PRIVACY AND COOKIES POLICY

This Privacy and Cookies Policy contains information on the manner in which PASABAN, S.A. (“Pasaban”) processes the personal data of the users who use the services available on the website www.pasaban.com (“Website”) and is intended to help you understand in a clear and simple manner what kind of information we gather, what we use it for, how we protect it and what are your rights.

WHAT DATA DO WE GATHER AND WHAT FOR?

In general, you do not need to give us any personal data for browsing through the website and referring to the information available on it. However, depending on the use you make of our services, we need you to give us certain information or we shall obtain certain information from the use you make of the Website. In general, we process your data to attend to your requests and queries, process the orders you place or send you the information you asked for.

Data you give us:When you subscribe to our newsletter, register yourself to place an order in our online store or fill in the contact form to ask us a question or request information, you voluntarily provide us with certain data. Pasaban shall only ask for the data required in each case and shall specify on the form itself those that are compulsory. These data may simply consist in your name, company and email address – when you subscribe to our newsletter – or other identifying and additional contact data such as email, password, company information, telephone number, shipping and billing address – when you create an account to place an order in our online store –. The use we make of your data shall depend on the purpose for which you facilitated them in each case or the use you may make of our services:

• When you create an account to place an order in our online store, we shall process your data to register yourself in our system, properly process your orders, manage your delivery through shipping agencies and process the payment of the order. We may also use your contact data to send you informative messages by email about your orders, as well as purchase confirmations or information on the status of the order.

  When you pay for the order through the payment gateway available in the online store, your payment data shall be processed securely by the financial institutions that manage these payment systems. If you decide to pay for your purchases by bank transfer, we shall use that information to verify that the order has been paid and initiate its management process, as well as to resolve any incident that may occur (undue charges or refunds, if applicable).

  Once you have created your account, we shall process your data so that you can place orders through your account without you having to register yourself each time and you may easily access your purchase history or consult the discount vouchers you may have obtained. We shall also process these data for the administrative management of our customers and for billing purposes, to provide you with after sales services or technical assistance when you ask us for it, as well as to attend to any incidence that may be covered by our guarantee.

• When you contact us, we shall use you data to properly attend to your requests, contact you to respond to your queries or send you any information you may ask us for. If you contact us to initiate any kind of commercial relationship, place an order or request technical assistance, we shall use the data you provide us to initiate and manage said relationship under the terms required in each case. If you acquire any of our products through this medium, we shall process your data in a similar manner to that explained in the previous section, in order to properly manage the order and for administrative and billing purposes.

• When you subscribe to our newsletter or ask to receive information on our activities, products and services, we shall use you contact data to keep you informed about novelties or activities relating to Pasaban and to regularly send you information about our products and services to the email address you have given us. We shall solely use your data for these purposes when you have given your consent by marking the checkbox specifically provided for the purpose when you register or contact us or when you have expressly so requested in another manner. Moreover, at any time you may cease to receive this type of messages by clicking on the option provided for this purpose on all our messages or by sending an email message to info@pasaban.com. This shall not preclude that if you are a registered user and make any purchase in our online store, you may continue to receive informative (non-commercial) notifications, referring to the orders you place.

Technical information and cookies: Every time you access a website or make use of Internet services, there are some technical data that are created and collected automatically. The same happens when you use this website. This information may include technical information about your computer or the configuration of your browser, such as the IP address, the device type, the browser or the operating system that you use or the access date to your account. This type of data is used to manage and forestall the security of our information systems, prevent unauthorized access to user accounts and to perform operating and diagnostics tests of incidents on the website. The cookies are small text files that are generated on your computer or device every time you visit a website or browse the Internet. The cookies may be of different kinds and fulfil different functions. You can always block, manage and remove cookies using the appropriate settings configuration on your browser. For further information, review our Cookies Policy further on.

WHY AND FOR HOW LONG DO WE PROCESS YOUR INFORMATION?

The legitimation for the processing of your personal data depends on the purpose for which you have facilitated us your personal data.

• If you make a purchase of our products, request our services or initiate a commercial relationship with us, the legal basis for the processing of your data in the execution of the contract. In these cases we shall use your data for the execution and the undertaking of the contractual relationship (ship you the order, provide you after sales services or technical assistance, manage incidents covered by our guarantee or for administrative management and billing purposes).

• If you have authorised or requested the receipt of our commercial messages, the legitimation for the processing of your data is based on the consent that you give us when you click on the checkbox to receive our corporate and commercial information or when you press on the “subscribe” button in our newsletter. In this case, you may withdraw your consent easily and at any time using the messages we send you, as already explained above. The withdrawal of your consent shall not affect the legality of the processing based on your prior consent, although as from when we have evidence of the withdrawal, we shall stop sending you messages of this kind until you request them from us once again, at your choice.

• We may also process the data for other legitimate purposes relating to our business activities (for example, to properly manage our internal administrative and operative procedures; to improve our support services and customer service; forestall the website's security and carry out maintenance tasks on our information systems; perform diagnostics of the use of our website in order to optimise and improve our online services) or when necessary in order to attend to our legal obligations (issue of invoices and payment of taxes, for example).

