1.1 LEGAL DATA
In compliance with article 10.1 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI), the identifying data of the owner are indicated below:
• Data controller: FERRO SYSTEMS, S.L.U., (hereinafter, 'Ferro Systems')
• Tax ID (CIF): B70208079
• Registered address: c/ Alcalde Francisco Vázquez, Pza. Interior 63, 15002, A Coruña (Spain)
• Registration data: Registered in the A Coruña Mercantile Registry, Volume 1912 of the Archie, General Section, Folio 103, Page C-18027, Inscription 3
• Contact details: comercial@braseli.com | Tel. (945) 333 050  Fax: (945) 333 048
• Registered Trademark in Spain: “BRASELI” registration no.: M2928298(5)

1.2 GENERAL TERMS AND CONDITIONS OF USE
Access to this website is free and does not require prior subscription or registration. Users shall use the information contained in this website in compliance with the legislation applicable in each case, respecting the intellectual property rights of Ferro Systems or third parties.
The user shall not carry out any action, through the services made available by Ferro Systems, that causes damage or alterations to the content, nor shall they hinder the proper operation of the website. The user shall not copy, distribute, transfer, display, create or, otherwise, reproduce, publish, license or create any work based on the information or content included in this website. The user shall not cause technical problems of any kind whether by transferring elements that could potentially carry any computer virus nor by damaging, interfering or intercepting this website in whole or in part.
Ferro Systems is not liable under any circumstance for the improper use of this website or its content, or for the consequences that its use may cause.

1.3 LIMITATION OF LIABILITY AND GUARANTEES
Ferro Systems does not guarantee that its webpage is operative, nor that its content is complete, exact or reliable at all times. Ferro Systems reserves the right to modify at any time, without prior notice, the content of this website, as well as the General Terms and Conditions of Access.
Ferro Systems assumes no legal liability for any consequential, punitive, incidental, indirect or special damages related to or arising from this website, whether or not the parties have actual or implied knowledge of the damages that they might incur in.
In the event of carrying out maintenance, repair, update or improvement operations on the services, Ferro Systems has the right to temporarily suspend access to this website without prior notice,and reserves the right to provide or cancel the services, with no restriction as to informing the users, if the circumstances allow.
This excludes any liability for damages of any kind that may arise from the lack of availability or continuous operation of the website and its services, and the benefits that users may have attributed to this website. Ferro Systems does not give any express or implicit guarantee on the website, or the Content and Services included in it, regarding, including, but not limited to, the availability and continuous operation of the website, the quality level and functionality of the website, content update, error or omission in the information included, virus and other elements that may damage computer systems, electronic documents and files stored on the computer system.

By means of this Privacy Policy, users are informed in a clear, precise and concise way. If users agree to it, they shall give Ferro Systems their free, informed, specific and unequivocal consent so that their personal data can be processed, according to the (EU) Regulation 2016/679 regarding the protection of natural persons, through the processing of their personal data and free circulation (GDPR) and the Organic Law 3/2018, of 5 December, regarding Data Protection and Guarantee of Digital Rights (LOPDGDD) (European and Spanish legislation on data protection in force).

2.1 BASIC DATA PROTECTION INFORMATION (EU Regulation 2016/679)

Data controller	FERRO SYSTEMS, S.L.U. (B70208079)
Purpose of data processing	Answering queries and doubts, service provision and eventually forwarding information on goods and services.
Legitimacy	Consent of the data subject (Article 6.1.a of the GDPR). Contractual relationship with the data subject (Article 6.1.b of the GDPR).
Recipients	The companies of Grupo GPF are listed at http://www.grupogpf.com/NuestroGrupo. They may also be accessed by: Tax Administration, Banks and financial institutions, Law Enforcement Forces and Agencies, and Data Controllers necessary for the provision of the service.
Rights and additional information	This provides for the exercise of the rights of access, rectification or erasure, among others. All information is accessible in the detailed information of this privacy policy.

2.2 DETAILED INFORMATION ON DATA PROTECTION

2.2.1 Who is the data controller?

The Data Controller's identifying data are shown in section 1.

2.2.2 What information from the user is collected and processed through the website?

• Through the contact form
The website includes the option to write to us so as to clear any doubts you may have regarding the operation of our goods/services, or anything else you may need. We shall get back to you via email or phone number, if provided.
• Through our business email
You may write to our e-mail address comercial@braseli.com and/or request the information you may consider necessary to clear any doubts related to our services.
• Application reception. Work with us
The website includes a section where you may upload your Curriculum Vitae if you are interested in being part of Grupo Plásticos Ferro's team. The process shall be completed on GPF - Grupo Plásticos Ferro's website and your CV shall be registered in GPF's selection system, where it can only be shared by the companies in the Group.
In the event that the user provides us with third-party data, they shall assume the responsibility of having previously informed them and having their consent to do so, in accordance with article 14 of the GDPR.

