PRIVACY AND COOKIES POLICY

Auctane, S.L.U. (“PACKLINK”) respects your privacy and is committed to protecting your personal data. This privacy and cookies policy (this “Policy”) will inform you about how we protect your personal data when you visit our website (from anywhere) and about privacy rights and how they are legally protected.

In this Policy, we explain how your personal information is acquired and used. We are PACKLINK and we exercise the appropriate information controls in accordance with the provisions of the EU Data Protection Directive (EU 95/46/EC) and its development regulations established in the General Data Protection Regulation (GDPR-EU General Data Protection Regulation).

At the end of the text you will find how to contact us if you have any questions about data privacy and protection.

We must have a legal basis to process your personal data and this Policy explains how we act lawfully with respect to each one of the purposes for which your information is held and used. In general, we are authorised to process your personal information where necessary, in connection with a contract between us (such as, for example, a contract to supply our products or provide our services), to comply with our legal obligations or if we have a legitimate interest, with your interests as a customer prevailing. Please, keep in mind that the access links from our website could lead you to access external websites that are not covered by this Policy. We recommend that you read the privacy policies form third parties before submitting personal information. PACKLINK shall not be responsible for content, function or data gathering from external websites.

What information do we collect and how do we collect it?

You are not obligated, by law or by contract with us, to facilitate personal information through our website. It will only be required when it is strictly necessary with the purpose of supplying a product or lending a service requested by you.

What information do you provide to us?

Information can be requested under the following circumstances that are detailed below:

• When our services are requested.
• Using and browsing our website.
• Telephone calls, email correspondence or publications.
• Requesting or applying for a job.

This information would include the following data:

• Identification, such as your complete name, your job position and company, in the case that you are self-employed.
• Mailing address, email address and telephone number.
• Other relevant information in order to use our website and services, such as preferences, studies, answers and opinions at the marketing level.
• Information about your shipment, including recipient or sender data, in the case that they are different from you.
• Fiscal information for issuing invoices.
• Payment information (this information is protected and processed by our payment provider).
• Regarding job applications, your CV including information about your education, job and career path, as well as any other information present on the CV.

Information that we acquire about you through our website

We acquire information through cookies and similar technologies that help us to identify and differentiate you from other users on our website. These resources will optimise your online experience by not having to fill in information that has already been requested, and it allows us to make improvements on our website. For more information on this matter, as well as the use of cookies, please consult the corresponding section in the COOKIES policy that you will find at the end of this document. When you visit our website, we may collect the following information:

• Information about the User Agent (electronic device) provided by your internet browser.
• If you access through a third party, this information will be registered.
• If you associate your account with a third party, such as a Marketplace to import articles for shipping, the necessary data will be registered for easy access.
• Device identification (cookie or IP address) and general location to prevent fraud.
• Data about visits to our website and sources accessed, including but not limited to websites, links, traffic information, location, weblogs and other communication data.
• When orders originate through advertising sources, the source of each order will be recorded. The goal is to analyse the effectiveness of that advertisement; this information will not be used to study the customer profile.
• Our website is not directed towards minors and data is not knowingly collected from them.

Information that we acquire about you through other sources

If you are applying for a job, your criminal record may be requested through an authorised agency. The content that you have publicly shared may also be displayed, including on social media.

This list is not restrictive and at higher levels, additional information could be acquired to satisfy the purposes set forth in this Policy and always within the data categories already mentioned.

Information that we receive about you from other sources

It is possible that you have allowed other websites, services or third parties to share your data with us. Including information that we receive about you, whether you have used other websites with which we do business or other services that we offer.

It also includes information facilitated by third parties with which we work and to which we provide our products and services, such as a Marketplace, Ecommerce platforms, payment platforms, transport companies, technological support companies and advertising companies.

How do we use your personal data?

Legal basis for the use of your personal data

We guarantee that the use of your personal data is covered by the GDPR (General Data Protection Regulation)

1. Development of the contract established with you.
2. Compliance with legal obligations.
3. Achievement of our legal interests or those of third parties. Your interests will prevail over ours.

