Version 6. Date of publication of this version: November 29, 2020.

1. Content and agreement

This document sets forth the Privacy Policy (hereinafter referred to as the “Privacy Policy”) applicable to www.adquiver.com (hereinafter referred to as the “Website”), a website set up primarily to provide information on the services offered by the company ADQUIVER MEDIA, S.L. (“AdQuiver”), and also applicable to its related domains (www.adquiver.es).

The “User” is anyone who accesses, uses, or browses the Website.

The User decides freely and voluntarily to provide his/her personal data through the Website, freely and voluntarily deciding to use the services and communication channels provided on the Website to make enquiries, in which case he/she may be required to provide certain personal data in order to respond to and process his/her request.

The Website’s complete legal information (the “Complete Legal Information”) consists, jointly, of the text contained in this document together with the Terms and Conditions (which includes the conditions of access, use, and browsing) and the Cookie Policy, forming a single unit. You can access these documents directly via a link at the bottom of the Website (the “Complete Legal Information”). Consequently, the Website’s Legal Information must be interpreted and considered jointly on the basis of all the aforementioned documents.

Access, use, and browsing of the Website by the User implies his/her express consent to and full agreement with the whole content of the so-called “Complete Legal Information” and therefore if you do not agree to any of the terms set out in these documents, please do not provide us with personal data or use the Website or any of the services made available to you on it.

The User may print and digitally store all the aforementioned documents, which are permanently available through a direct link at the bottom of the Website.

The User is advised to read the Complete Legal Information on a regular basis, even each time he/she accesses the Website, and, in any case, each time he/she decides to provide us with personal data through the Website, as its content may be subject to changes. Any changes will be duly published and will always be accessible on the Website, with reference to the version and date.

2. Identification of the owner of the domain and service provider. Means of contact

In compliance with the provisions of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSICE), you are hereby informed that the company that provides its services and offers its products through the domain, as well as being the data controller, is:

ADQUIVER MEDIA, S.L., a Spanish company with Spanish Company Tax ID (CIF) B-76248046. Registered office: C/ Eduardo Benot, 1, Oficina 60, 6º, C.P. 35007 Las Palmas de Gran Canaria (isla de Gran Canaria, Comunidad Autónoma de Canarias, Spain). Registration details: registered in the Commercial Register of Las Palmas, in General Companies Volume 2131, Folio 171, Sheet GC-50724.

ADQUIVER, the provider of the services carried out on the domain www.adquiver.com (the Website) and its related domains (www.adquiver.es), is authorized to use these domains by virtue of assignment of use granted through a license issued by their owner.

To establish direct contact with AdQuiver:

• Postal address office: C/ Eduardo Benot, 1, Oficina 60, 6º, C.P. 35007 Las Palmas de Gran Canaria, isla de Gran Canaria, Comunidad Autónoma de Canarias, Spain.
• Telephone: (+34) 828.051.544.
• info@adquiver.com.

Data Protection Officer contact (to exercise personal data protection rights):

• Postal address office: C/ Eduardo Benot, 1, Oficina 60, 6º, C.P. 35007 Las Palmas de Gran Canaria, isla de Gran Canaria, Comunidad Autónoma de Canarias, Spain.
• Email: legal@adquiver.com

3. Additional information (Right of information) on the processing of personal data

In compliance with the provisions of Article 21 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSICE), 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 (“General Data Protection Regulation”), or “GDPR”) and in the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”) and current regulations on data protection, we inform you that your data will form part of our data processing system, in accordance with the following Information:

a) Who is data controller of my data and what are their identification and contact details?

ADQUIVER MEDIA, S.L., Spanish Company Tax ID (CIF) no. B-76248046, postal address C/ Eduardo Benot, 1, Oficina 60, 6º, C.P. 35007 Las Palmas de Gran Canaria (isla de Gran Canaria, Comunidad Autónoma de Canarias, Spain), contact telephone number: (+34) 828.051.544, contact email: info@adquiver.com.

Data Protection Officer: contact email: legal@adquiver.com

b) Where do the data processed by the company/processor come from, what data are they and what are the purposes of the processing of my data?

