Personal data will be treated in a fair, lawful and transparent manner, and the interested parties must be informed, at the time their data is collected, in the terms established in articles 13 and 14 of the General Data Protection Regulation, hereinafter RGPD , the latter, in case the data has not been obtained directly from the interested party.

Due to the fact that the information is very extensive, Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights allows the Data Controller to comply with the duty of information established in art. 13 or 14 of the RGPD, depending on whether they have been provided directly by the interested party or by third parties, providing basic information (such as the proposal for the Center's corporate email), regarding the identity of the person responsible for the treatment, purpose and exercise of rights and indicating an electronic address or other means that allows simple and immediate access to the rest of the information, either on the Kórdoba Software As a Service, SL website through a hyperlink, or as a document available for download from a URL. It may also be sent as information attached to an email addressed to the affected party.

Kórdoba Software As a Service, SL manages the national and international vehicle transport service through the web portal https://www.eurotransportcar.com and / or its mobile application, in which case, users must accept the conditions of use prior to registering. Likewise, in the registration process, users will have all the information that affects the processing of their data contained in our "Data protection policy", which they can consult in the following links, enabled on the web https://www.eurotransportcar.com/es/extended-privacy .

Kórdoba Software As a Service, SL, is a company committed to complying with the principles of data protection and we respect your privacy, for such purposes:

• Your data will be treated with fairness, lawfulness and transparency, for the explicit and legitimate purposes with which they have been collected.
• We do not send you commercial communications or our newsletter unless you expressly request it, taking into account that you can unsubscribe at any time.
• We make sure that privacy and security are built into everything we do.
• We are committed to keeping your data safe and secure, working only with trusted partners.
• We respect your rights and always try to accommodate your requests to the extent possible, in accordance with our own legal and operational responsibilities.

The protection of your personal data is of vital importance to us, so through this personal data protection policy we inform you about how we collect and process said data, complying with the obligations imposed in Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data and in Organic Law 3/2018, of April 5 December, Protection of Personal Data and guarantee of digital rights.

Kórdoba Software As a Service, S.L. con CIF B14925028

Registered office: Ctra. de Palma del Río km. 3,3 – Parque Joyero Fase 6 A Oficina 2004 - (CP 14005), Córdoba

E-mail: [email protected]

Personal Data refers to any information or data that can directly identify you and that we can obtain through the following means:

• We will process the data that you provide us through our website, forms and applications when you register to use any of our services. Said data will be the identification and contact data, in addition to the economic ones in case you hire our services.
• Your data may also be obtained when using our services, specifically your location; IP adress; the transports that you carry out; the identification code that we assign you internally; your web browsing and mobile application (dates and times you access, clicks you make, etc.) and the hardware, software and browser you use.
• Your data may also be obtained from different social networks, which will provide it to us if you have authorized it by accepting their terms and conditions.
• At the Kórdoba Software As a Service, SL headquarters there are video surveillance cameras that capture and record images in order to guarantee security within the premises.

Remember that before you start using any of our services or functionalities, you should read this Policy, as well as the Terms of Use of the website and / or application. Failure to provide certain information indicated as mandatory may mean that it is not possible to manage your registration as a user or the use of certain functionalities or services available through our website and / or application.

By providing us with your data, you declare that you are the owner thereof, that they are true and are fully updated.

For what purposes can we use your Personal Data?

When we collect your Personal Data, we indicate the mandatory fields through asterisks, being necessary to:

• Comply with our contract with all guarantees (manage the required vehicle transport).
• Comply with legal requirements (for example, billing).
• Manage the required services (for example: sending our Newsletter).

Next, we inform you about the purposesof the treatment of your data:

• Management of the contractual relationship for the provision of the required service, complying with the commitments and obligations derived from said relationship, in the following terms:
  
  
  • Manage the creation of your user account. To access the web and / or the mobile application in general, you must first register as a user of the same, said registration being mandatory in order to have access to the services offered through the application and to certain web services, leaving your access restricted to users of the same, by means of the access code that you have assigned.
    
