This is a translation provided for information purposes. In the event of any discrepancy, the Spanish version prevails.

I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, LMGroup (hereinafter also the Website) undertakes to adopt the technical and organisational measures necessary to ensure a level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force on the protection of personal data on the internet. Specifically, it complies with the following rules:

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 and on the free movement of such data (GDPR).

Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).

Spanish Royal Decree 1720/2007 of 21 December approving the Regulations implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).

Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The controller of the personal data collected by LMGroup is Lightning Machining Group, S.L., with tax ID (NIF) B64681844 (hereinafter, the Data Controller). Its contact details are as follows:

Address: C. del Miño, 17, 08223 Terrassa, Barcelona, Spain

Phone: +34 93 783 32 31

Email: info@lmgroup.es

Register of personal data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by LMGroup through the forms on its pages will be incorporated into and processed in our files in order to facilitate, expedite and fulfil the commitments established between LMGroup and the User, to maintain the relationship established in the forms the User completes, or to respond to a request or query from the User. Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is kept which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data is subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018:

Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times, after fully transparent information on the purposes for which the personal data are collected.

Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.

Principle of data minimisation: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.

Principle of accuracy: personal data must be accurate and always kept up to date.

Principle of storage limitation: personal data will only be kept in a form that permits identification of the User for the time necessary for the purposes of the processing.

Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.

Principle of accountability: the Data Controller is responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by LMGroup are identification data only. In no case are special categories of personal data within the meaning of Article 9 of the GDPR processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. LMGroup undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not affect the use of the Website.

Where the User must or may provide data through forms in order to make enquiries, request information or for reasons related to the content of the Website, the User will be informed if completing any of them is mandatory because they are essential for the operation in question.

Purposes of the processing

Personal data are collected and managed by LMGroup in order to facilitate, expedite and fulfil the commitments established between the Website and the User, to maintain the relationship established in the forms the User completes, or to respond to a request or query.

The data may also be used for commercial personalisation, operational and statistical purposes, and for activities within the corporate purpose of LMGroup, as well as for data extraction and storage and marketing studies in order to adapt the Content offered to the User and to improve the quality, operation and browsing of the Website.

When the personal data are obtained, the User will be informed of the specific purpose or purposes of the processing; that is, of the use or uses to be made of the information collected.

Retention periods

Personal data will only be retained for the minimum time necessary for the purposes of the processing and, in any case, only for the following period: 24 months, or until the User requests their erasure.

When the personal data are obtained, the User will be informed of the period for which the personal data will be kept or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, when the personal data are obtained, the User will be informed of the recipients or categories of recipients of the personal data.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018, only persons over 14 years of age may give their consent for the lawful processing of their personal data by LMGroup. In the case of a child under 14, the consent of the parents or guardians is required, and the processing will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

LMGroup undertakes to adopt the technical and organisational measures necessary to ensure a level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, in both directions, is fully encrypted.

However, since LMGroup cannot guarantee that the internet is impregnable or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User may exercise the following rights recognised in the GDPR and in Organic Law 3/2018 against the Data Controller:

Right of access: the right of the User to obtain confirmation as to whether or not LMGroup is processing their personal data and, if so, to obtain information about their specific personal data and the processing that LMGroup has carried out or is carrying out, as well as, among other things, the available information on the origin of the data and the recipients of the communications made or planned.

Right to rectification: the right of the User to have their personal data amended where they are inaccurate or, taking into account the purposes of the processing, incomplete.

Right to erasure («right to be forgotten»): the right of the User, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn consent and there is no other legal basis; the User objects to the processing and there is no other legitimate ground to continue it; the personal data have been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14. In addition to erasing the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable steps to inform controllers who are processing the personal data of the data subject’s request for the erasure of any link to those personal data.

Right to restriction of processing: the right of the User to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data but the User needs them to make claims; and when the User has objected to the processing.

Right to data portability: where processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format and to transmit them to another controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.

Right to object: the right of the User to prevent the processing of their personal data or to have LMGroup cease processing them.

Right not to be subject to a decision based solely on automated processing, including profiling: the right of the User not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

The User may therefore exercise their rights by written communication addressed to the Data Controller with the reference «RGPD-www.lmgroup.es», specifying:

Name and surname of the User and a copy of their ID document. Where representation is permitted, identification of the person representing the User by the same means, together with the document accrediting the representation, will also be required. The photocopy of the ID document may be replaced by any other legally valid means of proving identity.

The request, with the specific reasons for it or the information to which access is sought.

Address for notifications.

Date and signature of the applicant.

Any document supporting the request.

This request and any attached document may be sent to the following address and/or email:

Postal address: C. del Miño, 17, 08223 Terrassa, Barcelona, Spain

Email: info@lmgroup.es

Links to third-party websites

The Website may include hyperlinks or links to websites of third parties other than LMGroup, which are therefore not operated by LMGroup. The owners of those websites have their own data protection policies and are themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es).

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions on the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Data Controller can proceed with it in the manner, for the periods and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

LMGroup reserves the right to modify its Privacy Policy at its own discretion or as a result of a legislative, case-law or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to check this page periodically to keep up to date with the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and to Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.