We shall only process your information for as long as we need it to provide our services to you and fulfil our contractual obligations under the terms described in this Privacy Policy or to comply with the legal obligations we are subject to in each case, until said obligations or legal liabilities have elapsed. When we no longer need to use your information, we shall delete it from our systems or shall keep it properly blocked as required by legislation insofar as we need to retain it to meet our legal obligations. If you have a user account and as long as you have no orders in progress, you may cancel it at any time from the personal area of your account or by sending an email to info@pasaban.com.

IN WHICH CASES IS THIS INFORMATION SHARED?

Pasaban does not sell the personal data of its customers or that of the users of the website. Personal data shall not be forwarded without the consent of the person concerned, except in the cases in which it is legally authorised to do so or when it is essential for the performance of our contractual obligations (for example, when you make a purchase of our products we need to share certain information with the shipping agency to send you order to the address you have given us). Insofar as is necessary, we may share information on a one-off base when it is required to comply with our legal or regulatory obligations, in response to the official summons of public authorities or when we eventually participate in processes of mergers, business restructuring or similar corporate transactions and it is necessary in the context of the good outcome of the transaction.

Pasaban may sometimes need to resort to outside suppliers who may potentially have limited access to personal information, for example, to provide us with hosting and IT maintenance services, email marketing services or for performing independent audits. In such cases, our suppliers shall process the data on our behalf and following our instructions, only for the purpose of properly providing their services and with the appropriate confidentiality safeguards.

Occasionally, our outside suppliers may be located outside the European Economic Area (“EEA”). Some non-EEA countries do not always have safeguards equivalent to those of the European Union. Therefore, in these cases we adopt additional measures and resort to suppliers located in countries or adhering to standards (such as the “Privacy Shield” agreement between USA-EU) with respect to which the European Authorities have declared that they offer safeguards equivalent to those of the European Union, such as is the case of email marketing services supplier “MailChimp”, an American company whose adherence to these standards you can verify here https://mailchimp.com/legal/privacy/. We also use specimen contractual clauses approved by the European Authorities to regulate the way in which this kind of suppliers use the information.

HOW WE PROTECT YOUR INFORMATION?

Pasaban adopts reasonable technical and organisational measures according to industry standards to provide protection and security of the user information against loss, misuse, unauthorised access, disclosure or alteration. These security measures include data encryption, firewalls and the access controls to our corporate information. At Pasaban we ensure the security of our users' information; therefore, our online store available through the website SSL (https) certificates to ensure more secure browsing using our online store. The SSL certificates ensure the secure transmission of information over the Internet, as the transmission of data between the server and the web user occurs in an encrypted manner. Although Pasaban strives to maintain the security of its systems, it is the responsibility of each registered user to maintain the security of their passwords and of the information of their account and device against possible unauthorised use by third parties.

USER OBLIGATIONS

Users are responsible for the truthfulness, legality and accuracy of the personal data facilitated and commit themselves to keep them updated. You must not facilitate the personal data of third parties to Pasaban and if for any reason this were the case, you must previously have informed them and have obtained their consent with regards to the matters set out in this Privacy and Cookies Policy. This website is intended for people 18 years of age and older. By their registration on the website, the users guarantee that they are of legal age and assume that Pasaban reserves itself the right to prevent the registration or delete the account of any user who does not meet this requirement or does not duly accredit it properly if required to do so.

USER RIGHTS

The users may exercise at any time and free of charge the rights conferred to them by current legislation. These rights include the following possibilities:

• Request access to your personal data, in other word, you have the right to know what personal data we have about you.

• Update your data or rectify them if they are inaccurate. If you have a user account, you can do so directly from the personal area of your account; otherwise, you may do so by contacting us.

• Oppose yourself to our processing your information for certain purposes. We shall only send you commercial messages if you have previously accepted or requested this and you may withdraw your consent easily and at any time by clicking on the option we include for that purpose on all of our messages or by sending us an email.

• Request their removal when the data are no longer needed for the purposes for which they were gathered (if you have an account on the website, you may cancel it at any time from the personal area of your account), as well as to request the portability of the information you have facilitated us to another organisation, if technically feasible.

• To file a claim, if you deem that the applicable regulations have been breached, with the Spanish Data Protection Agency (c/ Jorge Juan 6, 28001 Madrid) or with the local data protection authority of your country.

To exercise these rights, you must contact Pasaban accrediting your identity and providing details of your request, either via our postal address or by using our contact email. Below, we provide you with the identifying and contact information of the person responsible for the processing of your data: PASABAN, S.A. / Auzo Txikia, 17 - Apartado 53, 20400 Tolosa (Guipúzcoa-Spain) / info@pasaban.com.

MODIFICATION

We may modify this Privacy and Cookies Policy to adapt it to future regulatory changes, as a result of changes in the nature of the services available on the website or in the event that we change the way in which we process the information. In this case, we shall post said changes on this website. If the changes are significant, we will notify the changes more prominently or we will inform you by email. The fact of actively continuing to use the website after the entry into force of said changes implies the acceptance of the modification made to this Privacy Policy.

