitimate interest of TURITOP or, where appropriate, of a third party may be claimed (Considering 49 of the GDPR).
Apply the pertinent security, technical and/or organizational measures on your personal data with a focus on the risk that exists at all times.	Compliance with a legal obligation (REGULATION (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of these data and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) https://www.boe.es/doue/2016/119/L00001-00088.pdf. In the case of treatments intended to guarantee the security of the platform, the network and the associated information system, the satisfaction of the legitimate interest of TURITOP or, where appropriate, of a third party may be claimed, when appropriate (Recital 49 of the RGPD).

When the legitimate basis for the processing of your personal data is your consent, we remind you that you have the right to revoke your consent at any time in a simple and free way by writing to help@turitop.com.

¿POR CUÁNTO TIEMPO CONSERVAMOS TUS DATOS?

Personal data associated with the informed processing purposes	Terms or criteria for conservation of your personal data
Data associated with user navigation through our platform	-In general, your data will be kept for these purposes for the essential and necessary time to enable you to correctly navigate and use our platform and the content available through it that you access. -Regarding the data associated with your browsing profile, in relation to the analytical cookies that you have accepted as indicated in the TURITOP cookie policy, you must attend to the section related to their temporality (seepolítica de cookies ).
Respond to your requests or requests in accordance with the forms or requests that you send us.	-For the time necessary to correctly attend to your requests and/or specific requests according to each case. -If they consist of the execution at your request of pre-contractual measures or the signing of a contract with TURITOP, your data will be kept for as long as necessary to give due satisfaction to such pre-contractual measures or service contract between the parties.
Quickly and efficiently resolve your doubts about our services.	For the time strictly necessary to solve or attend to them.
Allow and manage your registration as a user if you require it.	Until the moment you request the effective cancellation of such registration. If you are a TURITOP customer, the personal data retention periods described in these cases may apply as indicated below.
Enable you to access, if you were a client, the digital client channel available through the platform.	Durante los plazos necesarios para dar debida satisfacción a la ejecución del contrato entre las partes (duración del contrato entre las partes).
Comprehensive management of your personal account as a client, when you are one.	Durante los plazos necesarios para dar debida satisfacción a la ejecución del contrato entre las partes (duración del contrato entre las partes).
Adopt whatever protective measures are applicable in accordance with current regulations.	As long as the user’s personal data is processed, including the conservation of such data during the legally established periods, and regardless of the legitimate basis of processing that TURITOP uses.
Apply the pertinent security, technical and/or organizational measures on your personal data with a focus on the risk that exists at all times.	As long as the user’s personal data is processed, including the conservation of such data during the legally established periods, and regardless of the legitimate basis of processing that TURITOP uses.

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

• In accordance with current regulations on the protection of personal data, in everything that concerns the correct treatment of personal information by TURITOP, this entity may also keep the information securely for three years from its collection/capture (periods of prescription of infringements in this area).
• Regarding the storage time of cookies, the user is recommended to consult ourpolítica de cookies(temporary section).
• In general, when personal data is no longer necessary for the processing purposes for which it was collected, it will be blocked, remaining available only to the competent authorities for the possible clarification of legal responsibilities during the processing of the data. themselves, always in accordance with the applicable regulations, and cannot be used for purposes other than these. Once the corresponding legal deadlines have elapsed in the event of blocking, such personal data will be deleted in accordance with the applicable regulations, and may also, if applicable, be securely anonymized by TURITOP (anonymized/non-personal data).

WHAT CONSEQUENCES DO NOT PROVIDE US WITH YOUR DATA?

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

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

1. you can navigate our website correctly (non-acceptance of technical or session cookies)
2. process your request or specific request (for example, due to the lack or insufficient completion of the corresponding form or request).

In any case, the information and personal data that you provide us, depending on each case, must in all cases be:

• Sufficient, although adjusted, limited and proportionate to the legitimate processing purposes reported in each case, with maximum respect for the principles of purpose limitation and minimization of personal data.
• Exact, updated and truthful, in order to be able to adequately verify the identity, capacity and, where appropriate, representation, as well as to be able to adjust, in each case, the data processing carried out to your specific needs and your real situation. . All this in attention to the principle of accuracy of personal data.

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

¿COMPARTIMOS TUS DATOS PERSONALES CON TERCEROS?

In general, we do not share your data with third parties, nor do we sell or offer it to them. However, it is possible that certain third parties may access your personal information in the development of the services they may provide to TURITOP. For example, in the case of third-party cookies that are applied on the platform (seepolítica de cookies ).

TURITOP has various persons in charge of processing personal data under its control, allowing access to them, as trusted suppliers, and to the extent that it is strictly necessary for the provision of the services contracted with them. Such data processors operate under a service contract under the terms, with the conditions and guarantees contained in article 28 of the RGPD, with TURITOP carrying out the corresponding controls, inspections and audits in this area to verify that such data processors strictly comply. with the contracts signed for this purpose and the applicable regulations.

ARE INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA MADE?

We inform you that, in general, international transfers of your personal data are not planned, and TURITOP will adopt the necessary measures and guarantees in this area in accordance with current regulations on the protection of personal data.

