PRIVACY POLICY

In compliance with Regulation 2016/679 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (hereinafter, "RGPD"), of the Organic Law 15/1999, of Protection of Personal Data (LOPD) and of Law 34/2002 of July 11, Information and Electronic Commerce Service, (LSSI), ZTALENT will provide Users the necessary information so that, in advance, they can give their consent for ZTALENT to process their personal data so that Users can, with total freedom, decide if they wish to provide the data that may be required on the occasion of the subscription or registration in the services offered by ZTALENT through ZTALENT.

In this way, this Privacy and Cookies Policy has been prepared with in order to determine: (i) the type of information requested by ZTALENT when Users register on the ztalent.tech; (ii) the treatment and purposes for which ZTALENT uses said information; (iii) as well as the different security measures aimed at their protection.

In accordance with the provisions of the Legal Notice and in the General Conditions of Use and Contract, accessible through ZTALENT, User is understood to be any person, whether physical or legal, who makes use of any service offered by ZTALENT through ZTALENT, either as a Company or as a SAP Professional.

IDENTIFICATION DATA

The COMPANY* refers to the company ZTALENT GESTIÓN Y TECNOLOGÍA S.L., a company with registered office at Calle López de Hoyos 42, 28006 Madrid, with Tax ID number B72543317, registered in the Madrid Mercantile Registry, Volume 44.165, Page 98, Book 0, Section 0, Sheet n# M-, 778817 and which provides Users with the services provided through the Website www.ztalent.tech (“ZTALENT”).

DATA PROTECTION

Responsible for data processing

The COMPANY is responsible for data processing, contactable through the email address: info@ztalent.tech The data protection delegate is Alejandro Moyano, who can be reached at Calle López de Hoyos 42, 28006 Madrid, or at same email address: info@ztalent.tech

Legitimation of the processing of personal data

The COMPANY complies with the guidelines of Regulation 2016/679 regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (hereinafter, "RGPD") and other regulations in force at all times, and ensures the correct use and treatment of Users' personal data.

By the mere fact of visiting ZTALENT, no personal data is automatically recorded. However, there is certain information that is collected and recorded on the COMPANY servers through cookies, such as the type of browser, operating system or IP address, in order to improve the User's navigation and manage ZTALENT. The use and purpose of cookies is set out in section IV of this document.

Additionally, in order to carry out the services offered by ZTALENT, it is necessary for the SAP Professional and the Company to complete a registration form (hereinafter, "Form"), through which personal data will be collected.

Along with each personal data collection form, ZTALENT will inform Users of the existence and acceptance of the particular conditions for the processing of their data in each case, informing them of the data of the person in charge, the possibility of exercising their rights to access, rectification, deletion, limitation of the treatment, cancellation, portability of the data or opposition, the purpose of the treatment and the communication of data to third parties, where appropriate.

Information collected

In the event that an Internet User decides to register as a SAP Professional or ZTALENT Company, the information indicated therein will be requested through the Form and a password that will protect their account from unauthorized access. Said personal information will be provided by the SAP Professional and / or Company or Company Representative on a voluntary basis.

The SAP Professionals and the Company will respond, in any case, for the veracity of the data provided by completing the required data in the form found on ZTALENT, thus, being a SAP Professional or ZTALENT Company supposes that It must guarantee, both with the COMPANY and with third parties, the quality of the information provided, that is, that the data and information provided is real, truthful and up-to-date. In any case, the provision of false or outdated data is prohibited and SAP Professionals and / or Company or Company Representatives must always identify themselves with their real name and surname or correct company name and with true and current data.

For these purposes, the SAP Professional and the Company will be solely responsible for any direct and / or indirect damage caused to third parties or to the COMPANY due to the use of personal data of another person, whether physical or legal, or their own data. personal when they are false, erroneous, not current, inappropriate or impertinent.

However, the COMPANY will cancel, erase and / or block the data when it is inaccurate, incomplete or is no longer necessary or relevant for its purpose in accordance with the provisions of this document, as well as current legislation on the protection of data. In this way, the personal data provided will only be kept as long as the relationship with the SAP Professionals and / or Company is maintained.