2.2.3 Which is the purpose for processing the user's personal data?

Ferro Systems processes personal data for the following purposes, considering the reason for which they have been provided:
a) To provide the contracted goods/services, carry out the maintenance of the contractual relationship and the monitoring thereof.
b) To contact, process, manage and respond to any of the user's requests, queries or incidences (either via email, contact form or telephone).
c) To manage the client's purchasing process and any queries in relation to the goods/services contracted.
d) To manage, if necessary, the sending of information about goods, services and news related to Ferro Systems by electronic and/or conventional means.
e) To assess and manage, where appropriate, the curriculum vitae provided by the user for selection processes that fit their professional profile and carry out the necessary actions for the selection and recruitment of staff.

2.2.4 What is the legitimacy of user's data processing?

• The legal basis for personal data processing for the purpose set out in the previous section is the provision of the corresponding service, and it is also a requirement to do so, as stated in Article 6.1 b) of the GDPR.
• Regarding the sending of information about goods, services and news related to Ferro Systems, the legal basis for processing the personal data provided is the consent expressly given by the user, as set out in Article 6.1 a) of the GDPR.
• The legal basis for processing the data of the person who provides Ferro Systems with their Curriculum Vitae (CV), and other related data (identifying and professional), shall be the consent expressly given by the user as set out in Article 6.1 a) of the GDPR.

2.2.5 For how long shall the user's personal data be processed?

• The data for themanagement of the relationship with the client, and the invoicing and collection of services shall be kept for the time necessary to reply to them, and, if applicable, for as long as the data subject does not request the withdrawal of their consent to be sent information relating to their query.
• The data for the management of queries and applications shall be kept for the time necessary to reply to them, and, if applicable, for as long as the data subject does not request the withdrawal of their consent to be sent information relating to their query.
• The data for the sending information related to Ferro Systems's goods or services shall be stored as long as the user does not revoke their consent.
• The data from an applicant's Curriculum Vitae (CV) for selection processes shall be stored for up to two years.

2.2.6 To which recipients shall the user's personal data be disclosed?

As a general rule, your data will not be disclosed to third parties unless there is a legal obligation to do so, or it is necessary to provide the service. With this in mind:
• The user's personal data may be disclosed to the financial institutions through which collections and payments are managed.
• The data shall only be communicated to Law Enforcement Forces and Agencies if it is legally required.
• They may also be communicated to the relevant Public Administrations where required by law.
• To the companies belonging to GPF - Grupo Plásticos Ferro (P. FERRO GPF, S.L.; PLÁSTICOS FERRO, S.L.U.; FERROPLAST MAROC, S.A.R.L.; TUBERÍAS Y PERFILES PLÁSTICOS, S.A.U.; PLÁSTICOS IMA, S.A.U.; FERRO SYSTEMS, S.L.U.; TÉCNICA DE ENVASES PESQUEROS, TEP, S.A.; ELECTROMECÁNICOS VIVEIRO, S.A.U.; COMPAÑÍA BF DE COMERCIO, S.A.U.; GRUPO PLASTICOS FERRO FRANCE, S.A.S.; ABC CONFORT, S.L.U.; PLÁSTICOS EL PINAR, S.A.U.; PLÁSTICOS LANTARON, S.A.U.; TRANSFORMADOS PLÁSTICOS EGA, S.A.U.; PLÁSTICOS FERRO BILBAO, S.L.; P.FERRO INVERSIONES, S.L.)
• If applicable, the data shall also be disclosed to the data controllers of Ferro Systems for the appropriate provision of the service.

2.2.7 Which are the user's rights?

La normativa en materia de protección de datos permite que pueda ejercer sus derechos de acceso, rectificación, supresión y portabilidad de datos y oposición y limitación a su tratamiento, así como a no ser objeto de decisiones basadas únicamente en el tratamiento automatizado de sus datos, cuando proceda.
These rights provide that:
- The exercise thereof is free of charge, except in the case of manifestly unfounded or excessive requests or applications (e.g. repetitive), in which case Ferro Systems may charge a fee proportional to the administrative costs incurred or refuse to act.
- You may exercise your rights directly or through your legal or voluntary representative.
- We shall respond to your request within one month, although, taking into account the complexity and number of requests, the deadline may be extended for another two months.
- We are obliged to inform you of the means of exercising these rights, which shall be accessible, and you shall not be denied the exercise of these rights on the sole ground of choosing another means. If the request is made by electronic means, the information shall be provided by such means where possible, unless you ask us to do otherwise.
- If Ferro Systems does not follow up on the request, you shall be informed, at the latest within one month, of the reasons for non-performance and the possibility of complaining to a Supervisory Authority.
• Form to exercise the right of access
• Form to exercise the right to rectification
• Form to exercise the right to object
• Form to exercise the right to erasure (right to be forgotten)
• Form to exercise the right to restrict processing
• Form to exercise the right to data portability
• Form to exercise the right to not be subject to individual automated decisions

