I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of current legislation, NORDIC PAPER IBÉRICA (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it respects the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD).
• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for processing the personal data collected in NORDIC PAPER IBÉRICA is: NORDIC PAPER IBÉRICA SL, with NIF: B62360854 and registered in: Mercantile Registry of Barcelona with the following registry data: Volume 32903, Folio 137, Sheet 221204, whose representative is: Roger Blakstad (hereinafter, Data Controller). Their contact details are as follows:

• Address: Enric Granados 153-155, 1Bis, 1ª

  08008 BARCELONA

• Contact phone: +34 932 720 789
• Contact email: info@nordicpaperiberica.com

Registration of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by NORDIC PAPER IBÉRICA, through the extended forms on its pages, will be incorporated and will be processed in our file in order to be able to facilitate, expedite and comply with the commitments established between NORDIC PAPER IBÉRICA and the User or the maintenance of the relationship established in the forms that the User fills out, or to attend to a request or query from the User. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD is applicable, a record of treatment activities is maintained that specifies, according to its purposes, the treatment activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles contained in article 5 of the RGPD and in article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of the digital rights:

• Principle of legality, loyalty and transparency: the User’s consent will be required at all times prior to completely transparent information on the purposes for which the personal data is collected.
• Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed.
• Accuracy principle: personal data must be exact and always updated.
• Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of its treatment.
• Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.
• Proactive responsibility principle: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data that are treated in NORDIC PAPER IBÉRICA are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

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

The User shall have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions in which the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory. because they are essential for the proper development of the operation performed.

Purposes of the treatment to which the personal data is destined

The personal data is collected and managed by NORDIC PAPER IBÉRICA in order to be able to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend a request or inquiry.

Likewise, the data may be used for a commercial personalization, operational and statistical purpose, and activities of the corporate purpose of NORDIC PAPER IBÉRICA, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected.

Personal data retention periods

Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 6 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipients:

• MONDI PLC, Ground Floor, Building 5, The Heights, Brooklands, Weybridge, Surrey KT13 0NY. United Kingdom and subsidiaries.
• CURIONI SUN TERAMO Via Luigi Cadamosto, 4C 26900 Lodi, Italy

In the event that the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which the transfer is held. intention to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

Respecting the provisions of articles 8 of the RGPD and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the treatment of your personal data lawfully by NORDIC PAPER IBÉRICA. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

NORDIC PAPER IBÉRICA undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent accidental destruction, loss or alteration. or illicit of personal data transmitted, conserved or treated in another way, or the unauthorized communication or access to said data.

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

However, due to the fact that NORDIC PAPER IBÉRICA cannot guarantee the impregnability of the Internet 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 violation of the security of personal data that is likely to entail a high risk for the rights and freedoms of natural persons. Following the provisions of article 4 of the RGPD, a breach of the security of personal data is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

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

Rights derived from the processing of personal data

The User has NORDIC PAPER IBÉRICA and may, therefore, exercise the following rights recognized in the RGPD and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights against the Data Controller :

• Right of access: It is the right of the User to obtain confirmation of whether or not NORDIC PAPER IBÉRICA is treating their personal data and, if so, to obtain information about their specific personal data and the treatment that NORDIC PAPER IBÉRICA has carried out or carries out. , as well as, among others, the information available on the origin of said data and the recipients of the communications made or planned for them.
• Right of rectification: It is the right of the User to modify their personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete.
• Right of deletion (“the right to be forgotten”): It is the User’s right, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when these are no longer necessary for the purposes for which they were collected. or treated; the User has withdrawn their consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any link to those personal data.
• Right to limitation of treatment: It is the User’s right to limit the treatment of their personal data. The User has the right to obtain the limitation of the treatment when he contests the accuracy of his personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.
• Right to data portability: In the event that the treatment is carried out by automated means, the User will have 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. of the treatment. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease the processing thereof by NORDIC PAPER IBÉRICA.
• Right not to be the subject of a decision based solely on automated processing, including profiling: It is the User’s right not to be the subject of an individualized decision based solely on the automated processing of their personal data, including the profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-www.nordicpaperiberica.com”, specifying:

• Name, surnames of the User and copy of the DNI. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other legally valid means that proves identity.
• Request with the specific reasons for the request or information to which you want to access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request made.

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

Postal address: Enric Granados 153-155, 1Bis, 1ª 08008 BARCELONA

Email: info@nordicpaper.com

Links to third party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than NORDIC PAPER IBÉRICA, and therefore are not operated by NORDIC PAPER IBÉRICA. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims before the control authority

In the event that the User considers that there is a problem or infringement of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and is in agreement with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he accepts the processing of his personal data so that the Data Controller can proceed to the same in the form, during the periods and for the indicated purposes. The use of the Website will imply the acceptance of its Privacy Policy.

NORDIC PAPER IBÉRICA reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of 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 April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD) and the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.