PRIVACY POLICY

Privacy policy and information on personal data protection of Quality Advanced Therapies Research, S.L. enterprise’s website and social networks

1. Data Controller

The company Quality Advanced Therapies Research, S.L. (hereinafter “QUATRE LAB” or “Data Controller”) acts, under the terms established in the data protection regulations, as Data Controller in relation to the processing of personal data (e.g. customers, website users, information requesters) that ismade through QUATRE LAB’s websites, smartphone applications (“APP”s) and social media presence.

Data Controller: Quality Advanced Therapies Research, S.L.
NIF: ES-B67905885
Address: Paseo Mikeletegi, 81 –20009,Donostia-San Sebastián (Spain)
Telephone: +34 943062666
Email: info@quatrelab.com
Registration information: Commercial Registry of Gipuzkoa, Volume 3036, Book, 0, Folio 45, Sheet SS-44568, 1st Registration

2. Applicable Legislation

The basic regulations regarding the protection of personal data applicable to the data processing carried out by QUATRE LAB are:

• EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons regarding the processing of personal data and the free circulation of these data (“GDPR”).
• Organic Law 3/2018, of December 5, regarding the Protection of Personal Data and digital rights guarantee (“LOPDGDD”).
• Their respective complementary and development regulations.

3. Website identification and social network presence

QUATRE LAB’s official website iswww.quatrelab.com.

QUATRE LAB’s main official channels in social and professional networks are the following:
• Linkedin: https://es.linkedin.com/company/quatre-lab

For the purposes of this Privacy Policy, the official QUATRE LAB website, APPs and official channels on social or professional networks will all be referred to hereinafter as “the website”, except when otherwise specified.

4. Purposes of data processing and legitimate legal basis

In compliance with current regulations on the Protection of Personal Data, users are informed that the personal data they provide through any means located on the website or official channels on QUATRE LAB´s social or professional networks (e.g. by email, forms), or as a result of their use, may be incorporated into QUATRE LAB´s data processing systems.

The purposes of the data processing that QUATRE LAB can carry out through the website are:

1. CUSTOMERS AND WEBSITE USERS:

Purpose: performance of quality control analysis of Advanced Therapy Medicine Productsand associated services for pharmaceutical, biotechnology and other companies that carry out their activity in the pharmaceutical and medical research industrie as well as development, production and marketing of products, and related activities.
Legal Basis: we need to process the data to manage our products and services (“contractual” or “pre-contractual” relationship according to article 6.1.b of the GDPR).
Possible recipients: no communication of data to third parties is foreseen, except to QUATRE LAB´s suppliers that intervene in any phase of the marketing or delivery of the products or services requested and for legal obligations or specific cases.
Rights:please read the “Rights of Interested Parties” section.

2. INFORMATION REQUESTS:

Purpose: providing contact, consultation, and communication tools with interested and relatedparties, responding to applications, requests and/or queries.
Legal basis: consent from the interested party (GDPR art. 6.1.a), when they provide their data for these purposes, by filling in “Contact” forms or similar, and checking the required boxes to accept the conditions and the privacy policy.
Possible recipients: we do not foresee the communication of data to third parties.
Rights: please read the “Rights of Interested Parties” section.

3. USERS OF THE WEBSITE AND THE SOCIAL OR PROFFESIONAL NETWORK CHANNELS:

Purpose: managing and analyzing the use of the website and its corporate presence in social and professional networks.
Legal Basis: QUATRE LAB’s legitimate interest (GDPR art. 6.1.f) topublicize theirproducts, services and activities.
Possible Recipients:we do not foresee the communication of data to third parties, except for the publication or dissemination of the opinions and evaluations made.
Rights: please read the “Rights of Interested Parties” section.

4. USERS OF THE WEBSITE AND THE SOCIAL OR PROFFESIONAL NETWORK CHANNELS:

Purpose: managing and analyzing the use of the website and its corporate presence in social and professional networks.
Main Legal Basis: QUATRE LAB´s legitimate interest (GDPR art. 6.1.f) to know and manage the operation of theirwebsite and channels on social and professional networks.
Specific Legal Basis: consent from the interested party (GDPR art. 6.1.a), when the data analysis is based on the use of analytical cookies, to advertise cookies or similar technologies, granted by accepting the use of cookies.
Possible Recipients:we do not foresee the communication of data to third parties.
Right to Modify or Revoke the Consent Granted for the Use of Cookies: the user has the “Cookie Settings” tool available at all times on the website for this purpose.
Other Rights: please read the “Rights of Interested Parties” section.

5. INDIVIDUALSAPPLYING FOR JOBS THROUGH THE WEBSITE AND CHANNELS ON SOCIAL OR PROFESSIONAL NETWORKS
Purpose: providiga tool for contact, consultation and communication with individualsinterested in working at QUATRE LAB and, where appropriate, to invite them to participate in the company’s personnel selection processes.

