Privacy Policy of Gabinete Morales Asociados S.L. (Morales Abogados Penalistas)

This privacy policy (hereinafter, the "Privacy Policy") explains in detail the way in which we collect your personal data, why we need to collect it, its purpose, and how we store it, always in accordance with the services offered by Gabinete Morales Asociados S.L. (hereinafter "Morales Abogados Penalistas").

This Privacy Policy applies to the personal data that you have provided to us (hereinafter, the "Users" or "User") on our website (hereinafter, "Website" or "Platform"), in order to provide you with a better service.

By accessing our Website and using our services, you acknowledge that you have read and understood this Privacy Policy and the practices to collect and process information described herein.

In accordance with applicable data protection legislation, including but not limited to the General Data Protection Regulation [EU] 2016/679 (hereinafter, the "GDPR"), the details of the data controller of the personal data you provide to us are as follows:

• Holder: Gabinete Morales Asociados, S.L. (hereinafter, “Morales Abogados Penalistas”).
• Representative: Fermín Morales Prats
• Registered office: Manuel Silvela 1, 1º izq 28010 Madrid
• Tax identification code: B-87937603
• Telephone: (+34) 932.419.820
• E-mail: info@moralespenal.com

We understand that providing information online implies a high degree of trust on your part, which is why we take this trust very seriously. Our top priority is to guarantee the security and confidentiality of your information.

WHAT INFORMATION DO WE COLLECT?

The following is a list of some of the information that we may request from you, at Morales Abogados Penalistas.

From the Website

The information we can collect from Users from our Platform may vary depending on whether or not you are registered. In the event that you decide to register to access our services, the data that we will request is as follows:

• Identification data
• Postal or e-mail address
• Commercial information
• Financial information
• Telephone number
• Employment details
• Social circumstances
• Personal features

You must bear in mind that the list above is merely informative and not exhaustive, which means that we may request some additional information, but we will always justify and explain why we need such additional information. We may also collect data from you when you access our Website, such as browsing data, web browser preferences, etc. If you would like more information about this, click on the Cookies Policy (hyperlink).

All the data indicated above is collected by Morales Abogados Penalistas solely and exclusively to offer you the contracted services.

Automatic collection of information

We automatically collect certain information from your computer or device when you visit the Morales Abogados Penalistas Platform. For example, we will collect session data, including your IP address, browser software or device and referring website. We may also collect information about your online activity, such as the content viewed, pages visited and searches and/or bookings that were provided or made. One of our goals in collecting this automatic information is to better understand our Users' interests and preferences.

For more information, please click on the Cookie Policy (hyperlink).

Cookies and other web technologies

We collect information through cookies and other similar technologies (such as web beacons). Cookies are small text files that are automatically stored on your computer or mobile device when you visit almost any website. They are stored through your internet browser. Cookies contain basic information about your internet usage. Your browser sends these cookies back to the website each time you revisit it so that it can recognise your computer or mobile device, personalise, and improve your browsing experience.

For more information, please click on the Cookie Policy (hyperlink).

HOW DO WE USE YOUR INFORMATION?

General purposes

We want you to know that all data that you have provided to Morales Abogados Penalistas is used exclusively for the following:

• Carrying out the contracted services
• Establishing communications between the parties
• Sending the newsletter
• Carrying out anonymous statistical reports regarding access habits and Users’ activity carried on the Website
• Complying with the legally established obligations

At no time will your data be used for any purpose other than those indicated above, unless required by law or by a Court order.

Under no circumstances will we carry out any of the following actions in relation to the personal data provided to us by Users of the Website:

• Transferring them to other persons or entities without your prior consent
• Transferring them to other States without your prior consent

E-mail communications

Any communications you may receive through electronic means are based on what we believe may be of interest to you. Occasionally, we may use the personal data provided by Users to show you advertising material from Morales Abogados Penalistas or other content from other websites that may be of interest to you. If you do not wish us to use your data for this purpose, inter alia, you can deactivate the corresponding cookies indicated in the Cookie Policy (hyperlink).

The receipt of any email communications for marketing purposes is based on your prior consent. If you no longer wish to receive such communications, you can unsubscribe from the communication service here. Hyperlink

WITH WHOM DO WE SHARE YOUR INFORMATION?