Purpose

The COMPANY will use the personal information of the SAP Professionals and / or Company in order to provide any of the services offered through ZTALENT and to improve the experience of the SAP Professional and / or Company in the process of hiring the Service.

In this way, the data of the SAP Professional and / or Company will be treated with the following purposes:

• To facilitate the information requested by the SAP Professional and / or Company and manage the User's registration on ZTALENT.
• In the event that the SAP Professional and / or Company carry out the contracting of the products and / or services online, perfect, comply with and control the correct fulfillment of the contract.
• Comply with legal obligations.
• If the SAP Professional and / or Company accepts the processing of geographic location data, these will be processed for the purpose of carrying out quantitative studies.
• The electronic address data will be processed in order to send notifications of the required service through ZTALENT.
• To send promotional communications to the SAP Professional and / or Company related to commercial and advertising information of ZTALENT.
• To send promotional communications to the SAP Professional and / or Company related to commercial and advertising information of ZTALENT.

The COMPANY may use personal information to develop methods, to manage, improve or expand the services provided through ZTALENT. Specifically, the data collected may be used to manage, improve and optimize the online contracting process and in general, to improve service.

Likewise, the COMPANY may collect the User's IP address in order to provide an additional level of security against fraudulent activities.

In addition, the COMPANY may use personal information for statistical and analysis purposes, as well as to inform the SAP Professional and / or Company of commercial offers of products and services that may be of interest to them.

The COMPANY will only use the personal data of its SAP Professional and / or Company for the aforementioned purposes, treating them confidentially. In the event that the information was used for a different purpose, the COMPANY will request the prior consent of the User who owns the personal information.

In the event that the COMPANY plans the subsequent processing of personal data for a purpose other than that for which it was collected, it will provide the interested party, prior to said further processing, information on that other purpose and any additional pertinent information.

User consent

The use of ZTALENT is absolutely voluntary and implies full acceptance by the User of the Privacy and Cookies Policy in force at all times that they are on ZTALENT, for which the User must read carefully and accept without any reservations the present Privacy and Cookies Policy before registering on ZTALENT.

• To register as a User on ZTALENT, the User must provide at least his email address and a password.
• To complete the SAP Professional profile, the User must provide their email, name, surname, date of birth, location, languages, experience, fee, education.
• To be part of the Forum, the SAP Professional must provide their name, surname, gender, their province and a nickname.
• The user's profile will be visible to members and customers of our services.
• To register as a Company, at least the following information must be provided: country, user, email, password, name, surname, NIF, company name, commercial name, and CIF.

The User must understand that, by registering on ZTALENT, they accept that the COMPANY use said information in accordance with this Privacy and Cookies Policy and with the Conditions of Use accessible by the User on ZTALENT.

Users who do not register on ZTALENT may continue to access the content that appears on ZTALENT. However, the COMPANY will not be able to provide you with those services for the effective provision of which it is necessary to provide the aforementioned information, being necessary to create an account and provide the requested data in order to contract the corresponding service offered on ZTALENT.

Likewise, the sending of personal data and messages by email, requesting information on the services of ZTALENT, implies the User's consent for their personal data to be used in accordance with the aforementioned purposes and the acceptance of this Privacy and Cookies Policy.

User responsibility

The SAP Professional and / or Company or Company Representative will be responsible for the security of your password. Thus, the SAP Professional and / or Company or Company Representatives should not share their passwords with anyone.

ZTALENT recommends SAP Professional and / or Company Representatives to always disconnect at the end of a session to ensure that other people cannot access their personal data.

Likewise, the User must undertake not to use the services of ZTALENT in a manner contrary to the provisions of current legislation. In this sense, the COMPANY reserves the right to withdraw access to ZTALENT to any User who violates the provisions of this Privacy and Cookies Policy.

Rights of access, rectification, deletion, limitation of treatment, cancellation, portability of data or opposition

The data indicated by the User will be kept as long as the User does not modify them or indicate their elimination by exercising their right.

The User may revoke the consent given at any time and exercise the rights of access, rectification, deletion and opposition, request the limitation of the data in relation to the specific object of treatment, as well as request the portability of their data to another entity.

