PRIVACY POLICY AND DATA PROTECTION.

1. INTRODUCTION

The Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs reserves the right to modify this Policy in order to adapt it to legislative developments, judicial criteria, industry practices, or the interests of the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs. Any modifications will be announced in advance to ensure you are fully aware of their content.

To provide certain services, it is necessary to manage your personal data. To this end, such data will be incorporated into the corresponding processing activities of the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs and will be processed for the specific purpose of each treatment, in accordance primarily with the regulations established by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation), and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

2. GENERAL INFORMATION

Below, the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs provides general information about the safeguarding of privacy and the protection of personal data applied to the processing activities it carries out at the web level, as well as through other means:

2.1. Who is responsible for processing your personal data?

Net Positive Labs, with its registered office for these purposes at 85 Great Portland Street, First Floor, London, England.

For data protection, please contact: juliana@netpositivelabs.com

2.2. For what purposes do we process your personal data?

The purpose of collecting and processing personal data through the various forms owned by the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs, made available to Users, is, depending on the specific case, to manage and respond to requests for information, doubts, complaints, congratulations, or suggestions regarding publications or any services or activities, acts, or events provided, offered, sponsored, and/or endorsed by the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs.

2.3. What is the legal basis that legitimizes the processing of your personal data? In other words, what justifies or enables us to process your personal data?

The legal basis that legitimizes us to process your personal data is as follows: (i) the consent granted by you through the signing or acceptance of the relevant forms, for one or more specific purposes, (ii) where applicable, the execution of a contract to which you are a party, as a contractor or awardee, (iii) and compliance with a legal obligation, or the exercise of public functions or competencies.

2.4. How long do we keep your personal data?

We will retain your personal data for the period necessary to maintain a service history and manage our services efficiently, provided the data subject does not request its deletion. Even if deletion is requested, the data will remain blocked for the necessary time, limiting its processing solely to the following cases: to comply with legal/contractual obligations of any kind to which we are subject and/or during the legal periods provided for the prescription of any liabilities on our part and/or the exercise or defense of claims arising from the relationship maintained with the data subject.

2.5. Who is responsible for keeping the data updated?

Furthermore, to ensure that the data in our files, whether electronic and/or on paper, always correspond to reality, efforts will be made to keep them updated. To this end, the User must make changes directly when enabled to do so or communicate them, through reliable means, to the corresponding area or department of Net Positive Labs.

2.6. Who may be assignees or recipients of your personal data?

Personal data will not be transferred or communicated to third parties, except in cases necessary for the development, control, and fulfillment of the expressed purpose(s), in the cases provided by law.

2.7. Security of personal data

The Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs will adopt appropriate technical and organizational measures in its information system, in accordance with Royal Decree 3/2010, of January 8, which regulates the National Security Scheme in the field of Electronic Administration, complying with the principle of proactive responsibility, to ensure the security and confidentiality of stored data, thus preventing their alteration, loss, unauthorized processing, or access; considering the state of technology, implementation costs, and the nature, scope, context, and purposes of processing, as well as risks of varying probability and severity associated with each processing.

2.8. What are your data protection rights and how can you exercise them?

To exercise the rights of Access, Rectification, Deletion, Limitation, Portability, or, where appropriate, Opposition, you can submit a request by writing to: 85 Great Portland Street, First Floor, London, England. London, W1W 7LT, or to our Data Protection Officer: juliana@netpositivelabs.com. The written request must specify which of these rights you wish to be satisfied and, in turn, you must show or, in the case of postal submission, accompany a photocopy of your ID card or equivalent identification document. If acting through a representative, legal or voluntary, you must also provide a document accrediting the representation and the representative's identification document. Additionally, if you consider your right to personal data protection has been violated, you can file a complaint with our Data Protection Officer (juliana@netpositivelabs.com), or with the Spanish Data Protection Agency (www.aepd.es).

Below is more information about exercising your data protection rights:

a) What are my rights?

b) Who can exercise these rights before the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana?

c) How and where can I exercise these rights?

d) Additional information

a) What are my rights?

Data protection regulations allow you to exercise before the data controller, the Fundación and Net Positive Labs, the rights of access, rectification, opposition, portability, deletion ("right to be forgotten"), limitation of processing, and not to be subject to individualized decisions, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter "GDPR") and Organic Law 3/2018 of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD):

Right of access

You have the right to know:

• Whether or not we are processing personal data concerning you.

• The origin of your data, if you did not provide it to us.

• The purposes of processing your data.

• The categories of data concerned.

• The recipients or categories of recipients to whom the personal data have been or will be disclosed.

• If possible, the envisaged period for which the personal data will be stored (or, if not possible, the criteria used to determine this period).

• The right to lodge a complaint with a supervisory authority.

• Whether we make automated decisions—including profiling—using your personal data.

Right to rectification

You have the right to have your personal data rectified:

• By completing them, if they are incomplete.

• By updating or correcting them, if for any reason they are no longer accurate or are incorrect.

By exercising the right to rectification, we will ensure that all your personal data are accurate and complete.