    For these purposes, access to the different areas that require it made under the password of a registered user will be deemed to have been made by said registered user, who will be responsible in any case for said access and use. Registered Users may modify their exclusive password at any time through the website and / or the application of Kórdoba Software As a Service, SL In case of forgetting the password or any other circumstance that poses a risk of access and / or use by unauthorized third parties, Registered Users must immediately notify Kórdoba Software As a Service, SL so that it can be immediately blocked and replaced.
    
    The User has the right to cancel the account at any time. Notwithstanding the foregoing, where appropriate, personal data will be kept only during the period established by the legally established obligations for this purpose and only to comply with legal requirements.
  
  
  • Monitor the transport of entrusted vehicles so that customers and / or carriers can view the journey in real time. For this, it is necessary that we access the location of the carrier through the geo-positioning systems of your mobile device during the journey. The mobile application will have access to your location data only when you are using it.
    
    Location services use GPS and Bluetooth (if available), along with data from cell towers and Wi-Fi access points, to determine the approximate location of the carrier user device.
  
  
  • Manage queries and information regarding the contracted service through our communications platform or by going to the email and / or phone number provided by the user.
  
  
  • Administrative management for the payment of the requested service. The corresponding invoice will be prepared for its delivery to the user and the payment will be executed through the means chosen by the user.
    
    Payment information (credit card number / Paypal information / bank account details) is not collected by us, but directly by payment service providers.


• Sending commercial communications. If you have expressly authorized it, your identification and contact data will be processed in order to send you, by any means including electronic means, commercial communications informing you about the different products and services offered by Kórdoba Software As a Service, SL You will also have the option to unsubscribe in each commercial communication you receive.


• Subscription to our Newsletter. You will receive information about our offers and news from the sector at the email address you have indicated, with the option to unsubscribe from each communication you receive.


• Improving the quality of our service for the benefit of the user. The data collected from the hardware and/or software of the device on which the application is executed or the web is accessed will be processed in order to optimize the functionalities and future developments of our services.
  
  We will treat the data derived from your browsing our online environments in accordance with what is included in our Cookies Policy, in order to analyze your browsing, personalize your offer and improve our online services and content, based on your consent.
  
  Cookies can be removed from the computer or mobile device by using the browser. To obtain instructions on how to manage and delete cookies, simply go to the "Help" tab of the browser and cookies can be deactivated or, where appropriate, receive a notification each time a new cookie is sent to the computer or mobile device.
  
  Likewise, through our technical and functional cookies we ensure that the website and/or mobile application work correctly and its continuous improvement, in addition to ensuring that they are safe and protected.


• For security reasons, video surveillance cameras have been installed at the headquarters of Kórdoba Software As a Service, SL in order to guarantee the safety of people and their assets, as well as of the entity itself.

Personal data will be kept for processing in our systems as long as the relationship with our entity is maintained for the indicated purposes and after its completion, during the applicable legal prescription periods.

Your data will be treated with loyalty, legality and transparency, being adequate, pertinent and not excessive, in accordance with the aforementioned purposes.

What is the legal basis that allows us to process your data?

• Your data may be processed for the management of the contractual relationship: maintenance, compliance, development, control and execution of the required service.


• The sending of commercial communications by any means, including electronic means and our Newsletters, is legitimized based on the consent that you have previously granted. Likewise, we remind you that you can withdraw said consent at your simple request, by contacting Kórdoba Software As a Service, SL at any of the addresses referenced in point 2 of this document. In the event that you withdraw your consent, said revocation will not affect the legality of the data processing carried out by Kórdoba Software As a Service, SL prior to its revocation.


• The processing of data linked to the improvement of the quality of our services is protected by the legitimate interest of Kórdoba Software As a Service, SL in offering the user the products and services with the functionalities that best suit their needs.


• Finally, the treatment of the images captured by the video surveillance cameras will be carried out under the provisions of Law 5/2014, of April 4, on Private Security based on the legitimate interest of Kórdoba Software As a Service, SL of guarantee the security within the enclosure, as well as of people and goods.

To determine the data retention period of your Personal Data, we use the following criteria:

• Personal Data obtained when contracting our services: while our contractual relationship lasts;


• Personal Data obtained when contacting us for a query: for the time necessary to attend to your query;


• Personal Data obtained when creating an account: until you ask us to delete it;


• Personal Data obtained when giving your consent for the sending of commercial communications or our Newsletter: until you withdraw your consent or demand that we delete them;


• Cookies that are installed on your computer or mobile device: we keep them for the time necessary to achieve your purposes (for example, during a session for session identification cookies) and for a maximum of 365 days.


