We may use your personal data for the following purposes, and on the following lawful bases:

• To enter into a contract with you.
• When you give your consent to the processing of your personal data.
• When we need to process your personal data to comply with a legal or regulatory obligation.
• When necessary for our legitimate interest or that of a third party.

Where you give your consent to our processing of your personal data, you may withdraw that consent at any time by sending an email to support@asafedigital.com or by consulting the section on the exercise of rights below. Please note that once you have given your consent, it may take a short period for us to cease processing.

The table below explains all of the ways we may use your personal data and the lawful basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

In some cases, we may process your personal data on an additional lawful basis. If you need more information, you can send an email to support@asafedigital.com

Changes in Purpose: We will only use your data for the purposes for which we collected it, unless we reasonably believe that we should use it for another reason, or we notify you in advance so that you are informed of the legal reason for its processing and provided that the purpose is compatible with the original purpose.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.

We do not authorise people out of legal age to provide their personal data through the means enabled on this website (completion of web forms contact or by sending emails). Therefore, the people who provide personal data using these means formally declare to be over legal age, leaving us exempt from any responsibility for the breach of this requirement.

If your child is under the established age limit and has provided personal information to us, please contact us to request the exercise of your applicable rights.

How to exercise these rights? You may send a communication to the registered office of Fathom 3 Dev S.L. or email support@asafedigital.com, including in both cases, a photocopy of your ID or other similar identification documents. Users can request the exercise of the following rights:

• Access to your personal data: you can ask Fathom 3 Dev S.L. if they are using your personal data.
• To request data is rectified if incorrect.
• To exercise the “right to be forgotten” with respect personal data.
• To request the restriction of processing.
• Object to processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedom. You also have the right to object where we are processing your personal data for direct marketing purposes.
• To the portability of the data: in case you want your data to be processed by another company, Fathom 3 Dev S.L., will facilitate the portability of your data to the new person in charge.
• To withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. We will ask you for specific information to help us confirm your identity and ensure your right to access your personal data (or exercise any other of the rights mentioned above). This is a security measure to ensure that personal data is not disclosed to any person who is not entitled to receive it. We try to respond to all legitimate requests within one month. However, it can take us more than a month if your application is particularly complex. In this case, we will notify you and keep you updated.

We may share your personal data with the parties set out below for the purposes set out in this Policy:

• Service providers that provide systems administration and information technology services.
• Professional advisors including lawyers, auditors and insurers who provide banking, legal, insurance and accounting consulting services.
• Other companies in our corporate group.
• Recruitment management platforms.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• HM Revenue & Customs, regulators, courts and other authorities. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only allow such processors to process your data for specific purposes and in accordance with our instructions. However, in compliance with transparency, you can request a list of who the companies that provide services to us are, you can do so by emailing support@asafedigital.com.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, modified or disclosed. In addition, we limit access to your personal data to those employees, contractor agents and other third parties who have a business need to know such data. They will only process your personal data on our instructions and will be subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If you do not agree with the way us processes your personal data, you can contact us by sending an email to support@asafedigital.com or by contacting directly to the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD, in Spanish) here (www.aepd.es.).