WEBSITE PRIVACY POLICY

www.enbotella.com

I. PRIVACY AND DATA PROTECTION POLICY

Respecting the provisions of current legislation, Enbotella (hereinafter also Web Site) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws that this privacy policy incorporates

This privacy policy is adapted to current Spanish and European legislation on the protection of personal data on the Internet. Specifically, it respects the following regulations:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).

Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).

Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the party responsible for the processing of personal data

The person in charge of the treatment of the personal data collected in Enbotella is: ENBOTELLA-T S.L, provided of NIF: B99512592 and registered in: Commercial Register of Zaragoza with the following registry data: Volume 4333, Section 8, Folio 68, page Z-63804, whose representative is: Enbotella (hereinafter, Responsible for the treatment). Its contact details are as follows:

Address: CASTILLO DE CAPUA 10, NV7

Contact telephone number: 976248122

Contact email: Hola@enbotella.com

Register of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Enbotella, through the forms on their pages will be incorporated and will be treated in our file in order to facilitate, expedite and fulfill the commitments established between Enbotella and the User or the maintenance of the relationship established in the forms that this fill, or to respond to a request or query from it. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a register of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times following fully transparent information on the purposes for which the personal data are collected.

Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.

Principle of data minimisation: personal data collected will be only that which is strictly necessary in relation to the purposes for which they are processed.

Accuracy principle: personal data must be accurate and always up to date.

Principle of limitation of the storage period: personal data shall only be kept in a form that allows the identification of the User for the time necessary for the purposes for which they are processed.

Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.

Principle of proactive accountability: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Enbotella are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Enbotella undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw his/her consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, withdrawal of consent shall not condition the use of the Website.

On those occasions when the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed in the event that the completion of any of them is compulsory because they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data is used

The personal data are collected and managed by Enbotella in order to facilitate, expedite and fulfill the commitments established between the Web Site and the User or the maintenance of the relationship established in the forms that the latter fills or to respond to a request or enquiry.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical, and activities of the corporate purpose of Enbotella, as well as for the extraction, storage of data and marketing studies to adapt the content offered to the user, as well as improve the quality, operation and navigation of the Web Site.

At the time the personal data is obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses to which the information collected will be put.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 24 months, or until the User requests their deletion.

At the time the personal data is obtained, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is collected, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of articles 8 of the RGPD and 7 of the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Enbotella. In the case of a minor under 14 years of age, the consent of the parents or guardians is required for the processing, and this will only be considered lawful to the extent that the parents or guardians have given their consent.

Secrecy and security of personal data

Enbotella undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in return, is fully encrypted or encoded.

However, because Enbotella can not guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data that is likely to involve a high risk to the rights and freedoms of individuals occurs. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any other person to whom it makes the information accessible.

Rights deriving from the processing of personal data

The User has over Enbotella and may, therefore, exercise against the Data Controller the following rights recognized in the RGPD and the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights:

Right of access: this is the right of the User to obtain confirmation of whether or not Enbotella is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Enbotella has carried out or is carrying out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned of the same.

Right of rectification: This is the right of the User to have his or her personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.

Right of erasure ("the right to be forgotten"): This is the User's right, unless otherwise provided for by law, to obtain the erasure of his or her personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other legal basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under the age of 14. In addition to erasure, the Controller shall, taking into account the technology available and the cost of its implementation, take reasonable steps to inform controllers who are processing the personal data of the data subject's request for erasure of any link to those personal data.

Right to restriction of processing: This is the User's right to restrict the processing of his or her personal data. The User has the right to obtain the restriction of processing where the User contests the accuracy of his or her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and where the User has objected to the processing.

Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format and to transmit it to another controller. Where technically feasible, the Controller shall transmit the data directly to that other controller.

Right to object: It is the right of the User not to carry out the processing of their personal data or cease the processing of the same by Enbotella.