Legal Basis: we need to process the data to manage the application (RGPD art. 6.1.b) and consent to sue the website (GDPR art. 6.1.a) provided by the interested individual.
QUATRE LAB’s legitimate interest (GDPR art. 6.1.f) to publicizetheirproducts, services and activities.
Possible Recipients:it may be carried out internally or by external companies that QUATRE LAB hire to carry out personnel selection processes.
Rights: please read the “Rights of Interested Parties” section.

5. Data retention period

The personal data provided will be kept for the time necessary to fulfill the purpose for which they are collected, determine the possible responsibilities that may arise from the purpose, or for the period that the applicable regulations establish in each case (from an accounting, tax orcommercial, among others), after which they will be deleted by adopting the necessary security measures to guarantee their confidentiality.

6. Rights of the interested parties

You can exercise the rights related to the protection of your personal data (e.g. access, rectification, erasure, restriction of processing, objection, portability), as well as withdraw the consent granted or make any other request on this matter by addressing your request in writtento QUATRE LAB´s business address (Paseo Mikeletegi, 81 – 20009, Donostia- San Sebastián, Gipuzkoa, Spain) or email account (info@quatrelab.com).

The requestmust include a copy of a document evidencingthe requester’s identity. If you submitthe request in your capacity as legal representative, you must attach a document evidencing such representation besides the copy of a document proving your identity.

The control authority to which you can go if you do not agree with the resolution of the requests or to file a claim is the Spanish Agency for Data Protection (www.aepd.es).

7. Personal Data Collection

The Data Controller does not require you to provide personal data to access the website. However, the website contains utilities and forms (e.g. contact form) whose use requires the user to provide personal data, mostly identification or contact details. The user provides personal data freely and voluntarily. QUATRE LABdo not request more personal information beyond the strictly necessary in order to carry out the query processed.

Any user who sends/includes any type of content (data, documents, texts, images, videos, sound, graphics, messages, or other material) declares and guarantees to do so in such a way that it complies with the conditions expressed herein and with the current legislation. Any user who includes third-party personal data declares that they have their prior and express consent for their processing. The inclusion of third-party data without their prior and express consent is prohibited.

The user is solely responsible for the veracity, correctness and legitimate processing of the data included, exonerating QUATRE LAB from any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity, and authenticity of the personal data provided and undertake to keep them duly updated.

The non-completion or erroneous completion of fields indicated as mandatory in the forms on the website may result in the Data Controller not being able to attend to the user’s request.

The Data Controller will collect personal data appropriately, according to the purposes, utilities, services, or features included on its website, in a determined, explicit, and legitimate manner, so that in no eventnone fraudulent, unfair, illicit, or illegal neither mean nor use will jeopardize the legitimate rights of users.

Sending information through this website implies acceptance of this privacy policy and general conditions of the website.

8. Specific data processing: minors

The services of the Data Controller do not target minors. In the event that some of our products or services were specifically addressedto minors, the Data Controller would request the consent of the parents or guardians for the collection of personal data or, where appropriate, for the treatment of the personal data.

QUATRE LAB recommend that users consult the different materials that have been developed by the supervisory authorities in relation to the protection of personal data of children and young people. This information (recommendations, manuals on the use of new technologies, educational videos, etc.) is available on the websites of the Basque and Spanish Data Protection Agencies.

9. Specific data processing: Job applicants

In accordance with the provisions of the Personal Data Protection regulation, any person who provides his/hercurriculum vitae offering his/hercandidacy to work at QUATRE LAB through forms, email, social or professional network channels or similar mechanisms, is informed that the data provided through his/herjob application will be incorporated into our data processing systems (“CV and personnel selection” processing”).

Thedata of the applicant may be used for the purpose of making them participate in future personnel selection processes inour companywhich may be carried out internally or by external companies that QUATRE LAB hire for these purposes.

QUATRE LAB will keep the applicant´sresume for approximately one year. After this, the data will be destroyed, applying the necessary security measures to ensureits confidentiality.

If you do not agree with any of the purposes described, please notify us in writing as soon as possible. Likewise, if there is any change in your data, please keep us informed.

You can exercise the rights related to the protection of your personal data (i.e. access, rectification, erasure, restriction of processing, objection, portability) as well as any request on this matter as indicated in the section “Rights of Interested Parties” of this Privacy Policy.

10. Specific data processing: registrations and subscription

In the eventof subscription to newsletters or similar services, which involve the processing of personal data, users may request cancellation of said services at any time by sending a request to the e-mail address info@quatrelab.comor using any other means thatQUATRE LAB provides for this purpose, such as the mechanism called “Unsubscribe”, located at the end of the newsletters themselves.

11. Links to social and professional networks

This website offers links to social networks and external websites and channels. QUATRE LAB assume no responsibility in relation to these linked sites. Any user who accesses social and professional networks and external websites and channels related to QUATRE LAB, from the links located in this website or in any other way, is previously and expressly informed that the conditions of use, privacy policies, cookie policies and any other conditions or regulations depend on the entities responsible for said social networks and websites and channels, and never on QUATRE LAB.

