Introduction
This Privacy Statement, effective as of September 1st, provides information on the collection, use, sharing and processing of personal information by AZLYC (see foot-note 1)  (“AZLYC”, “we” or “us”) in connection with your use of AZLYC websites, mobile applications, and social media pages that link to this Privacy Statement, your interactions with AZLYC during in-person meetings or at AZLYC events, and in the context of other offline sales and marketing activities. It sets out the purposes of AZLYC’s data processing in respect of our web site, the use of cookies and your rights in respect of your personal data. AZLYC recommends that you read this Privacy Statement prior to using the AZLYC website.

AZLYC may collect personal data about you, either directly (where you are asked to provide the data) from our online and offline interactions with you, during events, or email or telephone correspondence, from your interactions with our sites or indirectly through third-party data providers. AZLYC will, however, only use these personal data in accordance with the purposes set forth in this Privacy Statement and is committed to safeguarding the personal information collected.

Purposes of processing
AZLYC collects and processes your personal information to conduct its business, to inform and make available products and services that may be of interest to you and for the development of web statistics. The information you provide will be used to contact you when necessary, e.g. to notify you about functionality changes to the web site and to offer services that you may find helpful (provided you have not opted out to receive such services); to respond to your requests; to deliver functionality on our sites; to administer our subscriptions; to market and tailor services to your or your company’s interests; to develop, improve the performance of, and secure our sites, services; and to comply with applicable laws such as to comply with an opt-out request.

Who will use the personal data?
AZLYC will be responsible for the use of the personal data in respect of the AZLYC website.
If AZLYC uses the services of firms with which it has a strategic alliance and/or other service providers, including service providers, and public, government, judicial and law enforcement entities, AZLYC – where necessary – will also provide your personal data to those other firms and/or service providers.

Other than as described above, AZLYC will not sell, distribute or make available your personal data to third parties outside of its own organisation without your prior consent, unless obliged to do so under law, codes of conduct and professional practice or a court order.

What data will be used?
AZLYC can process information about you collected both offline and online.
• Offline information about you originates from our interactions with you during in-person meetings or at AZLYC events, conferences, workshops or gatherings;
• Online information about you originates from your activities on our sites, for example, in relation with your AZLYC accounts, inquiries or from your interactions with AZLYC via electronic communication tools such as email or telephone. Information about you may also be provided by third party sources, such as data aggregators who may not have a relationship with you. Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties.

If you make inquiries, ask questions, make comments, apply for a position and/or make use of other services through the AZLYC website (hereinafter to be referred to jointly as ‘the Services’), you may be required to provide certain personal data and/or you may provide this data on your own initiative. AZLYC will use this data for the purpose of:
• making the AZLYC website available to its users;
• making available to you and providing you with the Services offered on AZLYC website;
• optimising AZLYC’ Services, whether provided via the AZLYC website or otherwise.
If you have submitted questions and/or comments by e-mail and/or requested other Services through the AZLYC website, AZLYC may use your personal data to contact you for the purpose of responding to those questions and/or comments and providing those Services.
Information about you that AZLYC may collect and process includes:
• name and physical address, email addresses, and telephone numbers;
• photographs and testimonials;
• transactional data, including services ordered, financial details and payment methods;
• company data such as the name, size and location of the company you work for and your role within the company;
• data from surveys and publicly available information, such as social media posts;
• unique IDs such as your mobile device identifier or cookie ID on your browser;
• IP address and information that may be derived from IP address, such as geographic location;
• information about a device you use, such as browser, device type, operating system, the presence or use of "apps", screen resolution, and the preferred language;
• behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.

AZLYC will not retain your personal data longer than is necessary for the purposes described above, unless this data is necessary for complying with a statutory retention obligation, or (if longer) after the retention period under the applicable code of conduct and professional practice has expired. After expiry of the retention periods, your Personal Data will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.


Legal basis
For personal information collected about you in the EEA, our basis for processing is the following:
• In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
• In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
• We process personal information for marketing and sales activities based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
• We rely on our legitimate interest to analyse, develop, improve and optimize our sites, products and services, and to maintain the security of our sites, networks and systems.
• In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

Sensitive data
AZLYC does not seek to collect sensitive personal data (such as data revealing political opinions, religious beliefs or data concerning health or sex life) through this site. If AZLYC does seek to collect such data, your prior consent hereto will be asked. Please note that, by providing AZLYC with unsolicited sensitive personal data you consent to our using those data as described above.
Security
AZLYC has put appropriate technical and organisational measures in place in order to safeguard your personal data against loss or any form of unlawful use. Those persons who, on behalf of AZLYC, have access to your personal data, have a confidentiality obligation.

Your rights
You have certain rights regarding your personal data, subject to local data protection laws. These may include the following rights:
• to access your personal data held by us (right to access);
• to rectify inaccurate personal data and ensure it is complete (right to rectification);
• to erase/delete your personal data to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
• to restrict our processing of your personal data (right to restriction of processing);
• to transfer your personal data to another controller to the extent possible (right to data portability);
• to object to any processing of your personal data carried out on the basis of our legitimate interests (right to object). Where we process your personal data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); Automated Decision-Making currently does not take place on our websites;
• to the extent we base the collection, processing and sharing of your personal data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
To exercise your rights, please contact enrique@aznar.co. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you.
If you believe that AZLYC is not processing your personal data in accordance with the requirements set out in this Statement or applicable European Economic Area (EEA) data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which AZLYC has its registered seat.

Cookies and log files
AZLYC may gather and analyze information regarding usage of this web site, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using a cookie. A cookie is a small unit of information which can be passed to your browser and placed on your hard drive while you are on the AZLYC website. You can choose to deactivate the use of cookies by altering the settings of your browser. If you have deactivated the cookies, it might have consequences for the ease of use of the AZLYC website. The AZLYC website automatically generates log files that register the use by you and other users of the AZLYC website. AZLYC maintains user data, such as source addresses of pages requested, IP (internet protocol) addresses and domain names, dates and times of page requests, links from other websites and other parameters in the URLs (universal resource locators). These log files and data will be used, on an anonymous basis, for statistical purposes and for improving the Services offered via the AZLYC website.
Third party vendors, including Google, show our ads on sites on the internet. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to our website. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

Third party sites
Please note that this Privacy Statement does not extend to third party sites linked to this web site. AZLYC may include links to third party websites and these third parties or other parties present on these websites may gather information about you. AZLYC will not be responsible for the content of these websites or the actions of these third parties and other parties present on these websites. AZLYC recommends that you read their policies on the use of personal data.

Trademarks
AZLYC and AZNAR LEGAL & COMPLIANCE logo and design are trademarks owned by AZNAR LEGAL & COMPLIANCE SLP. All other company and product names are trademarks or registered trademarks of their respective holders, and are hereby acknowledged as such by AZLYC.

How to contact AZLYC
If you have any questions about this Privacy Statement or our data processing activities, please contact us at enrique@aznar.com.

Amendments
AZLYC reserves the right to modify sections of this Privacy Statement at any time, for example to comply with legal requirements or to meet changing business needs. Please check this statement from time to time for any changes. If we plan to use personal data for a new purpose, we update our privacy information and communicate the changes to individuals before starting any new processing.

(1)  AZNAR LEGAL & COMPLIANCE SLP, a limited liablity Company registered at c/ Enric Morera 21, Esc B. 3-1, 08870 Sitges , Spain. NIF B-67038695.