• Images captured by security cameras: these images will be deleted within a maximum period of one month from their capture, except when they must be kept to prove the commission of acts that threaten the integrity of people, goods or facilities.

Likewise, Kórdoba Software As a Service, SL will cancel or rectify the data when they are inaccurate, incomplete or no longer necessary or relevant for its purpose.

As a general rule, your data will be kept in our systems while the relationship is maintained and after the end of it we will not delete your data, keeping them duly blocked, during the legal prescription periods that are applicable based on what is established in the regulations (Law 58/2003, of December 17, General Tax) or any other applicable regulations, in which case, they will be treated for the sole purpose of proving compliance with our legal or contractual obligations, for compelling legal reasons, or the exercise or the defense of possible claims. After these limitation periods, your data will be deleted or, alternatively, anonymized.

In the management of the services contracted by Kórdoba Software As a Service, SL, service providers may intervene with whom the corresponding data protection documents are formalized to guarantee the confidentiality, security and integrity of the information to which they have access.

Likewise, your data may be communicated to any Public Organization that may require them to comply with legal obligations, as well as, where appropriate, to the corresponding banking entity for economic management. Likewise, both the clients who contract a transport service and the carriers assigned to it will have the corresponding data for their billing, execution and resolution of incidents. The characteristics and status of the vehicle will be published on our transport management platform, as well as the data necessary for its collection and delivery, making it available to our network of carriers for processing and subsequent execution.

International data transfers will not take place, with the exception that Kórdoba Software As a Service, SL may contract the services of providers located in third countries, prior compliance with all the requirements established by the data protection regulations and applying the guarantees and necessary safeguards to preserve data privacy. For more information on privacy guarantees, you can contact Kórdoba Software As a Service, SL at the addresses indicated in section 2.

We are committed to protecting your Personal Data and to taking all reasonable precautions to do so. We contractually require that trusted third parties that handle your Personal Data do the same. Kórdoba Software As a Service, SL guarantees compliance with generally accepted security standards to protect the information provided by the User, both during transmission and during reception and storage.

We have implemented the necessary technical and organizational security measures to guarantee the security, integrity and confidentiality of your personal data in order to prevent its alteration, loss, treatment and/or unauthorized access, taking into account the state of technology. , the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment. However, it is made clear and the User acknowledges and acknowledges that no method of transmission or electronic storage is one hundred percent secure. Therefore, Kórdoba Software As a Service, SL, cannot guarantee its absolute security, but only the utmost diligence regarding it and up to that limit is responsible.

After providing us with your personal data, we inform you of the rights that you can exercise before Kórdoba Software As a Service, SL, at the addresses made available to you in point 2 of this document, and that assist you:

• You have the right toacceder to all the personal data that is in possession of Kórdoba Software As a Service, SL, as well as to request themodification of them or theirsuppression.


• You can ask us to let's limit the processing of your data, in which case we will only keep them for the exercise or defense of claims.


• You can oppose to the processing of your personal data, so Kórdoba Software As a Service, SL will stop processing your data except for compelling legitimate reasons, or the exercise or defense of possible claims.


• You can request theportabilityof your personal data, in which case we will send you the personal data that appears in our databases by email to the address that you provide us in your request, in text format, legible and adaptable to the needs of any other data controller, or we will proceed to transmit it to the new data controller in the same format, to the email address that you indicate in your request.


• You have right not to be the subject of a decision based solely on automated data processing, including profiling.


• You can also withdraw or revoke the consents that you have given expressly, indicating it in your request.

The rights of those affected may be exercised directly by the interested party, providing the DNI or equivalent document, in order to prove their identity or through legal or voluntary representation, in which case, in addition to the DNI or equivalent document of the interested party, the document Authentic accreditation of the representation of the third party together with their ID or equivalent document.

If you consider that the processing of your personal data violates the regulations or the provisions of this clause, you can file a claim with the Spanish Data Protection Agency, which is the competent control authority for the protection of your personal data, through of its electronic headquarters or its postal address that you can consult on the webwww.aepd.es.