In accordance with the provisions of 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, and repealing Directive 95/46/EC (hereafter, “GDPR”), and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (hereinafter, “LOPDyDD”) we inform you below of our data protection policy.

1. Data Controller details

Company name:	ADAS3D MEDICAL, SL (“Adas3D”)
ID number:	B67430926
Postal address:	Rambla Catalunya, 53-55, 4º-H 08007 Barcelona
Phone:	(+34) 93 209 41 48
Email:	info@adas3d.com
Contact details of the Data Protection Officer (DPO):	dpo@adas3d.com

2. Purpose, legitimacy of processing and period of data retention

Below you will find a table identifying the purpose of the processing of your personal data, i.e. the reason why Adas3D processes your personal data, the legal basis that allows the processing for the indicated purpose and the period of conservation of your data.

PURPOSE OF THE PROCESSING	LEGAL BASE	CONSERVATION PERIOD
Response to a contact request from a user.	Legitimate interest in responding to contact requests received through the web.	Until the issue that prompted you to fill in the form has been resolved.
Communication management and direct marketing through our newsletter.	Unambiguous consent of the data subject.	Until you expressly inform us that you no longer wish to receive the newsletter.
Response to a contact request for the purpose of receiving a demo from a potential customer or user.	Legitimate interest in responding to a request for a demo of the product marketed by the company.	Until we have provided you with the demo that prompted you to fill in the relevant form.
Management of CV’s received through the “Work with us” section.	Unambiguous consent of the data subject.	For a maximum period of two (2) years from the date on which the data was provided (considering that after this period the information in your CV will be out of date).
Manage access to and provision of documentation, including the user manual, to customers and users.	Clients: the execution of the contract formalised with Adas3D.  Users: Unambiguous consent of the data subject.	Clients: The personal data provided will be kept for as long as there is a contractual relationship with Adas3D. Users: When you expressly inform us that you no longer wish to have access to the user portal.
Management, where appropriate, of your rights as a data subject	Compliance with a legal obligation applicable to Adas3D.	For the time necessary to resolve requests and/or complaints.

In the event that Adas3D processes your personal data for a purpose other than that listed in the table above, Adas3D will inform you prior to the processing about the purpose of the same and will provide you with any other additional relevant information in accordance with the applicable legislation, as well as requesting, where appropriate, your consent, if this is necessary to justify legitimate processing.

We also inform you that, apart from the aforementioned retention periods, we will retain your data during the mandatory limitation periods in order to comply with our legal obligations and for the management of our rights (to file or defend, where appropriate, a claim), also applying the provisions of the corporate regulations on archiving and documentation retention periods.

3. Recipients of the personal data: assignees and data processors

We inform you that your personal data will not be communicated to third parties, unless legally obligated to do so.

Additionally, we inform you that, in certain cases, we may communicate your data to other entities (including companies of the group), in their capacity as data processors of the data owned by Adas3D Medical, SL, and in accordance with the provisions of article 28 GDPR, a contract has been formalized which legitimizes the access of these entities to the personal data and which includes the obligations that shall be contemplated in the processing. 

Data processing carried out outside the territory of the European Union are carried out on the basis of an adequacy decision (third country or international organisation guaranteeing an adequate level of protection) or by means of appropriate safeguards (standard data protection clauses, binding corporate rules). This information is available to data subjects who may request a copy of it by sending an e-mail to the DPO contact address. 

We use the reCAPTCHA service of Google Inc. (Google) to protect the data sent through the forms of our users’ pages. This service makes it possible to differentiate the data sent by people from automated messages and involves the transmission of the IP address and other data required by Google for the use of the reCAPTCHA service. For this purpose, the data will be transmitted to Google in order to be used. The IP address will be encrypted by Google in the member states of the European Union as well as in the states associated with the European Economic Area. Only in some exceptional cases, the IP addresses will be transmitted to the Google server in the United States for encryption. On behalf of the owner of this website, Google will use this information to evaluate the use of the service by users. The IP address transmitted by reCAPTCHA will be kept separate from other Google data. Google’s privacy policy applies to these data. All details about Google’s privacy policy can be read on the page https://www.google.com/intl/es/policies/privacy/

By using the reCAPTCHA service, the user consents to the processing of data about him that Google has in the manner and purposes set out above.

4. Data subject rights 

We hereby inform you that, in relation to the processing of your personal data, you have the right:

• To obtain confirmation as to whether or not Adas3D is processing personal data concerning you.
• To request access, rectification of inaccurate or incomplete data and, where appropriate, deletion of your data when, among other reasons, they are no longer necessary for the purposes for which they were collected.
• In certain circumstances, you may:
  • request the restriction of the processing of your data, in which case we will only keep them for the exercise or defence of claims.
  • on grounds relating to your particular situation, object to the processing of your data, in which case we will no longer process them, except for compelling legitimate reasons, or for the exercise or defence of any claims.
• To receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable form and to transmit it to another data controller without being prevented from doing so by us. In this regard, you may request that we transmit your personal data directly, if technically feasible, to the data controller indicated in your communication.
• To withdraw your consent, if you have given your consent for a specific purpose. The withdrawal of consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal.

You may exercise your rights at any time and free of charge, by sending an email to dpo@adas3d.com digitally signed (electronic ID or other recognised certificate), or through a written communication addressed to Adas3D Medical, SL, with address for data protection processing purposes, at 08007 Barcelona, Rambla Catalunya, 53-55, 4º-H (Ref. RGPD). The content of the request must include: your name and surname(s); a photocopy of your national identity card, passport or other valid document that identifies you and, if necessary, of the person representing you, as well as the document or electronic instrument accrediting such representation; details of the request being made; address for notification purposes; date and signature of the applicant; and documents accrediting the request being made, if necessary.

 If you consider that the processing of personal data concerning you infringes the applicable regulations or you are simply not satisfied with the exercise of your rights, you have the right to file a complaint with the Spanish Data Protection Agency, through any of the following channels: (i) by telephone on +34 901 100 099, or +34 912 663 517; (ii) by electronic means, by going to the website https://sedeagpd.gob.es/sede-electronica-web; (iii) in person by going to calle Jorge Juan, 6, 28001 Madrid.