To exercise your rights, Ferro Systems offers you the following means:
1. By written and signed request addressed to Ferro Systems. Ref. 'Exercise of Rights GDPR'.
2. By sending a scanned and signed form to the email address comercial@braseli.com, indicating in the subject: 'Exercise of Rights GDPR'.
In case of doubt, Ferro Systems may request a document establishing identity (ID) to ensure that an answer is given only to the person concerned or his/her legal representative, in which case a document accrediting the representation may also be requested.
Likewise, and especially if you consider that you have not obtained full satisfaction in the exercise of your rights, you may file a complaint with the national Supervisory Authority by addressing the Spanish Data Protection Agency (AEPD), c/ Jorge Juan, 6 - 28001 Madrid (www.aepd.es).

2.2.8 Which are the security measures in place?

At Ferro Systems, we are committed to protecting your personal information.
We use reasonably reliable and effective physical, organisational and technological measures, controls and procedures aimed at preserving the integrity and security of your data and guaranteeing their privacy.
In addition, all personnel with access to personal data have been trained and are aware of their obligations in relation to the processing of your personal data.
In the case of the agreements we sign with our suppliers, we include clauses requiring them to maintain the duty of secrecy with respect to the personal data to which they have had access by virtue of the order placed, as well as to implement the technical and organisational security measures necessary to guarantee the confidentiality, integrity, availability and permanent resilience of the systems and services for personal data processing.
All these security measures are reviewed periodically to ensure their adequacy and effectiveness.
However, absolute security cannot be guaranteed, and there is no impenetrable security system so, in the case of any information processed and under our control being compromised as a result of a security breach, we shall take appropriate measures to investigate the incident, notify the Supervisory Authority and, where appropriate, those users who may have been affected so that they can take appropriate action.

The domain www.braseli.com is owned by Tuberías y Perfiles Plásticos, S.A.U., and Ferro Systems has been granted the authorisation for its use.
This website contains trademarks, logos, designs and slogans, all owned by Tuberías y Perfiles Plásticos, S.A.U. or its subsidiaries. The User expressly acknowledges this ownership and understands that they do not acquire any right over them, nor are they allowed to modify or make use of them. None of these trademarks, without an express written and signed consent of their owners, shall be used without authorisation. The User is not authorised to use, in any other website, Tuberías y Perfiles Plásticos, S.A.U.'s trademarks as links without Tuberías y Perfiles Plásticos, S.A.U. or Ferro System's written consent.
The User shall not copy, modify, distribute, transfer, reproduce, publish, assign, sell the above-mentioned elements or create new goods or services derived from the information obtained without expressly citing its source.
Braseli's website contains texts that are intended to inform its users. Tuberías y Perfiles Plásticos, S.A.U. or Ferro Systems shall not be, in any case, liable for any error or omission in the generated content.

4.1 BASIC COOKIE INFORMATION

What you should know about Cookies

Cookies are small files that store information on the devices of the Users who use our website.
Cookies are associated with the browser of a particular computer or device. Through them, Ferro Systems is able to recognise the browsers of the Users. They are also used to determine the users' navigation preferences and, thus assess their preferences, using them as indicators to improve its services.

Accepting cookies in Ferro Systems

Law 34/2002, of 11 July, on Information Society and Electronic Commerce (hereinafter, LSSICE) in relation to cookies, requires that Users be informed prior to their browsing experience on the platform about the use, type and purpose of cookies. That is why we have implemented an information notice that is displayed once you access our website, informing you in advance, giving you the option to choose the cookies you allow, and accepting them expressly, thus complying with the criteria established by the European Data Protection Board and the Guide on the Use of Cookies published by the AEPD in July 2020.

