PRIVACY POLICY

1. CONTACT DETAILS OF THE DATA CONTROLLER

• Corporate name: TWO MOONS MEDIA SRL
• Registration number: 39017431 and J16/560/13.03.2018
• Registered office: Craiova, bld. 1 Mai nr. 104, scara 1, etaj 1, apt. 2, Dolj, 200301, Romania
• Email address: [email protected]

2. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)

Mr. Martin López Escartín, attorney of the Illustrious Bar Association of Madrid (ICAM) number 103.516 with professional office for notification purposes at HONOS ABOGADOS S.L.P. located at C/ Langreo nº2, 1ºD, Gijón, CP 33.206 Asturias. Telephone: (+34) 608 781 399, Email: [email protected]

3. INFORMATION ABOUT DATA PROCESSING ACTIVITIES CARRIED OUT ON OUR WEBSITE

The acceptance of the terms and conditions established on the website by registered members entails acceptance of the privacy policy and all legal consequences related to compliance with current data protection regulations.

However, consent for these purposes must be given individually and expressly.

Our organization respects and complies with the fundamental rights to personal data protection (ex. Art. 18.4 CE) and personal privacy (ex Art.18.1 CE). We protect our users' personal data in a responsible and proactive manner.

Personal data belongs to each individual person. When you provide it to our organization, you are entrusting it to us, and our commitment is to process it lawfully, fairly and transparently, and above all, confidentially.

We process your data under equal treatment, without any discrimination or distinction based on race, color, sex, language, religion, political opinion, national or social origin, economic position, birth or any other personal or social condition; and without distinction of legal or international status of the country or territory under whose jurisdiction you fall.

At TWO MOONS MEDIA SRL, we provide and guarantee you access to and control of your personal data at all times.

Before providing any personal data, persons accessing our website must carefully read and understand the following in order for the processing to be LAWFUL, FAIR AND TRANSPARENT. Additionally, they must be of legal age, which in Spain means being at least 18 years old.

With the objective of creating a safe online environment for everyone, we have created the private initiative Padresprotegen.com, an educational project where we share educational content, guides and advice so that parents and guardians can establish controls and block access to inappropriate material. In this way, we complement the content that the AEPD offers regarding child protection.

We care about privacy and responsible access to our websites. If you notice any error or have suggestions, please do not hesitate to contact us at [email protected].

You authorize (in cases where it is through your consent), or through other legal bases (contracts) the entity TWO MOONS MEDIA SRL with registered office at Craiova, bld. 1 Mai nr. 104, scara 1, etaj 1, apt. 2, Dolj, 200301, Romania to collect and process personal data for the following:

PURPOSES:

• COOKIE Registration: This shall be governed through the cookie policy, whereby through "non-necessary" cookies, monitoring of your internet activity may be carried out and additional details about navigation on our websites may be obtained.
• Management of IP access addresses: For the purpose of enabling navigation and safeguarding the security of our website. They are simply collected, anonymized, and finally archived.

LEGAL BASIS FOR EACH PROCESSING ACTIVITY:

• Management of data entered in collection forms for REGISTERED MEMBER Registration: Royal Decree-Law 1/2007 of November 16 applies, whereby through payment via the service provider entity, the client becomes party to a DISTANCE SALES CONTRACT FOR OUR SERVICES.
• COOKIE Registration: "NON-NECESSARY" cookies, through CONSENT. This is granted through acceptance or customization of the same, or alternatively, their rejection.
• Management of CURRICULUM VITAE through the "Want to be a Webcammer" form. The legal basis relies on the consent collected when submitting the form with the requested data.

Likewise, IN ACCORDANCE WITH ARTICLES 12 AND 13 OF THE GDPR, we inform you through this table about the specifications of all data processing activities we carry out through different forms, as well as the collection of IP data and cookies.

There is differentiated processing between unregistered users, from whom no personal data is requested, versus registered members, where it is necessary for them to provide basic personal data for identification purposes, and where they must also provide their bank card details for the purpose of processing payments for the services they have accessed.

Consequently, registering on the website in the MEMBERS section implies that you will first be asked for the personal data necessary for user identification. Additionally, bank card details are required, which will be expressly transferred to COMMERCE GATE with the user's consent, and such transfer is necessary for the purpose of processing the sales contract in its "terms and conditions" section. For such purposes, Article 13 of the GDPR is complied with, in order to guarantee the principles of fairness and transparency by providing the user with necessary information in their relationship with the data controller when purchasing any of our services offered on the website.

Purchases refer to those made through the websites as a result of services accessed by the registered member.

This data protection policy may be modified due to possible legislative, jurisprudential changes or changes in criteria followed by the Spanish Data Protection Agency and/or the competent authority at any given time. Therefore, TWO MOONS MEDIA SRL reserves the right to modify this legal notice to adapt it to legislative or jurisprudential developments or those established by the Regulator, which are in force at the precise moment when the websites are accessed, as well as those motivated by industry practices. We ask you to review this legal notice and privacy policy periodically.

