Web Site Privacy Policies (online.lead2team.com and lead2.team)

I. PRIVACY POLICY AND DATA PROTECTION

In compliance with the applicable legislation, Lead2Team (hereinafter also the Website) undertakes to adopt the necessary technical and organisational measures, in accordance with the security level appropriate to the risk of the data collected at:

online.motorprive.com

lead2.team

online.lead2team.com

Contact form: The purpose of collecting data in this form is to be able to answer the queries raised and to send the user the information requested through the email address or telephone number indicated in the form.

Laws incorporated into 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, it complies with 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).
• Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The controller of the personal data collected at Lead2Team is: MEDIAGACH, S.L., holding Tax ID (NIF): B67287870 and registered at: the Commercial Registry of Barcelona with the following registration details: Volume 46604, Folio 90, Section 8, Sheet 525203, Entry 1.

Register of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Lead2Team through the forms available on its pages will be incorporated into and processed in our files in order to be able to provide, expedite and fulfil the commitments established between Lead2Team and the User, or to maintain the relationship established through the forms that the User completes, or to attend to a request or query from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is kept specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

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 and following 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 User's consent shall be required at all times, following completely transparent information about the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
• Principle of data minimisation: the personal data collected shall 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 kept up to date.
• Principle of storage limitation: personal data shall be kept in a form which permits identification of the User only for as long as is necessary for the purposes of the processing.
• Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures their security and confidentiality.
• Principle of accountability: the Controller shall be responsible for ensuring that the foregoing principles are complied with.

Categories of personal data

The categories of data processed at Lead2Team are solely identifying data. Under no circumstances are special categories of personal data within the meaning of Article 9 of the GDPR processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Lead2Team 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 shall have the right to withdraw their consent at any time. It shall 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.

On the occasions when the User must or may provide their data through forms in order to make queries, request information or for reasons related to the content of the Website, the User will be informed if the completion of any of them is mandatory because such data are essential for the correct performance of the operation carried out.

Purposes of the processing for which the personal data are intended

The personal data are collected and managed by Lead2Team for the purpose of being able to provide, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established through the forms that the latter completes, or to attend to a request or query.

The data may likewise be used for commercial personalisation, operational and statistical purposes, and for activities inherent to the corporate purpose of Lead2Team, as well as for the extraction and storage of data and marketing studies in order to tailor the Content offered to the User, and to improve the quality, operation and navigation of the Website.

At the time the personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data are intended; that is, of the use or uses to which the collected information will be put.

Retention periods for personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing or until the User requests their deletion.

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

Recipients of the personal data

The User's personal data will be shared with the following recipients or categories of recipients:

MEDIAGACH, S.L., with registered office in Badalona, Calle Francesc Layret, number 119, 5th floor, door 1

Should the Controller intend to transfer personal data to a third country or international organisation, at the time the personal data are obtained the User will be informed of the third country or international organisation to which it is intended to transfer the data, as well as of the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only persons over 14 years of age may give their consent for the lawful processing of their personal data by Lead2Team. In the case of a minor under 14 years of age, the consent of the parents or guardians shall be necessary for the processing, and this shall only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Lead2Team undertakes to adopt the necessary technical and organisational measures, in accordance with the security level appropriate to the risk of the data collected, so as to guarantee the security of personal data and to prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

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

However, because Lead2Team cannot guarantee the impregnability of the internet nor the total absence of hackers or others who may fraudulently access the personal data, the Controller undertakes to notify 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. In accordance with the provisions of Article 4 of the GDPR, a personal data security breach means any security breach resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

The personal data will be treated as confidential by the Controller, who undertakes to inform of, and to 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.

Rights arising from the processing of personal data

The User holds against Lead2Team, and may therefore exercise before the Controller, the following rights recognised in the GDPR and in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

• Right of access: This is the User's right to obtain confirmation as to whether or not Lead2Team is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Lead2Team has carried out or is carrying out, as well as, among other things, the information available about the origin of such data and the recipients of the communications made or planned of the same.
• Right to rectification: This is the User's right to have their personal data modified where they turn out to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): This is the User's right, provided that the applicable legislation does not establish otherwise, to obtain the erasure of their personal data where these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this has no other legal basis; the User objects to the processing and there is no other legitimate ground to continue with it; the personal data have been processed unlawfully; the personal data must be erased 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 erasing the data, the Controller, taking into account the available technology and the cost of its implementation, must adopt reasonable measures to inform the controllers who are processing the personal data of the data subject's request to erase any link to those personal data.
• Right to restriction of processing: This is the User's right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing where they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs them to make claims; and where the User has objected to the processing.
• Right to data portability: Where the processing is carried out by automated means, the User shall have the right to receive their personal data from the Controller in a structured, commonly used and machine-readable format, and to transmit them to another controller. Whenever technically possible, the Controller shall transmit the data directly to that other controller.
• Right to object: This is the User's right for the processing of their personal data not to be carried out, or for such processing by Lead2Team to cease.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualised decision based solely on the automated processing of their personal data, including profiling, which exists unless the applicable legislation establishes otherwise.

Accordingly, the User may exercise their rights by means of a written communication addressed to the Controller with the reference “GDPR”, specifying:

• The User's name and surname(s) and a copy of their national identity document (DNI). In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document evidencing the representation. The photocopy of the DNI may be replaced by any other legally valid means that proves identity.
• The request setting out the specific reasons for the application or the information to which access is sought.
• Address for the purpose of notifications.
• Date and signature of the applicant.
• Any document evidencing the request being made.

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

Postal address:

Mediagach, S.L.
Calle de Francesc Layret, 119, 5º, 1ª
08911 Badalona (Barcelona)
Spain

Email: [email protected]

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Lead2Team, and which are therefore not operated by Lead2Team. 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 before the supervisory authority

In the event that the User considers that there is a problem or infringement of the applicable regulations in the way in which their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint before 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 (http://www.agpd.es).

III. 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 and Cookies Policy, and that they accept the processing of their personal data so that the Controller may proceed with it in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy and Cookies Policy.

Lead2Team reserves the right to modify its Privacy and Cookies Policy, in accordance with its own criteria, or prompted by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookies Policy will be explicitly notified to the User. This Privacy and Cookies Policy was updated on 24 April 2020 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 the guarantee of digital rights.