LEGAL NOTICE

How do we obtain your data?
- We obtain them directly through our contractual relationship.
- By downloading technical software or technical files available in our website.
- Through your attendance at training courses organised by Sodeca or its collaborators and meetings at sector events and trade fairs, among other legitimate sources.

Who controls your data?
1. The data for correspondence regarding new regulations, new products, events and new developments in the data controller’s sector is SODECA, S.L.U. with company tax code B-08851321
Fiscal address: CTRA. DE BERGA KM. 0.7, 08580 SANT QUIRZE DE BESORA (BARCELONA)
Telephone: +34 93 852 91 11
e-mail: comercial@sodeca.com
2. The data required in order to take action before and after receiving an order, offer a service or execute a contract are controlled by each of the different group companies with which you maintain your contractual relationship:

DECACLIMA COMFORT SOLUTIONS, S.L., with company tax code B-66932138
Fiscal address: Avda. Del Castell 31, 08570 TORELLÓ (BARCELONA)
Telephone: +34 93 013 07 03
e-mail: info@decaclima.com

Which data do we process?
Basic contact data required for identification purposes and in order to execute a contract, offer a service, process an order and perform invoice management.

Why will we use your personal data?
We will process your personal data for one or more of the following purposes:

• To carry out actions on your behalf before an order, offer a service or execute a contract.
• For the purpose of notifying new regulations, new products, events and new developments in the sector.

Are you obliged to provide your personal data?
You are only legally obliged to provide the data needed to issue an invoice. In areas other than the one mentioned above, the provision of personal data is voluntary and not a legal obligation, but is sometimes necessary in order to maintain the contractual relationship.

How can I withdraw my consent?
You may withdraw your consent to process your personal data at any time, with no negative consequences. All you need to do is to send an email or a letter to the contact address of the respective data controller indicated above.

How to contact our personal data protection officer?
You may call them on +34 93 852 91 11 or send an email to comercial@sodeca.com

On what basis will we process your personal data?
The basis for processing the personal data is as following, depending on the activities carried out:

• Conclusion and execution of the contract to offer a service, place an order or purchase a product.
• Compliance with the legal obligation to issue an invoice.
• Communication between the parties during the term the agreed contract is executed.
• In the legitimate interest of the data controller, for the purpose of executing the contract.
• For the purpose of notifying new regulations, new products, events and new developments in the sector.
• For other tasks, in accordance with the consent agreed by both parties.

To whom may we transfer your data and to whom may we not?
We will not transfer your personal data to any third party other than the SODECA group companies mentioned above, or those companies whose services are needed to deal with your request or execute your contract.
What are your rights in relation to the personal data you provide to us?
You have the right to request access to your personal data, to edit them, to delete them or to restrict the processing thereof, with the option of transferring them to another data controller.

For how long do we store your data?
Your personal data will be stored for as long as they are useful and necessary to fulfil your contract with the data controller.

In all cases, even if you request the elimination of your personal data, the controller will have the right to preserve the legal data, duly blocked, for the time necessary to fulfil the applicable obligations, and to make them available to the authorities that are competent in the different matters that apply.

Where can I submit a complaint regarding the processing of my personal data?
Such complains may be lodged with the Inspector General for Personal Data Protection.

I. INTERNAL REPORTING SYSTEM

In compliance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory violations and combating corruption, DECACLIMA COMFORT SOLUTIONS SL hereby records that it has an Internal Reporting System and that the company is the personal data controller in accordance with the provisions set forth in legislation in force on the matter.

For the purpose of strengthening the reporting culture and the integrity infrastructures of said company, and to promote a culture of communication as a mechanism for preventing activities or omissions that could constitute serious or very serious criminal or administrative violations, the company has a Head of the Internal Reporting System (RSII), currently the Group’s Head of Quality.

Said reporting can take place through any of the following means:

• By postal mail to: Calle del Metall 2, Ripoll (Girona), to the attention of the Head of Criminal Compliance and RSII.
• Email: compliance@decaclima.com
• By letter delivered to the Head of Criminal Compliance and RSII.

At the request of the reporting person, communication can also take place through an in person meeting with the RSII within the period of seven days.

Verbal reporting made through an in-person meeting with the RSII must be documented by any of the following ways, subject to the consent of the reporting person:

1. by secure, lasting and accessible recording of the conversation, or
   (*) The reporting person will be cautioned that such communication will be recorded, and they will be informed about the processing of their data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016.
   
2. by a complete and exact transcription of the conversation made by data processing personnel.