Your personal data come from the following means of obtaining/sending provided through the Website, collecting for each of them the data specified and using them for the aims/purposes set out below:

Means of obtaining/sending	Data collected	Aims/purposes for which your data is intended
Sending and receiving of emails.	Providing your data via email is voluntary, requesting, depending on the subject, only mandatory data necessary for legal obligations and circumstances of your relationship with the company and not providing them may entail it not being pursued.	manage, attend to, respond to and maintain the relationship generated through the company’s emails and create their content.
Sending of electronic commercial communications.	We process the email and name/position data. We process your professional contact data, data provided directly by the data subject themselves, as a professional or representative of the private company/public entity to which he/she belongs, as well as his/her email address, interested in finding out about our products and services, or, having been a customer of our products and services, we process your professional contact data, data provided directly by the data subject themselves. Your data for sending emails with commercial electronic communications are voluntary, so if you do not wish to receive these messages, do not consent to them being sent or, if you receive them, you can revoke your consent at any time and can unsubscribe by sending an email to info@adquiver.com. You may withdraw your consent at any time or object to the processing of your data to send you communications about our products and services or summer greetings campaigns by sending an email to info@adquiver.com.	If you have been a customer of our products or services: the purpose for which we process your data is to carry out the management, development, execution, fulfilment and maintenance of the relationship with customers and the provision of services and circumstances of/for that purpose, including invoicing, collections, payments, accounting, administration, taxation, fulfilling contracts and agreements, sending of electronic commercial communications.If you have not been a customer of our products or services but have consented to the sending of newsletters and/or electronic commercial communications by AdQuiver: the purpose for which we process your data is managing newsletter subscriptions and the sending of electronic commercial communications on offers, competitions, promotions and advertising and commercial information on products and services, news, summer greetings campaigns, promotions, benefits, discounts and surveys related to the company’s activity.In any case, the professional contact details that we process at AdQuiver have been provided by the data subject themselves, so we remind you that you must not provide details of third parties unless you have their authorisation and have previously informed them of the content of this information.
Filling out contact forms and/or use of contact details present on the Website.	Mandatory: Name, surname and email address. Voluntary: Those you wish to provide in the “Subject” and “Message” fields.	To manage, attend to, respond to and maintain the relationship generated through the company’s web pages, managing and attending to users and potential customers, as well as creating their content.
Filling out forms to download files and documents made available on the Website.	Mandatory: Name and Surname, Position, Company and postal address. Voluntary: Telephone.	To manage, attend to, respond to and maintain the relationship generated through the company’s web pages, managing and attending to users and potential customers, as well as creating their content.
Filling out the work with us form and sending a CV.	Name, surname(s), academic background, email address, contact telephone number and those you wish to provide voluntarily in the “Message” field and in your attached CV file.	Selection of personnel.
Exercise of personal data protection rights	Name and surname, Spanish ID (DNI) or passport, address, document proving authorisation of representation and contact details.	To manage the exercise of the rights in protection of personal data and the conditions that are derived from them and for them as necessary.

No automated decision-making or profiling are carried out with your data by AdQuiver.

When accessing the resources enabled to collect your personal data, the personal data fields that are marked with an (*) are mandatory, with the rest being voluntary. If data considered obligatory are not provided, AdQuiver may not accept and/or manage the query/request made, or the web service used.

When personal data is requested by filling in a form or similar and it is necessary to click on a “Send” button or similar, a box will be available with “Basic information on data protection”, as well as a box for Acceptance indicating that you have read and consented to, among other documents, where appropriate, this Privacy Policy (and having a direct link to this Privacy Policy at that time).Clicking on the aforementioned box means that you state that have read and been informed of the contents of this Privacy Policy and that you consent to it and to the processing of your personal data in accordance with its contents.

By accepting this Privacy Policy, you expressly consent that the personal data provided through the Website, expressly including your health data, if provided voluntarily through this channel, shall be processed by AdQuiver for the aforementioned purpose(s) and in accordance with the content of this Privacy Policy.

c) What is the Legal Basis for processing my data?

The Legal Basis for sending and receiving of emails is the execution of the contract and/or services requested by you, your consent and compliance with legal obligations, including those relating to data protection.