Where appropriate and in accordance with local laws and requirements, Morales Abogados Penalistas may share your information with the following entities:

• Any group company.
• Third party vendors who provide services on our behalf, including business analysis, payment processing, customer service, marketing, public relations, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorise third party vendors to collect information on our behalf, including, for example, information necessary to use certain features of our Website or to facilitate the delivery to you of online advertising tailored to your interests. Third-party vendors may collect and have access only to the information necessary to perform their services, but are not allowed to share or use the information for any other purpose. In any case, if a third party needs to contact you directly, we would notify you so that you could give us your consent.
• Affiliated websites. If you were referred to Morales Abogados Penalistas from another website, we may share your registration information with that referring website, such as your name, email address, postal address, telephone number and travel preferences. We have not established limitations on the use of personal information by referring websites and recommend that you review the privacy policies of any website that has referred you to Morales Abogados Penalistas.

We may also share your information if we believe, in our sole discretion, that such sharing is necessary in:

• Complying with lawful and enforceable subpoenas or Court orders or other legal processes; establishing or exercising our legal rights; defending against legal claims; or in other cases where we are required to do so by law. In such cases, we reserve the right to raise or withdraw any objection or legal right available to us;
• Investigating, preventing or taking action regarding illegal or suspected illegal activities; protecting and defending the rights, property or safety of Morales Abogados Penalistas, our clients or others; and in connection with our Terms of Use and other agreements; or
• In connection with a corporate transaction, such as a divestiture, merger, consolidation or sale of assets, or in the unlikely event of bankruptcy.

In addition to the above, you will receive notice when your personal information is to be shared with third parties, and will be able to choose whether you want us to share your information.

We may also share anonymous or aggregated information with third parties, including advertisers or investors. For example, we may tell our advertisers the number of visitors to our Platform or the most popular holiday destinations and hotels. This information does not contain any personal information and is used to develop content and services that we hope will be of interest to you.

If we sell or transfer part or all of the company or our assets to another company (for example, in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution or liquidation), information such as name and email address, User content and any other information collected through the Platform may be part of the sale or transfer. In that case, the User content will remain yours. The buyer or transferee will have to respect the commitments agreed to in this Privacy Policy, or seek your consent to any changes they wish to make.

In any case, if you do not agree to your information being shared with a third party, you may exercise your right to limit the processing of your information, as set out in the section relating to your rights. Hyperlink

HOW LONG DO WE KEEP YOUR INFORMATION?

The data conservation periods depend on the type of data collected and its purpose, and may vary depending on the services contracted by each client. In any case, data should be kept for as short a time as possible, bearing in mind the following deadlines:

• A period of 4 years, in accordance with the Spanish Law on Infringements and Penalties in the Labour Sector (obligations regarding affiliation, registrations, cancellations, contributions, salary payment), as well as in accordance with the General Tax Law.
• A period of 5 years, in accordance with Article 1964 of the Spanish Civil Code.
• A period of 6 years, in accordance with Article 30 of the Spanish Commercial Code (invoices, accounting books, etc.).
• A period of 10 years in accordance with Article 25 of the Spanish Law on the Prevention of Money Laundering.

As for the data of Users who subscribe especially to the news channel of the data can be kept until the User unsubscribes, always indicating that the data will be retained.

WHAT ARE YOUR RIGHTS AND CHOICES REGARDING THE COLLECTION AND USE OF YOUR INFORMATION?

One of the main objectives of the GDPR is to protect and explain your rights in relation to the privacy of your personal data. That is why the GDPR confers you various rights associated with your data, even after you have given us your explicit consent to process that data.

The rights to which you are entitled, in accordance with the data protection regulations currently in force, are as follows:

• Right of access: all Users have the right to request Morales Abogados Penalistas at any time that we disclose the information we hold about them and thus modify, update or delete it.

• Right of rectification: Users have the right to request the rectification of inaccurate or incomplete personal data held about them by Morales Abogados Penalistas. In the event that their data has been shared with third parties, based on the request of the User, we will communicate the rectification of the data that has been transferred to the third party, except in those cases where it involves a disproportionate effort.

• Right of cancellation or deletion: Users have the right to request the deletion of their personal data from our database. In this situation, the User must be aware that the deletion of their personal data implies the closure of their particular account on the Morales Abogados Penalistas Platform, and they will not be able to benefit from all the services and advantages that this entails. Please note that after closing an account, you will no longer be able to log in or access your personal information. However, you may open a new account at any time.