For these purposes, reference should be made to the Processing Activities Record relating to Registered Members.

4. RIGHTS RECOGNIZED BY EU REGULATION 2016/679 AND LO 3/2018

• Right to request access to personal data: you may request from TWO MOONS MEDIA SRL whether we process your data, and specifically what data is being processed under the terms provided in Article 15 of the GDPR, and other concordant provisions.
• Right to request rectification, provided they are incorrectly collected or have undergone some modification (art. 16 GDPR).
• Right to request erasure and, where applicable, the right to be forgotten, when the data is not necessary for the purpose for which it was initially collected, or when the data subject deems it necessary (art. 17 GDPR).
• Right to request restriction of processing: in certain cases you may request to temporarily suspend data processing or that it be retained for longer than necessary when required (art.18 GDPR).
• Right to object to processing: we will stop processing your data, except for legal reasons (art. 21 GDPR).
• Right to data portability: you may request at any time that we send your data to the company you wish, through express request (art. 20 GDPR).
• Right to opt out of advertising: at any time you may communicate your desire not to receive advertising from our company by sending us an email.
• Any other right provided for in Community or national regulations on personal data protection.

HOW CAN I EXERCISE MY RIGHTS?

TWO MOONS MEDIA SRL has informed all its employees about the procedure for handling data subjects' rights; we have defined a protocol to respond to all rights exercises. You may send your rights exercise request to the email address [email protected] or by postal mail to our address indicated in the header of this privacy policy. We ask that you always consider the following when exercising these rights:

• The holders of personal data (data subjects) may exercise the rights recognized in Regulation 679/2016 and in LO 3/2018 of December 5. The exercise of rights is free of charge.
• The data controller must respond to data subjects without undue delay and in a concise, transparent, intelligible manner, using clear and simple language and must retain proof of compliance with the duty to respond to rights exercise requests submitted.
• If the request is submitted by electronic means, the information shall be provided by these means when possible, unless the data subject requests otherwise.
• Requests must be responded to within 1 month from receipt, which may be extended exceptionally for an additional month, taking into account the complexity or number of requests, but in that case the data subject must be informed of the extension within one month of receipt of the request, indicating the reasons for the delay.
• In any case, the user and/or data holder may file a complaint with the AEPD if they deem it appropriate at C/ Jorge Juan nº6 in Madrid. (www.aepd.es)

5. BASIC PRINCIPLES GOVERNING OUR PRIVACY POLICY

• All processing carried out on our website complies with and is governed by the principles set forth in Article 5 of the GDPR, with said principles being drafted so that they can be understood and comprehended by all persons who interact with this website. If you have any doubts about their complexity, please do not hesitate to contact us for clarification.

1. CONFIDENTIALITY

All personal data provided through electronic forms will be processed according to current regulations on personal data protection, and will in all cases be confidential for all TWO MOONS MEDIA SRL personnel who handle such information. In compliance with the proactivity obligation, all Company personnel are expressly trained in compliance with current legislation. In this regard, the data controller provides them with a welcome pack containing all information about data processing and rules for ensuring data security. Additionally, confidentiality agreements are signed with employees and collaborators, and with companies that provide us services and have access to or process data from the data controller, a data processor contract is established under the terms provided in Article 28 of the GDPR.

2. INFORMATION ABOUT DATA PROTECTION PRINCIPLES AND OUR DATA PROCESSING

PURPOSE LIMITATION
All processing described in this Privacy Policy is carried out through our website. Personal data is processed solely and exclusively for the purposes stated herein.

STORAGE LIMITATION
As can be observed in the table regarding data processing, all personal data has a maximum processing time. We have verification, destruction and secure erasure protocols for data that is no longer used because it has fulfilled the purpose for which it was collected, or when the right to erasure has been exercised.

INTEGRITY AND CONFIDENTIALITY OF DATA
In section 2.1 we refer to the importance that TWO MOONS MEDIA SRL places on the data we process being completely confidential. With policies and protocols that ensure the data we process is handled applying all necessary and sufficient protection measures to guarantee the integrity and security of personal data being processed. It is also important to emphasize that employees are properly trained to act in their protection proactively, and periodic controls are carried out to verify that our measures function adequately.

DATA MINIMIZATION
In all processing we carry out, we consider the principle of data minimization, processing only the data that is necessary and essential to provide you with our services.

CONSENT-BASED PROCESSING AND ITS REVOCATION
When the legal basis for processing is based on the consent of the personal data holder, such consent may be revoked at any time by sending an email to our entity at the following email address: [email protected] .

FILING A COMPLAINT WITH THE SUPERVISORY AUTHORITY
The registered member may file a complaint at any time with the supervisory authority (AEPD), located at Calle de Jorge Juan number 6, CP 28001 Madrid (www.aepd.es).