INFORMATION ABOUT COOKIES

What are cookies?

Cookies are small text files that are generated in the user's computer and that store the information generated by their activity on the Internet. Some are strictly necessary for a website to work properly (technical cookies) and others are used to improve performance and the user experience. The cookies may be of different kinds and fulfil different functions. Among other things, cookies allow for recalling language preferences or other configuration options so that it is unnecessary to modify them manually every time one visits a website; facilitate browsing and thus enable optimising and customising the website's display and for example provide contents that are better adapted to the user's interests and browsing habits; access to restricted areas, services or functionalities without having to register oneself for each visit; or measure the website's traffic and prepare aggregated statistics of usage and browsing.

What types of cookies are there and what are they used for?

By the purpose they fulfil, the following types of cookies can be distinguished:

Technical cookies: Are those that allow the user to browse through a webpage, platform or application and use the different options or services on it, such as for example, to control the traffic and data communication, to identify the user's session, to access restricted access areas, to recall the elements of their last visit, to use security elements during browsing, to store content for the broadcasting of videos or to share content through social networks.

Customisation cookies: Are those that allow the user to access the service with certain predefined general features based on a series of criteria from the user's terminal, such as for example, the language, the kind of browser through which the service is being accessed, the regional configuration from where the service is being accessed, etc.

Analytical cookies: Are those that, either being processed by the webpage's owner or by third parties, allow for quantifying the number of visits to the website and thus perform the statistical measurement and analysis of the usage made by users of the website's services, in order to make improvements based on the analysis of the service's user usage data.

Advertising cookies: Are those that, either being processed by the webpage's owner or by third parties, allow for managing in the most effective manner possible the offering of the advertising spaces on a website, bases on criteria such as the edited content or the frequency in which the ads are displayed.

Behavioural advertising cookies: Are those that allow the management, in the most effective manner possible, of the ad spaces that, if applicable, the editor may have included in a webpage, application or platform from which the requested service is provided. These cookies store the users' behavioural information, which is obtained through the ongoing observation of their browsing habits, which allows for a specific profile to be set up to display advertising based on it.

Depending on the time frame for which they remain active, one can distinguish between two cookie types:

Session cookies: Are a type of cookie that is temporarily downloaded while the user accesses and makes use of a website, to allow them to browse from one page to another with greater effectiveness or to recall the selected settings preferences (for example, to recall a list of acquired products in the shopping cart). In general, these cookies are eliminated when the browser is closed.

Persisteng cookies: These are a type of cookies that continues to be stored on the terminal after the browsing of a website has ended for a period defined by the entity responsible for the cookie, which can range from a few minutes to several years. Generally, these cookies remain until the user or the browser eliminates them and they can be used to help websites recall that you have already visited them earlier or to ensure that the displayed ads are orientated towards your browsing habits.

What cookies are used on this website?

Cookies in pasaban.com and in parts.pasaban.com

• Cookie settings: Settings

Cookies in parts.pasaban.com

These are the visible cookies. Moreover, Google may use certain complementary cookies if the user keeps a session active in Google. More information about the types of cookies Google uses: https://policies.google.com/technologies/types

This website uses Google Analytics, an analytical web service provided by Google Inc. domiciled in the United States, with its head offices at 1600 Amphitheatre Parkway, Mountain View, California 94043. For providing these services, Google uses cookies that gather information, including the IP address of the user's device, which shall be processed and stored by Google under the terms set out in Google's Privacy Policy available at https://policies.google.com/privacy?hl=us, including the possible transmission of said information to third parties due to legal requirements or when said third parties process the information on Google's behalf. By means of this service, information is gathered to measure, with analytical purposes and in an aggregate manner, the traffic and use of the website in order to optimise its functionalities and services and improve the users' browsing experience.

What options do I have over cookies?

At any time you may allow, block or eliminate the cookies installed in your computer by using the settings options of your browser, although we warn you that disabling or blocking some cookies may affect the proper operation of the website or worsen the user experience during browsing. To facilitate access to these options, we offer you the following information with instructions on how to remove and manage cookies in some of the most common browsers:

• Internet Explorer: Tools -> Internet Options -> Privacy -> Settings. For further information, you may refer to Microsoft support or the browser's Help.

• Firefox: Tools -> Options -> Privacy & Security -> History -> Use custom settings for history. For further information, you may refer to Mozilla support or the browser's Help.

• Chrome: Settings -> Advanced -> Privacy and security -> Content settings. For further information, you may refer to Google support or the browser's Help.

• Safari: Preferences -> Security. For further information, you may refer to Apple support or the browser's Help.

You can also install the Google Analytics Opt-out Add-on tool in your browser, which prevents Google Analytics from gathering information on your visits to websites that use this service. If you want further information about the Google Analytics Opt-out Add-on tool, you can find it at https://support.google.com/analytics/answer/181881?hl=us&ref_topic=2919631 and if you want further information about privacy matters relating to the Google Analytics service, you can find it at https://support.google.com/analytics/topic/2919631?hl=us&ref_topic=1008008