Without prejudice to the reporting person’s rights in accordance with regulations on data protection, they will be offered the opportunity to check, correct and accept the transcription of the conversation by signing it.

The Internal Reporting System complies with the requirements of Article 5(2) of the Law of reference:

1. It allows those to whom the law applies to be able to communicate information, by several means, regarding the violations provided for in Article 2 thereof.
2. It is managed securely, consequently guaranteeing that communications can be dealt with effectively at the company, as well as guaranteeing the confidentiality of the identity of the reporting person and of any third party mentioned in any communication and of the actions taken in the management and processing thereof. Moreover, data protection is secure, therefore preventing access by unauthorized personnel.
3. There is a Protocol for the Internal Reporting System, for use of the internal reporting channel and for actions of the Head of the Internal Reporting System, which establishes the guarantees for the protection of reporting persons:
• Proof of receipt within the period of seven calendar days following receipt of a report.
• Maximum period of three months for a response about investigation actions, under the terms of Article 9 of the Law, therefore diligently completing and safeguarding a Reporting Book-Register.
• Possibility of maintaining communication with the reporting person.
• Establishment of the right of the affected person to be informed about the attributed actions or omissions and to be heard.
• Guarantee of confidentiality when a communication might be sent through reporting channels that are not the established ones or might be sent to personnel who are not responsible for processing it, as well as the obligation of the person receiving a communication to immediately send it to the person who is responsible for the System.
• Respect for the presumption of innocence and the right to honour of affected persons.
• Respect for the provisions on Data Protection (Title VI of the Law of reference).
• Commitment to immediately forward information to the Public Prosecutor’s Office whenever the events could be indicative of a crime.

II. PERSONAL DATA PROCESSING

DECACLIMA COMFORT SOLUTIONS SL will, as the data controller, process the personal data included in the communications that are received and that are covered by Law 2/2023 in order to be able to manage such communications and initiate, if applicable, the corresponding investigation procedure. The legal basis of the processing will be compliance with a legal obligation derived from the Law of reference. If the communication contains special data, the legal basis will be the essential public interest and other provisions set forth in section 2 of Article 9(2) of 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.

Your personal data will not be assigned to third parties, barring a legal obligation to do so and except for SODECA HOLDING, for the purpose of processing said communication. Likewise, such personal data may be processed by authorised personnel only whenever it may be necessary for adopting corrective measures at the company or whenever it may be necessary for processing any applicable sanctions or criminal procedures. Personal data will be kept for the essential time that is necessary for deciding about the applicability of initiating an investigation of the reported events. In any case, if this decision is not made within the period of three months, the personal data contained in the communication will be deleted, except for the purpose of maintaining evidence that the system is operating.

Any personal data not deemed to be true will also be deleted, unless such lack of veracity could constitute a criminal offence, in which case the information will be stored for the necessary time during which the court proceeding takes place.

Finally, it is hereby recorded that, at any time, the reporting person can request, from the data controller, access to their personal data, as well as request the rectification or erasure thereof, the restriction of processing, objection to processing and the right to portability of the data by sending a letter, accompanied by a photocopy of their identity document, to the email address of the Data Protection Officer at comercial@sodeca.com or by contacting the same by calling 938529111. If you disagree with the processing of your data, you may lodge a complaint with the Spanish Data Protection Agency, which is the body that holds control authority over the matter, located at C/ Jorge Juan, 6 (28001) Madrid (www.aepd.es).

III. NO RETALIATION

DECACLIMA COMFORT SOLUTIONS SL undertakes not to carry out any acts that could be considered retaliation, including threats or attempts at retaliation against persons who file a communication of information in accordance with the provisions of Law 2/2023, and it undertakes to apply protection measures during the processing of a case with respect to the persons affected by a possible communication.

IV. EXEMPTION AND ATTENUATION OF THE PENALTY

Whenever a person who may have participated in the commission of an administrative violation, object of a communication of information, is the person who reports the existence thereof by submitting a communication, and as long as the communication has been reported prior to having been notified of the initiation of an investigation and penalty procedure, then the body that is responsible for resolving the procedure by a resolution with stated reasons may exempt that person from complying with the corresponding administrative penalty, as long as the points mentioned in Article 40 of the Law of reference are proved.

(*) The Internal Reporting Channel allows anonymous reports to be filed.
(**) However, whenever the internal reporting channel is possible, preference will be given to the use thereof. If the circumstances and the gravity of communications warrant it, a communication may be sent, if applicable, to the Independent Protection Authority of the Reporting Person, to the corresponding regional authorities or bodies, to the Public Prosecutor’s Office or to the European Public Prosecutor’s Office, as appropriate.

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