Without prejudice to the above, our cookie policy informs us of the existence of possible international transfers of personal data, in relation to the services provided to us by certain companies (third-party cookies). All these international transfers are fully guaranteed according to applicable regulations, being entities included in the list of certified entities within the Privacy Shield framework (seepolítica de cookies ).

¿QUÉ DERECHOS TIENES, QUÉ SIGNIFICAN Y CÓMO PUEDES EJERCERLOS?

Tus derechos	What does it consist of?	¿Cómo ejercitarlo?
Derecho de información	Right to be provided with appropriate information by TURITOP, both at the time your personal data has been collected (whether obtained from you or through a third party), and at any subsequent time regarding the processing of your personal information. You decide about your personal information. Please refer to articles 12 to 14 of the GDPR.	TURITOP tries to provide you with all the necessary information regarding the processing of your personal data in application of articles 12 to 14 of the RGPD. However, if you have any questions or doubts about our privacy and cookie policies, please do not hesitate to write to us by email:ayuda@turitop.comand we will respond to your additional request for information.
Derecho de acceso	Right to obtain confirmation from TURITOP as to whether or not your 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 processed.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
Right to rectification	The right to obtain from TURITOP without undue delay the rectification of personal data under the terms of article 16 of the RGPD.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
Right to erasure	Right to obtain without undue delay from TURITOP the deletion of your personal data under the terms of article 17 of the RGPD.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
Derecho a la limitación del tratamiento	Right to obtain from TURITOP the limitation of the processing of your data when: -You challenge the accuracy of your personal data, for a period that allows TURITOP to verify its accuracy. -The treatment is illicit and you oppose its deletion (and instead, request its limitation). -TURITOP no longer needs the personal data, but you need it for the formulation, exercise or defense of claims. Its exercise will be limited to what is described in article 18 of the RGPD.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
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 GDPR.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
Right to object	Right to object at any time to the processing of your 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.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
Right not to be subject to a decision based solely on automated processing (including profiling)	Right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you or similarly significantly affects you under the terms of Article 22 of the GDPR.	Sending a written communication through the email help@turitop.com with the Ref. “Exercise Rights” accompanying, if necessary, proof of identification, a copy of your national identity document or equivalent identification document (passport, NIE…). .
Derecho a revocar el consentimiento otorgado	You will have the right to withdraw your consent at any time. The withdrawal of consent will not affect the legality of the treatment carried out by TURITOP based on your consent prior to its withdrawal.	Through the forms, contents and privacy configuration spaces provided by TURITOP, according to each case, such revocation may be articulated (for example, requesting the cancellation of the newsletter service requested through the link provided at the end). However, you can always send a communication to this effect to the email: help@turitop.com so that your right can be duly attended to as described in the applicable regulations.
Right to file a claim with the competent supervisory authority (AEPD)	It implies the possibility of going before the supervisory authority if you believe your rights to the protection of personal data 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), you contact us in order to analyze the specific situation that corresponds and try, where appropriate, to find an effective and amicable solution. Apart from the above, if you wish, you can also refer to the AEPD websitewww.aepd.es

ARE SECURITY AND PROTECTION MEASURES APPLIED TO YOUR PERSONAL DATA?

Taking into account the nature, scope, context and indicated purposes of the processing, as well as the risks of varying probability and severity for your rights and freedoms, TURITOP applies (and will apply) appropriate technical and organizational measures in order to guarantee due security and protection of your personal data taking into account privacy criteria from the design and by default, as well as applying a system of approach to concurrent risk that will be reviewed and updated by TURITOP when necessary.

VIGENCIA Y MODIFICACIÓN DE LA POLÍTICA DE PRIVACIDAD

This policy is effective as of August 5, 2020

TURITOP reserves the right to modify this policy, to adapt it to future legislative, doctrinal or jurisprudential developments that may be applicable, or for technical, operational, commercial, corporate and business reasons, informing you in advance and reasonably of the changes that occur when this is possible. In any case, it is recommended that, every time you access this platform, you read this policy in detail, since any modification will be published through it.

Likewise, TURITOP may inform you personally and in advance of the changes planned in this policy, before their entry into force, whenever this is technically and reasonably possible, in particular, when you are considered a registered user or are a client of TURITOP.

¿NECESITAS CONTACTAR CON NOSOTROS?

In case of any question or suggestion that you would like to send us regarding this policy, please do not hesitate to contact us through the email address: help@turitop.com

COMPETENCE AND APPLICABLE JURISDICTION

In general, any controversy and conflict will be preferably submitted by the parties to their knowledge for the purposes of obtaining a friendly and mutually agreed solution using, for these purposes, the channel and email provided in section 13 of this policy.

If this is not possible, taking into account the criteria contained in the RGPD for determining the competence of the leading or main authority in order to know any conflict, controversy or claim regarding this privacy policy, to the At least, administratively, it is reported that such authority will be the Spanish Data Protection Agency (AEPD), or the competent control authority of your place of residence, in any case, complying with the provisions of article 56. of the GDPR. As regards the right to 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 to the extent that the responsible entity is a company based in Spain. The current Spanish and European regulations applicable in this area will be followed.