4.2 DETAILED INFORMATION ON COOKIES

• Technical or functional cookies:

These cookies allow the user to navigate through a website, platform or application, and use the different options or services that exist therein, including those that the publisher uses to allow the management and operation of the website and to enable its functions and services, such as, for example, controlling the traffic and communication of data, identifying the session, accessing areas with restricted access, remembering the elements that make up an order, carrying out the purchasing process of an order, managing payments, controlling fraud linked to the security of the service, making the request for registration or participation in an event, counting visits for the purposes of invoicing the licences of the software with which the service operates (website, platform or application), using security elements during navigation, storing content for the broadcasting of videos or sound, enabling dynamic content (for example, animations while loading texts or images), or sharing content through social networks.
Also belonging to this category, due to their technical nature, are those cookies that allow the management, in the most efficient manner possible, of the advertising spaces that, as another design or layout element of the service offered to the user, the publisher has included in a website, application or platform based on criteria such as the content published, without information being collected from users for different purposes, such as customising such advertising content or any other content.
*Technical cookies shall be exempt from the obligations established in article 22.2 of the LSSI when they allow the service requested by the user to be provided, as is the case with the cookies listed in the previous paragraphs. However, if these cookies are also used for non-exempt purposes (e.g. for behavioural advertising purposes), they shall be subject to these obligations.

*Technical cookies shall be exempt from the obligations established in article 22.2 of the LSSI when they allow the service requested by the user to be provided, as is the case with the cookies listed in the previous paragraphs. However, if these cookies are also used for non-exempt purposes (e.g. for behavioural advertising purposes), they shall be subject to these obligations.

• Preference or customisation cookies:

These cookies allow to remember information for the user to access the service with certain characteristics that may differentiate their experience from that of other users, such as, for example, the language, the number of results to be displayed when the user performs a search, the appearance or content of the service depending on the type of browser through which, or the region from which they access the service, etc.

* If the user chooses these characteristics (for example, if they select the language of a website by clicking on the icon of the corresponding country's flag), the cookies shall be exempt from the obligations of article 22.2 of the LSSI as they are considered a service expressly requested by the user, as long as the cookies obey exclusively to the selected purpose.

• Analysis or measuring cookies:

These cookies allow the data controller to monitor and analyse the behaviour of the users of the websites to which they are linked, including the quantification of the impact of advertisements. The information collected through this type of cookie is used to measure the activity of the websites, applications or platforms, in order to introduce improvements based on the analysis of user use data of the service.

*Regarding this type of cookies, although not exempt from the duty to obtain informed consent for their use, the WP29 stated that it is unlikely that they represent a risk to the privacy of users, provided that they are first party, that they process aggregate data for strictly statistical purposes, that information on their use is provided, and that the possibility of users expressing their refusal to consent their use is included.

• Behavioural advertising cookies:

These cookies store information on the behaviour of the users obtained through the continuous observation of their browsing habits, which enables developing a specific profile in order to display advertising based on it.

The cookies used by Ferro Systems

The table below includes the details, purpose, type and classes of cookies that we have implemented on our platform. For your understanding, we detail below the types of cookies that can be used if you give us your consent:

Name	Domain	Objective/Purpose	Duration	Type
_gat_gtag_UA_53772493_14	braseli.com	They are used to limit the percentage of requests.	1 months	Analysis
_gid	braseli.com	They are used to distinguish users.	24 hours	Analysis
_ga	braseli.com	They are used to distinguish users.	24 hours	Analysis
NID	google.com	They are used to remember your preferences.	5 months	Analysis
PHPSESSID	braseli.com	They are used to remember your preferences.	Session	Functional

4.3 HOW TO UNINSTALL COOKIES

Here you shall find the instructions for different browsers should you desire to uninstall the cookies used in www.braseli.com:
1. For more information on Internet Explorer click here.
2. For more information on Microsoft Edge click here.
3. For more information on Firefox click here.
4. For more information on Chrome click here.
5. For more information on Safari click here.

Ferro Systems may modify this legal text in accordance with the applicable legislation at any time. In any case, any modification of the Legal Notice, Privacy Policy and Cookie Policy that affects the use of the website, shall be duly notified to the user so that they are informed of the changes made in the processing of their personal data and, if the applicable regulations so require, the user can give their consent.

Our legal texts comply with the Spanish legislation. These texts shall remain accessible to users at all times from our website.
If the parties do not agree to submit to mediation or arbitration beforehand, this legal notice sets out the agreement to submit to the Courts and Tribunals of A Coruña, expressly waiving any other jurisdiction.
Ferro Systems reserves the right to modify these General Terms and Conditions at any time and without prior notice.
TAll notifications, summonses, agreements, consents, acceptances, approvals or communications of any kind that may be necessary in accordance with these General Terms and Conditions, or related to them, shall be made in writing and sent to Ferro Systems by mail to the company's registered address or to the Legal Department.

Last modified: 20 May 2021.