How is your data used on a legal basis?

Below, the different uses of your personal data are established, which may occur within each of the legal frameworks:

1.-Development of the contract established with you. Verification of your identity.

• Your data may be used if it is absolutely necessary with the purpose of complying with our legal obligations or to detect and prevent fraud, money laundering or other crimes.
• Providing our products and services (Additional supervision).

The use of your personal data is required to comply with the established contracts, such as, for example, in the case that you are registered as a customer. Your personal data will always be used within this context.

• To provide you with information about the contract with us.
• To provide you with information about our products and services related to your personal requests (for example, transport requirements and associated services, such as cargo insurance).
• Verification of your identity
• Handling of claims that, as a consequence, require reparations or improvements to our products and services.
• To contact you; to inform you about the changes that may be made to our products and services.

To Manage our website, including troubleshooting, situational diagnostics, statistical analysis, targeted searches and tests with the purpose of making our website secure.

If you register an account with PACKLINK, we can use the telephone number that you have given us to provide you with specific information that we believe may be helpful to you when using your account. We emphasise that calls made to/from PACKLINK may be recorded and stored using technology from a third party with the purpose of monitoring and training. Once these purposes have been accomplished, the recordings will be deleted.

If you apply for a job or request information, it will be necessary for us to use your personal data as part of the selection process, with the objective of establishing your aptitude for the position you applied for.

2.- The use of your personal data to comply with our legal obligations To comply with our Terms and Conditions and other policies. Logistics Management and Planning, including Accounting and Auditing. Management of legal disputes to which you are a party. Detection and Prevention of Fraud, money laundering and other crimes. Protection of the user and others from possible harm. Your personal data may be used when strictly necessary with the purpose of protecting your interests or the interests of others. Including crimes such as identity theft, piracy or fraud.

3.- The use of your personal data in pursuit of our legitimate interests a. To contact you in order to promote products or services which may be of your interest. Your personal data may be used to identify you and inform you about our products and services that may be of your interest. The request to receive promotional emails or calls from PACKLINK is voluntary, you are able to request both, neither, one or the other. Your request will not affect the rest of the products and services that you have contracted with us or that you are going to contract in the future. In case you do not want to keep receiving these emails, you may unsubscribe through the link included at the end of all the promotional emails sent by Packlink. All of the information related to preference management can be found in our Help Center.

b. To contact you in order to communicate important changes that may affect you or to verify or update certain information. On some occasions, we could use your personal data to answer your requests or to inform you of important changes. We will only use your personal data when it is strictly necessary, such as:

• To interact and answer the requests you have sent us, or any publication on social media where you have tagged us.
• To inform you about important changes in our company or our policies.
• To verify or update any important information, such as, for example, your bank details if the direct debit payment method has been agreed upon (bank receipt), or in the case that you have contracted cash on delivery.

c. To answer the communications you send us Including calls, emails, real time chats, publications and messages on social media.

d. To improve the operation of our company With the purpose of offering the best products, experiences and services, we may use your personal data in the following cases:

• To check and improve the existing products and services and develop new products and services.
• To check and improve our operating systems, processes and personnel, including training.
• To improve our site to ensure that the content is presented in the most effective way for you and your electronic device.
• To measure and understand the effectiveness of the advertising we offer to you and others, and to reach you with dedicated and relevant advertising.
• For market studies of our products with the purpose of improving them. Third party information processors may be used to carry out the studies.

e. To fulfil our obligations to third parties We may transfer data to third parties for the purpose of fulfilling our contractual obligations to the third party that may affect you (for example, when we have an affiliate contact with such third party and the third party has referred your data to us or you have registered on our platform through an affiliate link linked to such third party).

In any case, Packlink will ensure that only the minimum data required to fulfil its obligations will be transferred. Transfer data to the parent company of the group in order to ensure the proper functioning and fulfilment of the obligations of the business group to which we belong.