Right not to be subject to a decision based solely on automated processing, including profiling: It is the right of the user not to be subject to an individualized decision based solely on the automated processing of personal data, including profiling, unless existing legislation provides otherwise.

Thus, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD-www.enbotella.com", specifying:

Name, surname(s) of the User and a copy of the User's National Identity Document. In cases where representation is permitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be substituted by any other legally valid means that accredits identity.

Request with the specific reasons for the request or information to which access is sought.

Address for notification purposes.

Date and signature of the applicant.

Any document that accredits the request being made.

This request and any other attached documents may be sent to the following address and/or e-mail address:

Postal address: CASTILLO DE CAPUA 10, NV7

E-mail: Hola@enbotella.com

Links to Third Party Websites

The Web Site may include hyperlinks or links that allow access to third party websites other than Enbotella, and therefore are not operated by Enbotella. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the control authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his or her personal data is being processed, he or she shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State in which he or she has his or her habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he/she accepts the processing of his/her personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Web Site implies acceptance of the Privacy Policy of the same.

Enbotella reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to keep abreast of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.

Cookies Policy

This website uses third-party and own cookies to ensure you have a better browsing experience, to share content on social networks and so that we can obtain user statistics.

You can prevent the downloading of cookies through your browser settings, preventing cookies from being stored on your device.

As the owner of this website, I would like to inform you that we do not use any personal information from cookies, we only use general statistics of visits that do not involve any personal information.

It is very important that you read this cookie policy and understand that, if you continue browsing, we will consider that you accept its use.

According to the terms included in article 22.2 of Law 34/2002 on Information Society Services and Electronic Commerce, if you continue browsing, you will be giving your consent to the use of the aforementioned mechanisms.

Responsible Entity

The entity responsible for the collection, processing and use of your personal data, in the sense established by the Personal Data Protection Act is the website Enbotella, owned by Hugo Valero Artigas - C/ Castillo de capua,n10 nave 7 50197 Zaragoza.

What are cookies?

Cookies are a set of data that a server deposits in the user's browser to collect standard Internet log information and information on the behaviour of visitors to a website. In other words, they are small text files that are stored on the computer's hard drive and are used to identify the user when he/she logs on to the website again. Their purpose is to record the user's visit and to store certain information. Their use is common and frequent on the web as they allow pages to function more efficiently and achieve greater personalisation and analysis of user behaviour.

What types of cookies are there?

The cookies used on our website are session and third-party cookies, and allow us to store and access information relating to language, the type of browser used, and other general characteristics predefined by the user, as well as to monitor and analyse the activity carried out, with the aim of introducing improvements and providing our services in a more efficient and personalised manner.

Cookies, depending on their permanence, can be divided into session or permanent cookies. Those that expire when the user closes the browser. Those that expire depending on when the purpose for which they are used is fulfilled (for example, so that the user remains identified in the services of Hugo Valero Artigas) or when they are manually deleted.

Name Type Expiration Purpose Class

Third-party (Google Analytics) 2 years Used to distinguish users and sessions. Not Exempt

Third-party __utmb (Google Analytics) 30 minutes Used to determine new sessions or visits Not Exempt

Third-party __utmc (Google Analytics) At the end of the session Set up for use with Urchin Not Exempt

Third-party __utmz (Google Analytics) 6 months Stores the source or campaign that explains how the user arrived at the website Not Exempt

Additionally, depending on their purpose, cookies can be classified as follows:

Performance Cookies

This type of Cookie remembers your preferences for the tools found in the services, so you do not have to reconfigure the service each time you visit. By way of example, this type includes: Volume settings for video or sound players. Video streaming speeds that are compatible with your browser. Items stored in the "shopping cart" in e-commerce services such as shops.

Geo-location cookies

These cookies are used to find out which country you are in when you request a service. This cookie is completely anonymous, and is only used to help target content to your location.