The Legal Basis for electronic commercial communications is your consent, Article 21(2) of the LSSICE (Law on Information Society Services and Electronic Commerce), the execution of contracts and/or services requested by you, and compliance with applicable legal obligations, including those relating to data protection.

The Legal Basis for the processing of your data when filling in the contact form and/or using the contact details present on the Website, is your consent, the fulfilment of contracts or services requested by you, as well as the fulfilment of the corresponding legal obligations, including those of personal data protection, among others that may be applicable.

The Legal Basis for the processing of your data when filling in the forms for downloading files and documents made available on the Website, is your consent, the fulfilment of contracts or services requested by you, as well as the fulfilment of the corresponding legal obligations, including those of personal data protection, among others that may be applicable.

The Legal Basis for the processing of your data when filling in the “Work with us” section and when sending your CV is your consent, as well as the compliance with the corresponding legal obligations, of personal data protection, among others that may be applicable.

The Legal Basis for the processing of your data in the exercise of your rights regarding the protection of personal data, is your consent, as well as the compliance with the corresponding legal obligations, including those of personal data protection, among others that may be applicable.

d) Who are the recipients of my data?

The recipients of your data shall be the aforementioned controller itself, as well as third parties to whom it may be necessary to send it in compliance with legal obligations or because it is necessary regarding the existence of a legal relationship with the controller or derives from this. The following recipients will be available, in some cases through direct communication via the controller and in others through a response to a request received by the controller (by means of this document you are informed of and expressly consent to the communication of your personal data to the following recipients):

Generally speaking, there is no intention from the data controller to carry out the transfer of your personal data to a third country or international organisation. Notwithstanding the above, through the Website, cookies are installed by third parties based in the United States (see Website Cookies Policy), to which you expressly consent.

e) How long are my data stored for?

The Storage period of your data will coincide with the duration of your relationship with the data controller and the withdrawal of your consent when applicable. This duration will be different for each of the aforementioned means of obtaining/sending data and their respective purposes. Likewise, the data will be kept for the period necessary to comply with a legal obligation that requires the processing and storage of your data or is necessary for the forming, exercising or defending of claims related to your relationship or the processing of your data, in this case until the end of their limitation periods.

With regard to data provided in accordance with the “Work with us” section and the sending of your CV, the storage period for your data will be a maximum period of twelve (12) months, during which time if your CV has not been updated or used, it will be deleted, unless it must be kept for a longer time because there is a specific selection process open for the position in question, or to comply with a legal obligation requiring the processing and storage of your data or needed to form, exercise or defend claims related to your relationship or to the processing of your data, in this case until the expiration of their limitation periods. If you are hired as a result of a selection process, your CV will become part of your employment file, and the provisions of your employment contract will apply to your data.

f) What rights do I have regarding the protection of personal data?

You are informed of the existence of your Rights regarding personal data protection, being the following:

Right to access

The data subject (owner of the data) has the right to obtain from AdQuiver (data controller) confirmation as to whether or not personal data concerning him/her is being processed and, if so, the right to access the personal data and the following information:

1. the purposes of processing;
2. the categories of personal data processed;
3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients within third parties or international organisations;
4. if possible, the intended storage period of the personal data or, if this is not possible, the criteria used to determine this period;
5. the existence of the right to request from the controller the rectification or erasure of personal data or the limitation of the processing of personal data relating to the data subject or to object to such processing;
6. the right to lodge a complaint with a supervisory authority;
7. where the personal data have not been obtained from the data subject, any information available regarding their origin;
8. the existence of automated decision-making, including profiling, and, at least in these such cases, significant information on the logic applied and the significance and expected consequences of this processing for the data subject.
9. where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of appropriate safeguards pursuant to Article 46 concerning the transfer.

Right to rectification

The data subject (owner of the data) shall have the right to obtain without undue delay from AdQuiver (data controller) the rectification of any inaccurate personal data concerning him/her. Bearing in mind the purposes of the processing, the data subject shall have the right to have incomplete personal data amended, including through an additional statement.