Right to Erasure (Right to be Forgotten)

You have the right to have your personal data erased when any of the following conditions apply:

• The data are no longer necessary for the purposes for which they were collected or processed.​

• You withdraw the consent on which the processing is based, and there is no other legal ground for the processing.​

• You have successfully exercised the right to object to the processing of your data.​

• The personal data have been unlawfully processed.​

Right to Restriction of Processing

You have the right to obtain the restriction of processing of your personal data, meaning we will keep them without using them for the intended purposes.​

Right to Object

You have the right to request that we stop using your personal data, for example, when you believe the personal data we have about you may be incorrect or you believe we no longer need to use them.​

Right to Data Portability

When the processing of your data is based on consent or is necessary for the execution of a contract or pre-contract and is carried out by automated means, you have the right to data portability, that is, to receive them in a structured, commonly used, and machine-readable format, and even to transmit them to a new controller. Therefore, the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs will facilitate the portability of your data to the new controller.​

b) Who can exercise these rights before the Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana?

• You, as the data subject or owner of the personal data, acting on your own behalf.​

• Through another person acting, duly accredited, as a legal representative (e.g., when holders of parental authority or guardianship act on behalf of a person under 14 years of age or when acting as a legal representative of a person with functional diversity) or voluntary representative (a person to whom you have freely and voluntarily granted powers of representation for these purposes).​

c) How and where can I exercise these rights?

By Postal Mail

You can submit the written request to the following postal address:​

85 Great Portland Street, First Floor, London, England.​

By Internet

You can submit the written request by sending an email to the following address:​

juliana@netpositivelabs.com​

In both cases, you must:

• Provide sufficient data and information to process the request. For this purpose, you may use the form templates provided by the Spanish Data Protection Agency:​

  https://www.aepd.es/es/derechos-y-deberes/conoce-tus-derechos​

• Sign the form either by hand or, if you have a recognized digital certificate, sign it electronically.​

• Attach a photocopy of your ID card, passport, NIE, or other equivalent identification document. If acting on behalf of a third party, you must also include a copy of their ID or equivalent identification document, as well as the document accrediting the representation of the data subject.​

• Send the form and supporting documents of your identity by any of the aforementioned means.​

d) Additional Information

The Fundación de la Comunidad Valenciana para la Promoción Estratégica, el Desarrollo y la Innovación Urbana and Net Positive Labs will analyze whether the request is legally valid. It will inform the requester of the decision made, proceeding accordingly: if the request is upheld, it will take appropriate measures according to the exercised right; if denied, it will indicate the legally provided appeal system.​

In cases where requests are manifestly unfounded or excessive (e.g., repetitive in nature), the Fundación may:​

• Charge a fee proportional to the administrative costs incurred.​

• Refuse to act.​

For more information or clarification about your personal data protection rights, you can send a written request to the following email address:

juliana@netpositivelabs.com​

3. ADDITIONAL DATA PROTECTION INFORMATION

3.1. Suppliers

The personal data of the contract signatory, as well as of the individuals who participate or are in contact during the provision of the service, will be processed by the Fundación and Net Positive Labs as the Data Controller.​

The legal basis that legitimizes the processing of the data is the contractual relationship, for its formalization and execution.​

The purpose of the processing is to maintain the contractual relationship, in the derived economic and technical aspects, as well as the development and control of the contracted service(s) and, where appropriate, the sending of information about incidents related to them.​

The data will be retained for the time necessary to fulfill the purpose for which they were collected and to determine possible liabilities that may arise from that purpose and the processing of the data, and may be required by the competent public authorities (Tax Agency, Courts, or Tribunals).​

The data will not be transferred to third parties, unless they are communicated to public or private entities to which it is necessary or mandatory to transfer them to manage the contractual relationship, as well as in the cases provided by law.​

3.2. Social Networks

The Fundación and Net Positive Labs has various profiles on social networks to publicize its activities and interact with users.​

Users of these social networks who voluntarily decide to follow or become friends with the Fundación and Net Positive Labs express their consent for the processing of their personal data related to their profile to interact on the social network.​

The Fundación and Net Positive Labs do not collect data from social networks for purposes other than those mentioned.​

The use of social networks entails an international data transfer for the provision of the service. This communication is carried out based on the adoption by the social network of standard contractual clauses, in accordance with Decision 2010/87 of the European Commission.​

You can unfollow or unfriend the Fundación and Net Positive Labs at any time.​

Users must respect the rights of third parties, especially privacy and data protection rights, as well as intellectual and industrial property regulations, in all information they publish on the Fundación's and Net Positive Labs page.

The publication of information that in any way violates morality, public order, fundamental rights, public freedoms — with special attention to honor, privacy, or the image of third parties — and, in general, human rights, is prohibited.

The user will be solely responsible for the information published.

We recommend reviewing the privacy settings of the social network. Below are links to the different privacy policies:

• Twitter: https://twitter.com/en/privacy

• Facebook: https://en-gb.facebook.com/privacy/explanation

• Instagram: https://help.instagram.com/519522125107875

3.3. Email

The personal data processed as a result of receiving and/or exchanging emails will be processed for the purpose of addressing and responding to your request for information or inquiry, maintaining commercial or professional contacts and relationships that arise as a result, or for maintaining, where appropriate, a contractual relationship.

3.4. Electronic Bulletin or Newsletter

Furthermore, if you expressly authorize it through the appropriate checkbox or by express request, we will keep you informed about our activities.

Consent to process your personal data and its subsequent use for sending newsletters can be revoked at any time.

A link for this purpose will be included at the bottom of each newsletter.

You can also unsubscribe at any time or send us your request through the contact options specified at the end of this document.