• Right to object: This right allows you to object to the processing of your personal data when we do so for one of the four reasons listed below: i) our legitimate interests; ii) authorize us to perform a task that is in the public interest or exercise official authority; iii) send you direct marketing material; and iv) for scientific, historical, research or statistical purposes.

• Right to withdraw consent: after they have given us their express consent, Users may object to the processing of their data for a series of specific purposes (e.g. marketing, profiling, transfer to a specific third party, etc.). The User may withdraw their consent at any time so that Morales Abogados Penalistas can stop processing their data for the purpose indicated by the User.

• Right to limit consent: In certain circumstances, the User has the right to request that we limit the processing of their personal data, which means that we can only continue to store it, but we cannot carry out any other processing activity until: (i) one of the circumstances listed below is resolved; (ii) the User consents; or (iii) further processing is necessary either for the initiation of, carrying out of or defence in legal proceedings, for the protection of the rights of another natural person or for reasons of substantial public interest of the European Union or of a particular Member State.

The User has the right to request that the processing be restricted in the following circumstances:

• Where the accuracy of his or her personal data directly or indirectly processed by Morales Abogados Penalistas is contested.
• When the User objects to the processing of their personal data for our legitimate interests.
• When the processing is unlawful.
• When the User considers that we no longer need to continue processing their data.

• Right of portability: The User has the right to request the portability of his/her data to another data controller. In this case, he/she will be provided with a digital dossier of all the data held by Morales Abogados Penalistas so that it can be transferred to the new data controller.

If you wish to exercise any of the aforementioned rights, you can send an e-mail to info@moralespenal.com or a communication by post to Calle Tenor Viñas, 4-6, 5º1ª, 08021, Barcelona, always including a copy of your ID card or identification document, as well as indicating the right you wish to exercise.

The User must bear in mind that the exercise of any of these rights may affect the correct development of the services offered by Morales Abogados Penalistas.

HOW DO WE PROTECT YOUR INFORMATION?

We want you to feel secure when using Morales Abogados Penalistas’s Website and we are committed to protecting the information we collect. Although no website can fully guarantee your security, we have implemented and maintain appropriate physical, administrative, technical and organisational measures to protect the personal information you provide to us against unauthorised or unlawful access, disclosure, and against accidental loss, damage, alteration or destruction. For example, only authorised employees may access personal information, and they may only do so to carry out permitted business functions. We also use encryption to transmit personal information between our system and your system and between our system and the systems of parties with whom we share sensitive information, and we use firewalls and intrusion detection systems to prevent unauthorised persons from gaining access to your information.

EXTERNAL LINKS

Our Platform may include links to third party websites. If you access other websites from links provided on our Platform, the operators of those websites may collect information about you and use it in accordance with their privacy policy, which may differ from our Privacy Policy. We encourage you to review the privacy statements posted on those other websites to understand their procedures for collecting, using and disclosing personal information.

LEGITIMACY

The legal basis for the processing of your data is the performance of the contracted services.

Morales Abogados Penalistas will only provide information to law enforcement agencies under Court order or by obligation of a rule with the force of law, without prejudice to being able to initiate actions to suspend or cancel the User's account in the event of any inappropriate use of the application. The information provided will only be that available to Morales Abogados Penalistas.

The User guarantees that the data provided is true, accurate, complete and up to date, and is responsible for any damage or harm, direct or indirect, that may be caused as a result of non-compliance with this obligation. In the event that the data provided belongs to a third party, the User guarantees that he/she has informed said third party of the aspects contained in this document and obtained their authorisation to provide their data to Morales Abogados Penalistas for the aforementioned purposes.

CONSENT

Morales Abogados Penalistas will only proceed to process the personal data of Users provided that they have given us express consent to the processing. The data will only be processed for the purposes indicated in this Privacy Policy, and Morales Abogados Penalistas may not use the personal data of Users for any other purpose, unless additional express consent has been obtained for the processing of data for a purpose not described herein.

Likewise, the consent given by Users complies with the requirements of article 4 of the GDPR, whereby the consent given is "any freely given, specific, informed and unambiguous indication that the data subject consents, by means of a statement or a clear affirmative action, to the processing of personal data concerning him/her".

HOW CAN YOU CONTACT US?

If you have any questions about this Privacy Policy, you can contact us by:

• Post: Tenor Viñas, 4-6, 5º1ª 08021 Barcelona.
• Telephone: (+34) 932.419.820
• E-mail: info@moralespenal.com