PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, Lazarus is committed to adopting the necessary technical and organizational measures, according to the security level appropriate to the risk of the data collected.

I. Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following rules:

• The 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 (GDPR).
• The Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.
• The Royal Decree 1720/2007, of December 21, which approves the Regulation developing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• The Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

II. Identity of the data controller

The data controller of the personal data collected in Lazarus is Lazarus Technology S.L.

Their contact details are as follows:

• Address: Calle Isla Graciosa, 7 Planta 2º · 28703 · San Sebastián de los Reyes, Madrid, Spain
• Contact phone: +34 91 658 64 16
• Contact e-mail: info@lazarus.es

III. Data Protection Officer (DPO)

The Data Protection Officer (DPO) is responsible for ensuring compliance with the data protection regulations to which Lazarus is subject. The User can contact the DPO designated by the Data Controller using the following contact details: protecciondatos@lazarus.es.

IV. Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR:

• Principle of legality, fairness and transparency: the User's consent will be required at all times with fully transparent information about the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always up to date.
• Principle of storage limitation: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a way that guarantees their security and confidentiality.
• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

V. Categories of personal data

The categories of data processed in Lazarus are solely identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

VI. Legal basis for the processing of personal data

With the exception of Lazarus service platforms (see point VIII), whose legal basis for the processing of personal data is the provision of a service through a contractual relationship, the legal basis for the processing of personal data in all other situations is consent. Lazarus undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

VII. Purposes of the processing for which the personal data are intended.

Personal data are collected and managed by Lazarus for the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms that the latter fills out or to attend to a request or inquiry.

Likewise, the data may be used, with consent or legitimate interest, for a commercial purpose of personalization, operation, and statistics, and activities inherent to the corporate purpose of Lazarus, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

At the time personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data are intended; that is, the use or uses that will be given to the information collected.

VIII. Web Service Platforms

Lazarus web service platforms are made available solely and exclusively through their partners to the respective end customers, whether individuals or companies, so that access to the platforms is voluntary, that is, the customer subscribes to a service of their own volition and therefore accesses the services available on the associated platform.

The data requested for registration are strictly necessary to identify the user, namely: name and surname, tax identification number, email, and assigned policy/license.

If the customer wishes to delete their data, it will suffice for them to cancel the subscribed service through the Lazarus partner. The data will be deleted as soon as the partner informs us of the cancellation of the service.

Regarding the cookies present on the Lazarus platforms, we only use the so-called authentication cookies, which are deleted once the customer logs out of the platform.

Additional information: it is not mandatory to configure the so-called "cookie notice" when they are strictly necessary for the provision of a service, such as authentication cookies.

IX. Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 2 years, or until the User requests its deletion.

At the time personal data are obtained, the User will be informed about the period during which personal data will be kept or, when that is not possible, the criteria used to determine this period.

X. Transfer of personal data

The User's personal data may be transferred to the companies of the Lazarus group:

• Lazarus Portugal, Lda. NIF: 516309536
• Lazarus Technology, S.L. NIF: B83896753

In any case, at the time personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.

XI. Personal data of minors

Respecting the provisions of articles 8 of the GDPR and 13 of the RDLOPD, only those over 14 years of age may give their consent for the lawful processing of their personal data by Lazarus. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

XII. Secrecy and security of personal data

Lazarus undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to said data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, because Lazarus cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons. As established in article 4 of the GDPR, a personal data security breach means any security breach that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to said data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

XIII. Rights derived from the processing of personal data

The User has rights over their personal data and may, therefore, exercise before the Data Controller the following rights recognized in the GDPR:

• Right of access: It is the User's right to obtain confirmation of whether or not Lazarus is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Lazarus has carried out or is carrying out, as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned thereof.
• Right of rectification: It is the User's right to have their personal data modified that are inaccurate or, taking into account the purposes of the processing, incomplete.
• Right of erasure (“the right to be forgotten”): It is the User's right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible who are processing the personal data of the interested party's request to delete any link to those personal data.
• Right to limitation of processing: It is the User's right to limit the processing of their personal data. The User has the right to obtain the limitation of the processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other data controller.
• Right of opposition: It is the User's right that the processing of their personal data is not carried out or that the processing thereof by Lazarus ceases.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference “RGPDciberidentidad.lazarus.es”, specifying:

• Name, surname of the User and copy of the ID. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other means valid in law that proves identity.
• Petition with the specific reasons for the request or information to which you want to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that proves the request made.

This request and any other attached document may be sent to the following address and/or email:

• Address: Calle Isla Graciosa, 7 Planta 2º · 28703 · San Sebastián de los Reyes, Madrid, Spain
• Contact email: info@lazarus.es

XIV. Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Lazarus, and which are therefore not operated by Lazarus. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own records and their own privacy practices.

XV. Claims before the supervisory authority

In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a supervisory authority, in particular, in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (www.agpd.es).

XVI. Acceptance and changes to this privacy policy

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Lazarus reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to periodically consult this page to be aware of the latest changes or updates.

This Privacy Policy was updated on May 13, 2019 to adapt to 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 (GDPR).