PRIVACY POLICY.

As part of Azol Gas’ commitment to transparency, and being aware of the importance of privacy and security, in accordance with the applicable data protection Law and regulations, we inform you about the following:

Because we gather certain types of information about Users, we want you to understand (i) who is responsible for the processing of User’s data, (ii) what data is treated, for what purpose and which is the legal basis for its processing, (iii) how long do we keep User’s data, (iv) who has access to your data , (v) what rights do Users have  and (vi) what security measures are in place.

We highly recommend that you read this Privacy Policy and that you contact us if you have any doubt.

Who is responsable for the processing of your data in this Website?

The information provided by the User through any of the forms or methods of contact made available on this Website, which may content personal data, will be processed by:

• Data Controller:  AZOL GAS, S.L.U.
• ID number: B-01316801
• Address: Vitoria-Gasteiz, Polígono Industrial Júndiz, calle Landaluzea 7
• Email: lopd@azolgas.com

User may contact Grupo Azol Gas through this email in case of any doubt or need regarding data protection.

Take into account that, when personal data is provided through the Ethics Line, made available on the Website (see Claim Form), the following shall be deemed to be joint Controllers:

• The Company within Azol Gas Group involved in an employment, business or professional relationship with the Party concerned and/or with the Reported Party, and
• GRUPO EQUIPAMIENTO AUXILIAR AZOL GAS, S.L., being the parent Company of the Group, wherein the Committee of Ethics is included as a compliance oversight body.

What kind of data can be gathered on this Website and for what purpose?

Through this Website the following personal data can be collected:

• Through the Contact Form, where Users can make all kinds of enquiries and request information, identification data (name, surname, Company name) and contact data (telephone, email), as well as any other data provided by the User will be collected. This data will be exclusively treated, in order to manage User’s request for contact/information based on legitimate interest of Azol Gas in attending to such requests.
  
  Through the Claim Form of our Ethics Line,  where Users can report any perceived breach of the Code of Ethics and/or other internal policies and conduct rules, the following personal data can be gathered: Identification data (such as, name and surname, contact data), any data regarding the employee condition (of the  Party concerned and/or the  Reported Party; relationship with the company (for instance, position in the Company); other data with regard to the reported breaches, acts or omissions.
  
  This data will be used in order to answer any doubt or queries made, and so as to detect, investigate and/or legally assess any report of perceived breach of any laws and regulations, the obligations of a contract, as well as any breach of the Code of Ethics and/or any internal policies of Azol Gas Group.
  
  The legal basis for the processing of this personal data will be, in some cases, the existence of a public interest to prevent and act in the event of violation of applicable laws, and in others, the Company’s legitimate interest in attending, preventing and prosecuting actions contravening applicable legislation and/or internal regulations.
• Cookies.- While using this Website, AZOL GAS saves information on the User  through session cookies (type of Internet browser used, your computer operating system and the IP address), in order to improve navigation, to ensure the proper operation and effective management of the Website, based on  de AZOL GAS’ lawful interest. Additionally, other cookies are used (Google Analytics), based on User’s consent when accepting Cookies Policy.  For more information about cookies, see our Cookies Policy.

How long will we keep your data?

The personal data provided by users will be kept for the time necessary to effectively fulfil the purposes indicated above.

Once the purpose has been achieved, the personal data collected shall be kept for the following periods:

• Data in Contact Form: 1 year.
• Personal data obtained through the Ethics’ Line Claim Form, will be kept according to applicable legislation and no longer than necessary for the purposes stated above. Namely, data will be stored for as long as it is necessary to decide on whether or not the facts reported should be investigated. Such period may extend for three months at most, from the registration of the Claim. However, should personal data need to be processed for a longer period, in order to continue the investigation, or because a decision has been made to take legal action, data will be stored in a different area outside the Ethics Line, should this be necessary to complete the investigation or for Azol Gas to bring the relevant court proceedings.
• As for the conservation of information regarding navigation data Cookies Policy.

Who may have Access to your personal data?

Azol Gas may give access to personal data gathered in this Website, to fulfil the processing purposes above referred to other companies of Azol Gas Group.

Service providers, such as external advisors and collaborators who provide support with the handling and maintenance of our systems, applications and computer programs, may also have access to data, in order to ensure their security, development or maintenance. Please note that strict confidentiality and secrecy agreements have been concluded with these service providers.

Likewise, with regard to data obtained through the Ethic’s Line Azol Gas may also give access to (i) service providers, such as external advisors and collaborators who provide support with the handling or, as the case may be, the investigation of the Claims received through  the Ethics Line, and (ii) where action needs to be taken as a result of the investigation, the relevant areas/departments/entities of the Azol Gas Group, which will be involved in the investigation and the potential action to be taken regarding the reported behavior , and  (iii) judges, law courts, the Office of the Public Prosecutor or competent public administrations, as a result of the investigation which may be launched.

Is data transferred outside the EU?

No. We do not transfer data outside the EU.

What are your rights?

At any time, users may exercise the following rights recognized by current data protection regulation:

• Users are entitled to know which data are being processed and the processing operations that are being performed with that data- Right of access. In the event of data. With regard to data of the reported person within a Claim of the Ethics Line, the access right of the that Party will be limited to that its own personal data, and in no event to the data of the concerned party that made the corresponding claim.
• Users have the right to obtain from Azol Gas the rectification of inaccurate, incorrect or incomplete personal data – Right to rectification.
• Users may request the erasure of their personal data, provided there is no legal basis for its processing and that they are no longer necessary for the purposes stated – Right to erasure.
• Users have the right to obtain the restriction of the processing of its personal data from Azol Gas, in certain circumstances (doubts about accuracy and legality for instance), except in those cases envisaged by the applicable data protection regulation.– Right to restriction to processing.
• Users may request that their personal data are no longer processed by objecting the lawful interest of AZOL GAS, except when Azol Gas have a compelling legitimate interest.– Right to object.
• Users will also have the right to withdraw their consent at any time

If you have any queries regarding your data, or you wish to exercise your rights , we need you to send us a written notification  by post to the address stated above or an email to lopd@azolgas.com with the following content: (i) specify your request or query, (ii) attach a copy of your ID or passport, in order to check your identity and (iii) include the following data: Name, surname y contact address so that we can send you receipt confirmation as well as our answer or execution of any right exercised. If you are not satisfied with the solution found, you are also entitled to lodge a complaint with the Data Protection Agency.

AZOL GAS reserves the right to modify this Privacy Policy, at any time, always in accordance with applicable Spanish legislation. Any modification will be communicated to Users, either by publication in this Website or by any other means of communication or dissemination in its sole discretion.

What security measures are implementd?

Azol Gas is committed to fulfilling its obligation of secrecy of personal data and its duty to keep them confidential,

Therefore, Azol Gas has implemented the security measures of technical and organizational nature necessary to ensure the security of your personal data and prevent their alteration, loss and treatment and/or unauthorized access, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed.

Likewise, Azol Gas is concerned about privacy, in order to strengthen the confidentiality and integrity of information in their organization, continuously maintains the supervision, control and evaluation of their processes to ensure respect for privacy and security of information.