Registration cookies

Registration cookies are generated once the user has registered or subsequently logged in, and are used to identify you to the services for the following purposes:

To keep the user identified so that, if you close a service, the browser or the computer and at another time or another day re-enter that service, you will continue to be identified, thus facilitating your browsing without having to identify yourself again. This functionality can be deleted if the user clicks on the [close session] functionality, so that this cookie is deleted and the next time the user enters the service he/she will have to log in to be identified.

Check whether the user is authorised to access certain services, for example, to participate in a competition.

Additionally, some services may use connectors with social networks such as Facebook or Twitter. When the user registers for a service with credentials from a social network, he/she authorises the social network to store a persistent Cookie that remembers his/her identity and grants access to the services until it expires. The user can delete this Cookie and revoke access to services through social networks by updating their preferences on the specific social network.

Analytical Cookies

Each time a user visits a service, an analytics cookie is generated on the user's computer by a third-party tool. This cookie, which is only generated during the visit, will be used in future visits to the services of Hugo Valero Artigas to anonymously identify the visitor. The main objectives pursued are:

To allow the anonymous identification of browsing users through the cookie (identifies browsers and devices, not people) and therefore the approximate counting of the number of visitors and their trend over time.

Identify anonymously the most visited content and therefore more attractive to users Know if the user is accessing is new or repeat visit.

Important: Unless the user decides to register for a Hugo Valero Artigas service, the cookie will never be associated with any personal data that can identify the user. These cookies will only be used for statistical purposes to help optimise the user's experience on the site.

Advertising cookies

This type of cookies allow the information of the advertisements shown to each anonymous user in the services of Hugo Valero Artigas to be extended. Among others, they store the duration or frequency of viewing advertising positions, interaction with them, or browsing patterns and / or user behaviour as they help to shape a profile of advertising interest. In this way, they make it possible to offer advertising related to the user's interests.

Third party advertising cookies

In addition to the advertising managed by the Hugo Valero Artigas websites in their services, the Hugo Valero Artigas websites offer their advertisers the option of serving advertisements through third parties ("Ad-Servers"). In this way, these third parties can store cookies sent from the services of Hugo Valero Artigas from the users' browsers, as well as access the data stored in them.

The companies that generate these cookies have their own privacy policies. At present, the Hugo Valero Artigas websites use the Doubleclick platform (Google) to manage these services. For more information, go to

http://www.google.es/policies/privacy/ads/#toc-doubleclick and http://www.google.es/policies/privacy/ads/.

How can I disable cookies in my browser?

Different browsers can be configured to warn the user of the reception of cookies and, if desired, prevent their installation on the computer. Likewise, the user can check in their browser which cookies they have installed and their expiry date, and can delete them.

For further information, please consult the instructions and manuals of your browser:

For more information on the management of cookies in Google Chrome: https://support.google.com/chrome/answer/95647?hl=es

For more information on the management of cookies in Internet Explorer: http://windows.microsoft.com/es-es/windows-vista/cookies-frequently-asked-questions

For more information on managing cookies in Mozilla Firefox: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we

For more information on managing cookies in Safari: http://www.apple.com/es/privacy/use-of-cookies/

For more information about managing cookies in Opera: http://help.opera.com/Windows/11.50/es-ES/cookies.html

If you wish to stop being tracked by Google Analytics visit: http://tools.google.com/dlpage/gaoptout

To learn more about cookies

You can learn more about online behavioural advertising and online privacy at the following link: http://www.youronlinechoices.com/es/

Google Analytics data protection: http://www.google.com/analytics/learn/privacy.html

How Google Analytics uses cookies: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=es#analyticsjs

Updates and changes to the privacy/cookie policy

The websites of Hugo Valero Artigas may modify this Cookies Policy in accordance with legislative or regulatory requirements, or in order to adapt said policy to the instructions issued by the Spanish Data Protection Agency, for which reason users are advised to visit it periodically.

When significant changes are made to this Cookies Policy, these will be communicated to users either through the website or by email to registered users.