Right to erasure

The data subject (owner of the data) shall have the right to obtain without undue delay from AdQuiver (data controller) the deletion of the personal data concerning him/her, and AdQuiver shall be obliged to delete the personal data without undue delay when any of the following circumstances occur:

1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. the data subject withdraws the consent on which the processing is based, and the processing is not based on another legal basis;
3. the data subject opposes the processing and no other legitimate grounds for the processing prevail;
4. the personal data has been unlawfully processed;
5. the personal data must be erased in order to comply with a legal obligation under Union law or the law of the Member States that applies to the data controller;
6. the personal data were obtained in connection with the provision of information society services.

Right to request the limitation of processing

The data subject (owner of the data) shall be entitled to obtain from AdQuiver (data controller) the limitation of processing of the data when any of the following conditions are met:

1. the data subject contests the accuracy of the personal data, for a period enabling the data controller to verify the accuracy of the data;
2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the limitation of their use;
3. the data controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the forming, exercising or defending of claims;
4. the data subject has opposed the processing, while verifying whether the legitimate interests of the controller prevail over those of the data subject.

Right to data portability

The data subject (owner of the data) shall have the right to receive the personal data concerning him/her, which he/she has provided to AdQuiver. (data controller), in a structured, commonly used and machine-readable format, and to transmit them to another data controller without being prevented from doing so by the data controller to whom they have been provided, when:

1. the processing is based on consent, and
2. the processing is carried out by automated means.

The data subject shall have the right to have personal data transferred directly from data controller to data controller where this is technically possible.

Right of opposition and automated individual decision-making

The data subject (owner of the data) has the right to object at any time on grounds relating to his/her particular situation to the processing of personal data relating to him/her in certain cases and has the right not to be subject to automated decision-making, including profiling, which affects him/her legally or significantly affects him/her in a similar way. AdQuiver does not carry out automated decision-making or profiling with your data, except in accordance with the provisions of the Website’s Cookies Policy.

You are informed of your right to withdraw your consent at any time, without this affecting the lawfulness of processing based on the consent given prior to withdrawal.

You may withdraw your consent at any time or object to the processing of your data to send you communications about our products and services or summer greetings campaigns by sending an email to info@adquiver.com.

Similarly, you are informed of your right to file a complaint with a supervisory authority (Spanish Data Protection Agency www.agpd.es).

g) How can I exercise my personal data protection rights?

You can exercise your rights in personal data protection before AdQuiver through any of the following two ways:

1. Through a written document delivered or sent to the address of AdQuiver indicated in section 2 of this Privacy Policy.
2. By email to the address provided in section 2 of this Privacy Policy.

To exercise your rights you must send to us:

• A signed written request.
• Proof of your identity (ID card, passport or equivalent document).
• Documentation accrediting the representation of a third party, if applicable (minor from 0 to 14 years old, a person incapable of exercising his/her responsibilities, power of attorney or a document certifying authorisation of representation).

Depending on the right you exercise, we may ask you for additional information that we need in order to find the information you request from us or to fulfil your right. If so you wish, we make available to you forms for the exercise of your rights, and you may request them from us using the same channels indicated for the exercise of your rights.

4. Quality and accuracy of the data

AdQuiver shall only request those personal data that are adequate, relevant and not excessive in relation to the purpose for which they are to be used.

The User guarantees the truthfulness, accuracy, validity and authenticity of the personal data provided, and is liable for any damages that may be caused to the owner of the Website or to third parties as a result of non-compliance with this guarantee. Likewise, it undertakes to communicate to AdQuiver, if necessary, any modification or rectification of the data, so that its data processing is updated at all times and does not contain errors. The procedure for communicating these circumstances will be the one established for the exercise of the rights in protection of personal data in section 2 of this Privacy Policy.

The person who provides the data guarantees and is responsible for being the owner of the data he/she provides, and is liable for any claims, damages or losses arising from failure to comply with this circumstance. Impersonation in any form, identify theft, the provision of any personal data or information from third parties as belonging to the User, as well as the provision of any untruthful personal data by the User is expressly prohibited. It is expressly prohibited to register with false or fraudulent data, and these registrations may be removed, notwithstanding the taking of the appropriate legal measures.