You can find out more about these potential transfers by exercising your rights as set out in the following sections.

4.- Use of your personal data after you have given us your consent:

a. Contacting you to promote Packlink or third party products or services that are not covered by our legitimate interest.

b. Transfer your data to other entities of the business group to which Packlink belongs so that they can send you offers of their own products and services that may be of interest to you. You can find out about the companies in the business group to which we may transfer data for these advertising purposes here.

Modification of Intention

We will only and exclusively use your personal data for the aforementioned purposes, unless it is reasonably considered that they should be used for another reason that is compatible with the original objectives. If your personal data needed to be used for unrelated purposes, you would be notified and the legal basis that allows the aforementioned modification would be explained to you.

Please, keep in mind that we may process your personal data without your knowledge or consent, protected by the rules described above, always found within the legal framework.

Who do we share your personal data with?

How do we share your personal data within our company?

We share the data you have provided with our personnel so that we can provide you with our products and services.

How do we share your personal data with third parties?

We may share your personal data with certain service providers for the previously indicated purposes. For example:

• Internet Hosting Providers that we work with to maintain our website, infrastructures, services and applications.
• Contact management systems for sending emails, instant messages, social media messages and SMS.
• Providers that manage the customer opinions about our products and services. We work with third parties that act as data processors, with the purpose of acquiring opinions, assessments and comments from customers who have bought our services through one of our websites.

In addition, we also may share data with certain independent third parties, as long as its necessary in order to provide you with the service, to comply with a legal obligation or is based on the legitimate interest of Packlink. For example:

1. Carriers to supply merchandise transport services
2. If requested by the State Security Forces and Corps, in compliance with investigation and judicial processes.
3. For the Security and protection of our employees, property or public property.
4. Prevention or detection of crime, including the exchange of information with other companies or organisations for cases of fraud prevention and credit risk reduction.
5. Third parties to whom it is necessary to transfer data for the fulfilment of obligations arising from a contract with the same.
6. To the business group to which Packlink belongs in order to guarantee the correct operation and fulfilment of its obligations.
7. As part of a merger, sale of a business or assets. Should this be the case, the information would be shared with the interested buyer-seller in case it is necessary in order to close the business transaction or if it is necessary to report the state of the company to said buyer. In addition, if the purchase comes to fruition in the end, this information would be reported to the buyer that would act as the head, or part, of the group to which Packlink would belong.

How long do we keep your personal information?

Your information will be kept for the necessary time and until the purposes for which it was acquired are achieved. In the case of facilitation a service, the information will be stored until the service is completed.

If you are applying for a job or you send us your CV, we will keep your CV and the rest of the data related to the selection process, for a period of 24 months. If, on the other hand, your application is considered for a certain job, we would have your information for a longer period of time.

In all other cases, we would keep your personal data until your account has been settled, the claims or legal disputes have been resolved, if they exist, and there is no risk of fraudulent activity. If your data is deleted, your account would become inactive, unless you are an individual, in which case your data and account will be completely deleted

How do we protect your personal data?

All of the necessary precautions are taken so that your personal data is treated securely in accordance with this Policy.

We ensure that all of the information you give us is transferred securely through our website, but we must take into account that the transmission of information through the internet is not completely secure. Even though all of our resources are aimed at protecting your personal data, it is not possible for us to guarantee the complete security of your information; therefore, any transmission that you make will be your responsibility. Once we have received your information, it will be treated under the strictest security procedures and protocols to avoid unauthorised access.

The information will be stored and processed wherever possible within the EU. In case this is not possible for third parties, remember that the information will be treated according to EU model clauses (Standard contractual clauses that are used in agreements between service providers and their customers to guarantee that all of the data that leaves the European Economic Space is transferred in agreement with the EU Data Protection Law) or under one of the exceptions considered in Article 49 of the General Data Protection Regulation.

