WEBSITE PRIVACY POLICY

www.manave.net

I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, Manave (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporating 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, the same respects 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).

- The Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

- Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

- Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected in Manave is: Henry Guzman, : (hereinafter, Data Controller). His contact details are as follows:

Address: San Jose Costa Rica

Contact phone number: (+506) 8877-7000

Contact Email: info@manave.net

Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Manave, through the forms provided on their pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between Manave and the User or the maintenance of the relationship established in the forms that this fills, or to meet a request or query from the same. Also, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided in Article 30.5 of the RGPD is applicable, a record of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.

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 the guarantee of digital rights:

- Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times following fully transparent information of the purposes for which the personal data are collected.

- Purpose limitation principle: personal data will be collected for specified, 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.

- Accuracy principle: personal data must be accurate and always up to date.

- Principle of limitation of the storage period: personal data shall only be kept in such a way as to allow the identification of the User for the time necessary for the purposes for which they are processed.

- Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure their security and confidentiality.

- Principle of proactive responsibility: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Manave are only identification data. In no case, special categories of personal data within the meaning of Article 9 of the GDPR are processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Manave undertakes to obtain the express and verifiable consent of the User to the processing of his personal data for one or more specific purposes.

The User shall have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not condition the use of the Website.

In the occasions in which the User must or may provide his data through forms to make inquiries, request information or for reasons related to the content of the Website, he will be informed in case the completion of any of them is mandatory because they are essential for the proper development of the operation performed.

Purposes of the processing for which the personal data is used

Personal data are collected and managed by Manave in order to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills or to respond to a request or inquiry.

Likewise, the data may be used with a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of Manave, 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 the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 6 months, or until the User requests their deletion.

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

Recipients of personal data

The User's personal data will not be shared with third parties.

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

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of the Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Manave. In the case of a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Manave undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

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

However, because Manave 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 security of personal data occurs that is likely to involve a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure 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 has over Manave and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

- Right of access: this is the User's right to obtain confirmation of whether or not Manave is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Manave has carried out or will carry out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned of the same.

- Right of rectification: This is the User's right to have his or her personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.

- Right of erasure ("the right to be forgotten"): This is the User's right, provided that the legislation in force does not provide otherwise, to obtain the deletion of his/her personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his/her consent to the processing and the processing has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue the processing; 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 Controller, taking into account the technology available and the cost of its implementation, must take reasonable steps to inform the controllers who are processing the personal data of the data subject's request for the deletion of any link to such personal data.

- Right to limitation of processing: This is the User's right to limit the processing of his or her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.

- Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format, and to transmit it to another Controller. Whenever technically possible, the Data Controller shall transmit the data directly to such other controller.

- Right to object: This is the User's right not to have his or her personal data processed or to have the processing of such data by Manave cease.

- Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the User not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, existing unless otherwise provided by law.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "RGPD-www.manave.net", specifying:

- Name, surname of the User and copy of the ID card. In cases where the representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation. The photocopy of the DNI may be substituted by any other means valid in law that proves the identity.

- Request with the specific reasons for the request or information to be accessed.

- Address for notification purposes.

- Date and signature of the applicant.

- Any document that accredits the request being made.

This request and any other attached documents may be sent to the following address and/or e-mail:

Mailing address: San Jose Costa Rica

E-mail: info@manave.net

Links to Third Party Websites

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

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to file a complaint before a supervisory authority, in particular, in the State in which he/she has his/her 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 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 to accept the processing of their personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of the Privacy Policy of the same.

Manave 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 consult this page periodically to be aware of the latest changes or updates.

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