5. Third-party data

No personal data should be provided by anyone who is not the owner of the data. If the User provides personal data of third parties, he/she must have previously informed these third parties expressly, precisely and unequivocally about the points contained in this Privacy Policy and have obtained their consent and representation to provide them. In the event of non-compliance by the User, AdQuiver shall be exempt from any liability or claim by third parties for the processing of the personal data provided by the User in breach of the requirements set out in this section. This is notwithstanding the communication to be made by AdQuiver to the aforementioned third parties, where appropriate, in accordance with the contact details provided by them, in compliance with legal obligations.

6. IAB Europe Transparency and Consent Framework

AdQuiver participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. ’s identification number within the framework -Vendor ID- is 859.

The EU General Data Protection Regulation (GDPR), which came into force on 25 May 2018, was designed to give the individuals greater control and transparency over their personal data.

The Transparency and Consent Framework simple objective is to help all parties in the digital advertising chain ensure that they comply with the EU’s GDPR and ePrivacy Directive when processing personal data or accessing and/or storing information on a user’s device, such as cookies, advertising identifiers, device identifiers and other tracking technologies.

7. Data of minors

Any Internet user may freely access and browse the contents of the Website. However, the use and/or contracting of certain services and/or products offered through the Website has age limitations. In any case, this Website does not intend to obtain information or personal data from minors either directly or indirectly.

In order to carry out queries or establish information communications in which personal data are provided, if the User is a minor of 15 years of age or older, he/she has the appropriate capacity, and provides his/her personal data directly on the Website through the authorised contact channels, he/she will provide his/her data for consultative purposes, unless the assistance of his/her legal representatives is legally required. However, if the User is a minor of 14 years of age or less, regardless of the fact that he/she may have had free access to visit the content of the Website, he/she may not directly provide his/her personal data through any of the communication channels or forms available on the Website, in which case the consent of his/her legal representatives will always be required.

The contracting of services and the contact to do so, will only be able to be carried out by Users of legal age (18 years old).

AdQuiver is held harmless for failure to comply with these requirements and reserves the right to prevent or not fulfil communications or service provision, due to lack of legal capacity. In order to verify the age and legal capacity and, where appropriate, the authenticity of the consent of the legal representatives, AdQuiver shall have several procedures at its disposal, and may request a copy of the identity document and contact the legal representatives to confirm the representation and authorisation, including requesting the documentation accrediting its parental authority and/or legal representation, without which it shall not be able to process its application. The legal representatives will be considered, in any case, responsible for the acts carried out by parties dependent on them, in accordance with the provisions of the regulations in force.

8. Security measures

AdQuiver adopts and implements the necessary technical and organisational measures to guarantee the security of personal data, in accordance with the requirements of the regulations on the protection of personal data, avoiding its unauthorised alteration, loss, processing or access and guaranteeing the confidentiality, integrity, availability and continuous resilience of the processing systems and services.

Notwithstanding the above, the User should be aware that security measures on the Internet are by no means unbreakable. AdQuiver shall process the personal data provided by the User with due confidentiality and duty of secrecy.

9. Languages

The Website is available for browsing in Spanish and English. You can find all the documents that make up the Complete Legal Information in both languages.

10. Duration and modification of the privacy policy

The applicable Privacy Policy will be that published on the Website at all times. AdQuiver reserves the right to modify, in whole or in part, at any time and without prior notice, the text contained in this Privacy Policy document by extending, improving, clarifying or updating its content, whether due to legislative or legal changes or changes in business strategy, without this modification having a retrospective nature. If there are changes, the previous version shall no longer be applicable and the modified version shall apply from the date of its publication.

The Privacy Policy will always be accessible on the Website at the bottom of the page, with information on the version number in question and the date of publication, from which it takes effect.

11. Nullity and effectiveness

If any of the clauses or texts included in this document is declared null and void, the document itself shall continue to be fully effective and compulsory for the parties under the same terms and conditions, provided that such terms and conditions can stand without the clauses or texts that have been declared null and void.

12. Jurisdiction and applicable law

The applicable law will be Spanish. Unless specific legislation stipulating another jurisdiction is applicable, the User and AdQuiver expressly submit to the courts of the city of Las Palmas de Gran Canaria (Spain) for any dispute, all without prejudice to our willingness to resolve any dispute amicably beforehand.