In this way, Users have the right to (1) access, modify, correct or delete their personal information and (2) close their account, by sending an email to the address info@ztalent.tech indicating name and surname, as well as providing a copy of the applicant's identity document.

In the event that the User requests the removal of ZTALENT and, without prejudice to the data conservation obligations that may be established by current legislation, the COMPANY undertakes to cancel all the User's information, as well as their personal data.

In those cases in which the User has not satisfactorily obtained the exercise of any of the rights mentioned in this clause, he may contact the Spanish Data Protection Agency at the following address. https://www.agpd.es/portalwebAGPD/index-ides-idphp.php

Security measures

The COMPANY undertakes to keep secret the personal data that the User has provided and to adopt all the necessary measures to avoid its alteration, loss and unauthorized treatment or access in accordance with the provisions of current regulations. However, the User must be aware that Internet security measures are not impregnable.

Legal notice

The COMPANY informs the User that they may provide personal information to the competent authorities when required in accordance with current legislation.

Modifications

The COMPANY reserves the right to modify the terms of this Privacy and Cookies Policy and the Conditions of Contract and Use without prior notice. An updated version of the same will be permanently available on ZTALENT. The use of the services and / or simple access to ZTALENT will imply the acceptance of any modification made.

It is recommended to periodically consult the Privacy and Cookies Policy, as well as its modifications.

Transfer of data and communication to third parties

For the correct fulfillment of the services offered through ZTALENT, the COMPANY may communicate the personal data voluntarily provided by the SAP Professionals who own them, to the Companies attached to ZTALENT, or to the Companies that may be adhere to ZTALENT in the future, in addition to other assignments provided for in the Law, in order to carry out the provision of the service offered through ZTALENT.

For this purpose, it will be the responsibility of the Company to duly inform the SAP Professional about its personal data processing policy, and the COMPANY is not responsible for the processing and storage of the SAP Professional's data in the files of such managers with what establishes a commercial relationship, especially with regard to data processing for advertising and commercial prospecting purposes.

Notwithstanding the foregoing, the COMPANY may also process the personal data collected on behalf of the COMPANY responsible for the treatment in order to provide the services offered through ZTALENT and resolve any type of query or incident that may have the SAP Professional.

By accepting the box relating to commercial communications, the SAP Professional accepts that their identification data will be communicated to the Companies so that they can send the SAP Professional commercial or advertising information about their products and services and analyze decision-making to improve the services provided through ZTALENT. The COMPANY will not be in any way responsible for the treatment of the data that the Companies carry out with the aforementioned information.

The User's personal data may also be transferred to various service providers in the event that the transfer and treatment by these third parties is necessary for the development of the services offered through ZTALENT. In this sense, the User consents to the possible international transfer of data to companies that are outside the territory of the European Economic Area (EEA) that require access to the User's personal data in order to provide the service according to the purposes that are indicated in this Privacy and Cookies Policy.

The COMPANY informs the User that it uses the Google Analytics services that allow quantifying the number of users of ZTALENT and thus carry out the statistical measurement and analysis of the use and activity made by the Users, as well as preparing their browsing profiles. in order to make improvements to ZTALENT in accordance with the purposes described in this legal text. In this way, the User's browser automatically sends certain information to the Google group, whose subsidiaries with possible access to the data would be: (i) Google Ireland Limited, with offices at Gordon House, Barrow Street, Dublin 4, Ireland, (ii) Google Asia Pacific Pte. Ltd., with offices at 8 Marina View Asia Square 1 # 30-01 Singapore 018960, or (iii) Google Inc., with offices at 1600 Amphitheater Parkway, Mountain View, California 94043.

Finally, the User's personal data may be communicated to third parties in the cases that legally correspond, such as for the attention of requirements of public administrations, security forces and bodies and courts and tribunals or consumer arbitration tribunals, as well as consumer and user associations in case of controversy and any other third parties to whom, by virtue of the applicable regulations, it is necessary to carry out the transfer of data.

The User expressly accepts the transfer of personal data that is collected here, in accordance with the provisions of current legislation and with the sole purpose of providing the service contracted on ZTALENT.