All of the information you provide to us is hosted on secure servers managed by third parties. Please, keep in mind that you are responsible for the password we have given you or that you have created to access certain areas of our website. We request that you do not share the password with anyone.

How can you help us keep your personal data safe?

We will take all the reasonable measures to ensure that all of the personal data you provide to us through our website is kept and managed securely. PACKLINK complies with PCI Compliant Protocol, (established to protect the data of credit card holders during and after a financial transaction). The platform uses sophisticated security devices with the purpose of protecting your personal information. You can keep your personal information safe, not only on our website, but when you give your information to other online providers.

Below, we explain some tips on how you can improve the security of your personal information:

1. Use a modern operating system and a secure browser.
2. Make sure that both have the latest security update.
3. Use secure passwords and do not reuse them to access other websites.
4. Do not share your passwords.
5. Stay informed about how “scam” emails work and exercise extreme caution when using your email.
6. Be aware of the risk involved when using public WIFI networks.

What rights do you have regarding your personal data?

You have the right to be informed

We have the legal obligation to provide you with concise, transparent, comprehensible, and easily accessible information about your personal data and its use. We have drawn up this Policy precisely for this reason, but if you have any question or you need more information, you can contact us through the Help Portal

You have the right to access your personal data

You have the right to have us confirm if we keep any of your personal data. If it is still retained, you have the right to a copy of it.

With the purpose of maintaining the security of your data, we will have to verify your identity before providing you with a copy of the information we retain. The first copy you request from us will be free. If you require more copies, we could charge you an administrative fee in order to cover our costs.

You have the right to correct any incorrect/incomplete information in your personal data.

If you have requested a copy of your personal information, you may notice an error or inaccuracy or simply find it incomplete. In this case, you can contact us and we will correct/include the requested information.

You have the right to unregister

On occasions, we will no longer need to keep your personal data:

1. The information is no longer needed for the purpose for which it was stored.
2. You present your lack of consent for the retention of your data and we do not have any legal reason to keep using it.
3. You do not agree that we should continue using your personal data and we do not have any reason to keep it.
4. We have used your data illegally.
5. We have received legal notification that requires us to delete your personal data.

In the aforementioned situations, you have the right to request the deletion of your personal data. If you believe that you are in one of these cases, please send an email to privacy@packlink.com.

You have the right to request a copy of the information to be transferred to you or to a third party in a compatible format.

In the same way, you have the right to acquire a copy of the personal data that you have provided us on the basis of a contract or your consent for personal reasons. This right entitles you to move, copy or transfer your personal data more easily from one IT system to another, securely. If you need to transfer a copy of your personal data to another organisation in an authorised and computer-readable form, please contact us. This process is free.

You have the right to opt out of Direct Marketing

At any moment you can communicate to us that you prefer that your personal data is not used for Direct Marketing. If you do not wish to receive any communication in this respect, you can request it in the following way: At the end of any email from Marketing, you will find a link where you can request this. Or you can also send an email to privacy@packlink.com

You have the right to request that we stop using your personal data for our legitimate interests

Sometimes, we use your personal data to reach objectives that benefit us as much as you: When we inform you about products or services that are similar to those you have been using. When we use your data to improve the operations of our company.

When we contact you to inform you about important changes. Our objective is that your rights and personal data are properly protected. If you think we are using your personal data in an unjustified way and your rights are being violated, you have the right to present a claim. Unless there is a cause of force majeure, we will not continue to use your personal data.

With the purpose of exercising your right over the use of your personal data, please send an email to privacy@packlink.com.

You have the right to restrict the use of your personal data

You have the right to request that we do not use your personal data, just that we keep a copy. This right can be exercised in the following circumstances: You have communicated that the information that we hold is inaccurate and we have not been able to verify it yet. You have communicated that you did not agree to use your information for the pursuit of our legitimate interests and we are evaluating your claim.

We have used your data illegally but you do not want us to delete your data.

