Hocelot is concerned about the security and confidentiality of your personal data. In this Privacy Policy, which is an integral part of theLegal Notice, Hocelot explains how it does this, who is responsible for your personal data, and how your data is used. Please read it carefully. By providing your personal data to Hocelot and using its website, Hocelot assumes that you have understood the terms of this Privacy Policy.

The data controller for your personal data is Hocelot Technologies Spain S.L.U, with registered offices at Calle Alfonso XII number 10, 2 left, postalcode 28014, Madrid (hereinafter, “Hocelot”).

The contact details of the Data Protection Officer for Hocelot (hereinafter, “DPO”) are as follows: Phone no. 91 064 94 18 and e-mail address dpo@hocelot.com.

In compliance with the provisions of Personal Data Protection regulations, every visitor to the website (hereinafter, the USER) is hereby informed that any personal information provided under this contractual relationship will be incorporated into a file owned by Hocelot Financial Technologies S.L. This file will contain the following personal data categories:

• Identification information: name, surname(s), postcode, email address, contact telephone number.
• Traffic and location information.
• Commercial and professional information.
• Academic and professional information.

Your personal data can be collected in different ways, including:

• Contact form available on the website.
• Contacting Hocelot via email, postal address, or its phone number.
• Visiting the website through the installation of own and/or third party cookies. Please see our Cookies Policy for further information.

You will at all times be informed about what data requested is mandatory and what data is voluntary for the smooth delivery of the service requested.

You guarantee that the personal data you provide to Hocelot is accurate, complete, true and up-to-date. Hocelot will not be liable for damages of any kind that you may suffer as a result of the communication of personal data that does not comply with the aforementioned specifications.

Likewise, you guarantee that, in the event of communicating third-party personal data to Hocelot, the obtaining and communicating of said data is legitimate and is carried out in accordance

Hocelot processes your personal data for the following purposes:

• To provide you with relevant information about our services. For this purpose, Hocelot may send you information about its products and/or services by any means, including electronic means. Hocelot is entitled to process your personal data in accordance with this purpose, if you so expressly request or consent. Likewise, Hocelot hereby informs you that your personal data may be retained as long as you do not revoke the consent granted.
• To resolve any queries and/or incidents you may have. In this case, the processing of your personal data is covered under legitimate interest, and it will be processed only in accordance with this purpose, during the time required for your query and/or incident to be effectively resolved.
• To manage a possible business relationship linking you to Hocelot. For this purpose, Hocelot may manage any pre-contractual matters in order to be able to enter into a contractual relationship with the company in the future. Hocelot is entitled to process your personal data in accordance with this purpose because such processing is necessary for the implementation of pre-contractual measures at the request of the data subject. Likewise, Hocelot understands that there is a legitimate interest in entering into a contractual relationship pursuant to data protection regulations. Hocelot hereby informs you that your personal data will be retained for up to one (1) year since the last contact with the data subject took place.
• To manage your candidacy as part of a selection process. For this purpose, Hocelot may manage any matters related to your participation in Hocelot selection processes with a view to your incorporation into the company. Hocelot is entitled to process your personal data in accordance with this purpose if you so expressly consent. Likewise, Hocelot hereby informs you that your personal data will be retained for one (1) year in order to incorporate it into future calls to fill vacancies, unless you request it be deleted during the course of that period. If you update or amend your personal data, it will be deleted by Hocelot within one (1) year of the latest update or amendment.
• To know about the usage of the Hocelot website and thus improve its performance, as well as carrying out statistical studies on Hocelot’s commercial activity. For this purpose, Hocelot may process your personal data in order to identify the use made of the website and to conduct various statistical analyses in order to improve the website’s performance. Hocelot will be entitled to process your personal data in accordance with this purpose as long as you expressly consent to the processing of your personal data for these purposes. However, Hocelot hereby informs you that there are small text files called “Cookies” that are installed on your web browser and which are needed, in some cases, for the Website to operate properly. In these cases, you are hereby duly informed that, when browsing the Hocelot website, you expressly consent to the installation of all cookies that are essential for the operation of the Hocelot website. Your personal data will be processed during each cookie’s persistence periods. Please see our Cookies Policy for further information on cookies.

All the personal data required for the proper execution of the different purposes will be processed during the aforementioned periods of time. After the expiration of these periods of time, Hocelot may keep them, duly blocked, during the limitation period of any obligations related to the data that may arise. However, Hocelot guarantees the deletion of personal data once these purposes no longer apply.

Hocelot may communicate your personal data to the following entities, who may process such data in line with their own purposes:

Public administrations and other legal bodies, in the exercise of their powers, in order to comply with any legal obligations applicable to Hocelot.

In addition, in some cases, entities subcontracted by Hocelot could access personal data to help Hocelot in the management of its website and to ensure that your requests are duly addressed. However, Hocelot guarantees that any entities that may access your personal data as Processors will comply with all applicable data protection regulations.

In case any entity is outside the European Economic Area and could access the data from such location, resulting in an international transfer of personal data, Hocelot will guarantee the legitimacy of such international transfers in accordance with the mechanisms provided by the applicable regulations. To this end, Hocelot will demand from these entities guarantees in terms of security and confidentiality, with the aim of ensuring the protection of your personal data.

You may exercise your rights at any time by sending an email to info@hocelot.com, or a letter to Hocelot at Calle Alfonso XII number 10, 2 left, postalcode 28014, Madrid.

Likewise, you may exercise your rights by contacting the Hocelot DPO by sending an email to dpo@hocelot.com.

Your request needs to be accompanied by a copy of your DNI (National ID card) or other equivalent identification document. If your request does not meet the specified requirements, Hocelot may need it to be amended. No payment of any kind will be required for the exercise of your rights.

The rights you can exercise are the following:

• Revoking any consent you have given regarding the processing of your personal data;
• Accessing your personal data in order to obtain confirmation about whether Hocelot is processing said data, and if so, to know exactly what data is being processed;
• Rectifying your personal data in the event it is incomplete, incorrect or inaccurate;
• Erasing your personal data, for example, in the event it is no longer necessary for the purpose for which it was collected to be processed by Hocelot;
• Limiting the processing of your personal data in accordance with the provisions of applicable personal data protection regulations, in which case such data may only be retained by Hocelot for the exercise or defence of claims;
• Transferring your personal data;
• Objecting to the processing of your personal data for reasons related to your particular situation and in certain circumstances, in accordance with the applicable regulations, in which case Hocelot will stop processing your personal data;
• Making a claim to the Data Protection Agency, if you consider that Hocelot has not correctly addressed your request to exercise any of your rights, or has violated current personal data protection regulations.

Hocelot guarantees the security of your personal data through the implementation of technical and organisational measures that ensure its confidentiality and integrity, and that prevent its loss, alteration or unauthorised access, which include the following: encryption of communications between the user’s device and Hocelot’s servers, encryption of information on Hocelot’s own servers, use of a secure server environment (SSL), and establishment of controls for both computer security and access to information.

When determining these measures, criteria such as the processing scope, context and purposes have been taken into consideration; the state of technology and the risks involved.

This Privacy Policy is subject to possible updates, so we recommend that you review it periodically. If it is updated, Hocelot will add a new update date.

Date of last update: 13 de febrero de 2020.