WEBSITE PRIVACY POLICY

www.cronosports.com

This translation is provided for information purposes only. In the event of any discrepancy, the Spanish version shall prevail.

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with the legislation in force, Cronosports (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

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

• 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).
• Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Spanish Royal Decree 1720/2007 of 21 December approving the Regulation implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of the personal data

The controller of the personal data collected on Cronosports is: INNOVARTIUM ANALYTICS SL, Tax ID (CIF): B06939078 (hereinafter, the Controller). Its contact details are as follows:

Address: Pujada del Camp de Golf 7 1A, La Coma i la Pedra, CP 25284 La Coma, Lleida (Spain)

Contact phone: (+34) 668 89 23 32

Contact email: contacte@cronosports.com

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Cronosports, through the forms provided on its pages, will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between Cronosports and the User, or to maintain the relationship established in the forms filled in by the User, or to deal with a request or enquiry. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is kept which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User's consent shall be required at all times, following completely transparent information about the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected shall 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 kept up to date.
• Principle of storage limitation: personal data shall only be kept in a form which permits the identification of the User for as long as is necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures their security and confidentiality.
• Principle of proactive accountability: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on Cronosports are identification data only. Under no circumstances are special categories of personal data within the meaning of Article 9 of the GDPR processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Cronosports 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 shall have the right to withdraw their consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not affect the use of the Website.

On occasions when the User must or may provide their data through forms in order to make enquiries, 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 proper conduct of the operation carried out.

Purposes of the processing of personal data

Personal data are collected and managed by Cronosports in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms filled in by the latter, or to deal with a request or enquiry.

Likewise, the data may be used for commercial purposes of personalisation, operations and statistics, and activities pertaining to the corporate purpose of Cronosports, as well as for data extraction, storage and marketing studies in order to adapt the Content offered to the User, and to improve the quality, operation and browsing of the Website.

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

Retention periods of personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 12 months, or until the User requests their erasure.

At the time the personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User's personal data shall not be shared with third parties, with the sole exception described below.

If the User has given express consent to receive occasional information about other events organized by third parties present on the platform, Cronosports may send the User such information on behalf of the corresponding organizer. Under no circumstances is the User's personal data (name, email or other) disclosed to that organizer: Cronosports itself sends the communication, acting as an intermediary, without transferring the data. This consent is independent of any other, may be withdrawn at any time with the same immediate effect with which it was given (from the email received itself or by contacting us), and withdrawing it does not condition the use of the Website or participation in any event.

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

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, only persons over the age of 14 may lawfully give their consent to the processing of their personal data by Cronosports. In the case of a minor under 14 years of age, the consent of their parents or guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Cronosports undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such 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, since Cronosports cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Controller undertakes to notify the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data security breach means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data shall be treated as confidential by the Controller, who undertakes to inform of and to guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User holds the following rights vis-à-vis Cronosports, recognised in the GDPR and Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, and may therefore exercise them against the Controller:

• Right of access: this is the User's right to obtain confirmation as to whether or not Cronosports is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Cronosports has carried out or is carrying out, as well as, among other things, the information available on the origin of such data and the recipients of the communications made or planned.
• Right of rectification: this is the User's right to have their personal data modified where they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure ("the right to be forgotten"): this is the User's right, unless otherwise provided by the legislation in force, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; when the User has withdrawn their consent to the processing and it has no other legal basis; when the User objects to the processing and there is no other legitimate ground for continuing it; when the personal data have been unlawfully processed; when the personal data must be erased in compliance with a legal obligation; or when 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 erasing the data, the Controller, taking into account the available technology and the cost of its implementation, must take reasonable steps to inform the controllers processing the personal data of the data subject's request for the erasure of any link to those personal data.
• Right to restriction of processing: this is the User's right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; when the processing is unlawful; when the Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.
• Right to data portability: where the processing is carried out by automated means, the User shall have the right to receive from the Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another controller. Where technically feasible, the Controller shall transmit the data directly to that other controller.
• Right to object: this is the User's right to prevent the processing of their personal data or to have such processing ceased by Cronosports.
• Right not to be subject to a decision based solely on automated processing, including profiling: this is the User's right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by the legislation in force.

The User may therefore exercise their rights by written communication addressed to the Controller with the reference "RGPD-cronosports.com", specifying:

• Name and surname(s) of the User and a copy of their ID document. 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 evidencing the representation. The photocopy of the ID document may be replaced by any other legally valid means of proving identity.
• Request stating the specific reasons for the request or the information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document evidencing the request being made.

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

Address: Pujada del Camp de Golf 7 1A, La Coma i la Pedra, CP 25284 La Coma, Lleida (Spain)

Contact email: contacte@cronosports.com

Links to third-party websites

The Website may include hyperlinks or links providing access to third-party web pages other than Cronosports, which are therefore not operated by Cronosports. The owners of such websites will have their own data protection policies and will themselves be responsible, in each case, for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or an infringement of the regulations in force in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State of 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 (https://www.aepd.es/).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees to the terms on the protection of personal data contained in this Privacy Policy, and that they accept the processing of their personal data so that the Controller may proceed with it in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Cronosports reserves the right to modify its Privacy Policy, at its own discretion, or as a result of a legislative, jurisprudential or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to comply with 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) and with Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.