The purpose of this policy is to inform interested parties about the various data processing activities carried out by this organization through its website, which may affect their personal data, in accordance with the provisions of Organic Law 3/2018 of December 5th, on Personal Data Protection and the guarantee of digital rights, and Regulation (EU) 2016/679 of the European Parliament and Council of April 27th, 2016.

IDENTIFICATION AND CONTACT DETAILS OF THE CONTROLLERS Guillermo Ortega Atienza and Carminys Guzman Jumelles, email: academy@operary.com.

PURPOSES OF PROCESSING YOUR PERSONAL DATA USERS/BROWSERS OF THE WEBSITE OF THE CONTROLLER We will process the personal data you provide through our web forms for the following purposes:

• To respond to requests, complaints, and incidents submitted through our contact channels on the website.
• To understand user behavior on the website in order to detect possible cyberattacks.
• To comply with the legal obligations that directly apply to us and regulate our activities.
• To protect and exercise our rights or respond to claims of any kind.
• If applicable, to send commercial communications related to the goods or services we offer and/or news or bulletins related to our sector.
• To manage, administer, and supervise your activity on the blog/forum incorporated into the website.

LEGAL BASIS FOR PROCESSING USERS/BROWSERS OF THE WEBSITE OF THE CONTROLLER

• Your consent, which you have provided to us for processing your data for the stated purposes. Refusing to provide your personal data will make it impossible to process your data for the mentioned purposes.
• To comply with the legal obligations that apply to us. In this case, you cannot refuse the processing of your personal data.
• Our legitimate interest in protecting our image, business, and track record by preventing attacks on our website. In this case, you cannot refuse the processing of your personal data, although you may exercise the rights recognized in the eighth section of this policy.

DATA RETENTION PERIODS OR CRITERIA The personal data provided will be kept for as long as necessary to fulfill the purposes for which they were initially collected.

Once the data is no longer necessary for the relevant processing, it will be properly blocked and made available to the competent Public Administrations, Courts, and Tribunals, or the Public Prosecutor's Office, in compliance with the statute of limitations for any actions that may arise from the relationship with the client and/or the legally established retention periods.

AUTOMATED DECISIONS AND PROFILING The website does not make automated decisions or create profiles.

RECIPIENTS During the processing of your personal data, the organization may share your data with the following recipients:

• Judges and Courts.
• Law Enforcement Agencies.
• Other competent public authorities or bodies, when the controller is legally obligated to provide personal data.
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INTERNATIONAL DATA TRANSFERS The organization does not carry out any international data transfers.

RIGHTS Interested parties may exercise, at any time and completely free of charge, their rights of access, rectification, and deletion of their data, as well as request the limitation of the processing of their personal data, object to it, request the portability of their data (where technically feasible), or withdraw the consent given. They may also object to being subject to an automated decision, including profiling.

To do so, you may use the forms provided by the organization or write to the postal or email address mentioned above. In any case, your request must be accompanied by a photocopy of your ID card or equivalent document to verify your identity.

If you feel that your rights regarding the protection of your personal data have been violated, particularly if you have not been satisfied with the exercise of your rights, you may file a complaint with the competent Data Protection Authority.

In compliance with Article 21 of Law 34/2002 on Information Society Services and Electronic Commerce, if you no longer wish to receive information about our services, you may unsubscribe by sending an email to admin@operary.com with the subject "UNSUBSCRIBE," or by clicking on the "unsubscribe" link in the email.

ACCURACY OF DATA The interested party guarantees that the data provided is true, accurate, complete, and up-to-date, and is responsible for informing the organization of any changes through the channels provided and indicated in the first section of this policy. The interested party will be responsible for any direct or indirect damages or harm that may result from non-compliance with this obligation.

If the user provides data from third parties, they declare that they have the consent of the interested parties and agree to pass on the information contained in this clause to them, releasing the organization from any responsibility for non-compliance with this obligation.

Last Review: September 2, 2024