12. Presence of QUATRE LAB in social and professional networks

QUATRE LAB can have profiles on social and professional networks, with the main purposes of marketingtheirproducts, services and activities, and establishing channels of communication with companies and professionals. The publications offered through these channels are informative in nature.

By registering in the QUATRE LAB profiles with their profile on a social or professional network, the user gives his/herexpress authorization to QUATRE LAB for the latter to process his/her personal data in accordance with this Privacy Policy.

Any information and personal data provided voluntarily by the user through QUATRE LAB’s social or professional networks may be processed for the purpose of contacting the user and dealing with requests made, sending informative or commercial communications, managing events, invitations and similar activities, and knowing and managing both his/her opinion about QUATRE LAB and theirpublications,in general and the presence of QUATRE LAB in social and professional networks.

Users are informed that the information and content (data, texts, videos, sound, photographs, graphics, comments, messages or other material) that they publish through QUATRE LAB’s social or professional networks (including, where appropriate, personal data) may be made publicly available to other users of these social or professional networks and may be freely visible, commented on and shared by their visitors, under the terms established by each social or professional network.

From the configuration of the user profile of each social or professional network, the user can set upwhat information s/he wants to make public in each case, check the permissions s/he has granted, delete or deactivate, and manage his/herpublications according to thecriteria and rules of use of each social or professional network.

The user will be solely responsible for his/herpublications as per the current legislation, rules of use and privacy policies established by the corresponding social or professional network, and those of QUATRE LAB who do not bear any liability in relation to the publications that each user performs. QUATRE LAB will unilaterally and without prior notice remove content that they considerbreach the current legislation, rules of use and established privacy policies, or inappropriate.

QUATRE LAB can follow other profiles on other social or professional networks without this fact encompassinga link of any kind with them.

Likewise, the QUATRE LAB channels in different social or professional networks can be followed by other people or users of those networks without this fact encompassingany kind of connection with them.

QUATRE LAB reserve the right not to respond to messages or comments received through these channels. QUATRE LAB may modify or delete at any time and without prior notice the publications issued on theirsocial networks.

By becoming a follower, clicking “Like” or taking any other similar actions on social or professional networks, you consent to the processing of your personal data in the environment of the corresponding social or professional network, in accordance with its privacy policies, QUATRE LAB’s access to data contained in the contact list and that of their publications, expressly including those of a commercial nature, appear in your notices and notifications.

If the user wants to stop following the official channels on QUATRE LAB’s social or professional networks, s/hemust do so using the tools provided for this purpose by each network.

13. Security Measures

QUATRE LAB will process the personal data contained in theirdata processing system, adopting the technical and organizational measures required to guarantee theirsecurity and avoid theiralteration, loss, processing 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, whether they come from human action or from the physical or natural environment, in accordance with the current legislation that is applicable in terms of security measures for personal data processing. However, users are informed that computer security measures are not impregnable and are not safe from possible illegal and improper interference which would not be the responsibility of the Data Controller.

To guarantee the security and privacy of the user, this website uses encryption technology based on secure connection layer protocols (https), so that browsing is as secure as possible.

14. Security Breaches

The user must immediately notify QUATRE LAB of any incident, security breach, improper or unauthorized access detected in relation to the website, private areas, access codes, presence in social or professional networks or any other circumstance that jeopardize the security and confidentiality of the information or the proper functioning of the website.

The telephone number +34 943062666 and the email addressinfo@quatrelab.com are established as preferential notification mechanisms.

15. Duty of Secrecy

The Data Controller is committed to the privacy and protection of user data. The processing of the personal data will be carried out confidentially and in compliance with current legislation.

16. Validity and modifications

The Data Controller reserves the right to modify its privacy policy according to its criteria, to introduce legislative or jurisprudential changes. If the Data Controller introduces any modification, the new text will be published on this same website, where the user may have knowledge of it. In any case, the relationship with the users will be governed by the rules established at the precise moment in which the website is accessed. This is the reason why the Data Controller recommends that you visit this privacy policy each time you connect to the website.

17. Authority

Any relationships established between QUATRE LAB and the user will be governed by the provisions of the current regulations regarding the applicable legislation and the competent authority. However, regardless of any regulations permitting the parties to submit any claim and/or controversies to an authority, QUATRE LAB and the user expressly waiveany other jurisdiction that may correspond to them and submit themselves to the Courts of the city of Donostia-San Sebastián (Gipuzkoa, Spain).

QUATRE LAB will pursue legal action against the breach of these Conditions as well as against any improper use of the contents and utilities made publicon theirwebsite, exercising all civil and criminal actions that may correspond by law, including those of an economic nature.

Paseo Mikeletegi 81 A
20009 Donostia - San Sebastián
Basque Country

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