Privacy and Data Protection Policy

Respecting current legislation, Lazarus commits to adopting the necessary technical and organizational measures, according to the appropriate security level for the risk of the data collected.

I. Laws incorporated in this privacy policy

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

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

II. Identity of the data controller

The controller of the personal data collected at Lazarus is Lazarus Technology S.L. Contact details are as follows:

• Address: Avda. Isla Graciosa, 7 - 2nd floor - 28703 San Sebastián de los Reyes (Madrid) - Spain
• Phone: +34 91 658 64 16
• E-mail: info@lazarus.es

III. Data Protection Officer (DPO)

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

IV. Principles applicable to personal data processing

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 lawfulness, fairness and transparency: the User's consent will be required at all times after completely transparent information about the purposes for which personal data is collected.
• Principle of purpose limitation: 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.
• 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 form that allows 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 manner that ensures their security and confidentiality.
• Principle of proactive responsibility: the Controller will be responsible for ensuring that the above principles are complied with.

V. Categories of personal data

The categories of data processed at Lazarus are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

VI. Legal basis for personal data processing

Except for Lazarus service platforms (see point VIII), whose legal basis for processing personal data is the provision of a service through a contractual relationship, the legal basis for processing personal data in other situations is consent.

Lazarus undertakes to obtain the User's express and verifiable consent 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. It will be as easy to withdraw consent as to give 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 Website content, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation performed.

VII. Purposes of personal data processing

Personal data is collected and managed by Lazarus 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 out or to attend to a request or inquiry.

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

At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be used; 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 exclusively through its partners to 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 free will and therefore accesses the services available on the associated platform.

The data requested for registration is strictly necessary to identify the user, namely: name and surname, tax ID, email and assigned policy/license. If the customer wishes to delete their data, they simply need to cancel the service subscribed through the Lazarus partner. The data will be deleted as soon as the partner informs us of the service cancellation.

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

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

IX. Personal data retention periods

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: 2 years, or until the User requests their deletion.

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

X. Transfer of personal data

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

Lazarus Portugal, Lda. Tax ID: 516309536

Lazarus Technology, S.L. Tax ID: B83896753

In any case, at the time personal data is obtained, the User will be informed about the recipients or categories of recipients of 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 processing of their personal data lawfully by Lazarus. If it is a minor under 14 years of age, parental or guardian consent will be necessary for processing, and this will only be considered lawful to the extent that they have authorized it.

XII. Confidentiality and security of personal data

Lazarus commits to adopting the necessary technical and organizational measures, according to the appropriate security level for the risk of the data collected, to ensure 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 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 completely 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 Controller commits to communicate to 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. Following the provisions of Article 4 of the GDPR, a personal data security breach means a security breach that results 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 Controller, who commits to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible

XIII. Rights derived from personal data processing

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

• Right of access: It is the User's right to obtain confirmation as to whether Lazarus is processing their personal data or not and, if so, to obtain information about their specific personal data and the processing that Lazarus has performed or performs, as well as, among other things, the available information about the origin of such data and the recipients of communications made or planned.
• Right of rectification: It is the User's right to have their personal data that turns out to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
• Right to erasure ("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 they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to processing and there is no other legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; personal data has been processed unlawfully; personal data must be deleted in compliance with a legal obligation; or personal data has 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 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 that personal data.
• Right to restriction of processing: It is the User's right to limit the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their 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: In case the processing is carried out by automated means, the User will 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. Whenever technically possible, the Controller will directly transmit the data to that other controller.
• Right to object: It is the User's right not to have their personal data processed or to have processing of the same ceased by Lazarus.
• 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 automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights through written communication addressed to the Controller with the reference "RGPDciberidentidad.lazarus.es", specifying:

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

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

Address: Avda. Isla Graciosa, 7 - 2nd Floor - 28703 San Sebastián de los Reyes (Madrid) – Spain

E-mail: info@lazarus.es

XIV. Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites different from Lazarus, and therefore not operated by Lazarus. 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.

XV. Complaints to the supervisory authority

In case 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 complaint 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 for the User to have read and agree 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 Controller can proceed with it in the manner, for the periods and for the purposes indicated. 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 consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated on May 13, 2019 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).