We do not need to use your personal data anymore, but you need us to keep a copy for an existing legal claim. If you understand you are in one of these situations, please send an email to privacy@packlink.com You have rights regarding the automated decisions that determine the user’s profile/identification Any automated decision is merely used with the purpose of personalising the information we provide to you. We do not use this format to make decisions that have a legal effect or that affect you in a significant way, and you have the right to not be subject to such decisions. If you have any questions or concerns about this right, please send an email to privacy@packlink.com

Third Party Access

You will see that there are access links to third party sites on our website. Third party websites usually have their own privacy policies and we recommend that you look at them. PACKLINK is not responsible for third party policies and does not have control over them.

INFORMATION ABOUT COOKIES

PACKLINK on its own account or on behalf of third parties that are contracted to provide measurement services, may use cookies and other similar storage and data recuperation mechanisms on terminal equipment (from here on out, “Cookies”) when the User browses the website with the purpose of permitting and facilitating the interaction of the user with said website. The statistical services –our own or others–, employed by the website may use Cookies with the purpose of establishing metrics and patterns of use of the website.

The access, use and in general, browsing on the website necessarily implies the user’s consent to the use of Cookies on the part of PACKLINK and/or its service providers.

Through the use of cookies, it is also possible that the server on which the site is hosted may recognise the Web browser used by the user. This is with the purpose of ensuring that browsing is as simple as possible, allowing, for example, for access of previously registered users to the areas, services, promotions or competitions reserved exclusively for the latter, without needing to register upon each visit. They are also used to measure the audience and traffic parameters as well as to monitor the progress and number of entries.

What are cookies?

A cookie is a file that is downloaded onto your computer when accessing certain websites. Cookies allow a webpage to, among other things, store and retrieve information regarding the browsing habits of the user or their device. Depending on the information the cookies contain, and the way the device is being used, they may be used to recognise the user.

Types of cookies

By domain managing authority

• Own Cookies
• Third Party Cookies

By their length of stay

• Session Cookies
• Persistent Cookies

By their purpose

• Technical Cookies
• Functionality Cookies
• Analysis or Performance Cookies

WHAT TYPES OF COOKIES DOES THIS WEBSITE USE AND WHAT ARE THEIR PURPOSES?

1. Session cookies: These are a type of cookie designed and used to collect and store data while a user is accessing a web page. As their name suggests, these Cookies are stored in the terminal until the user ends the browsing session.
2. Analytical Cookies: These are Cookies processed by us or by third parties, which allow us to quantify the number of users and therefore carry out the measurement and statistical analysis of the use of the offered service by users. For this, your browsing on our website is analysed with the purpose of improving the products and services we offer you.

List of Cookies by issuer:

PACKLINK

_Name of Cookies: dc_gtm_UA-25579227-1

• Issuer website: packlink.es
• Type of cookie: Analytical Cookie
• Description: label management system that allows the tracking of web traffic
• Data storage period: 1 day
• Link to the privacy and cookies policy: https://www.packlink.com/en-GB/privacy-policy/

_Name of Cookies: td

• Issuer website: packlink.es
• Type of cookie: Analytical Cookie
• Description: These cookies record information about your website activity, such as pages you visit.
• Data storage period: 2 years
• Link to the privacy and cookies policy: https://www.packlink.com/en-GB/privacy-policy/

_Name of Cookies: uetevid

• Issuer website: packlink.es
• Type of Cookie: Analytical Cookie
• Description: store and track visits across websites.
• Data storage period: 396 days
• Link to the privacy and cookies policy: https://www.packlink.com/en-GB/privacy-policy/

_Name of Cookies: uetsid

• Issuer website: packlink.es
• Type of cookie: Analytical Cookie
• Description: store and track visits across websites.
• Data storage period: 1 day
• Link to the privacy and cookies policy: https://www.packlink.com/en-GB/privacy-policy/

BING

Name of Cookies: MUID

• Type of cookie: Analytical Cookie
• Description: Web traffic analysis
• Data storage period: 396 days
• Link to the privacy policy: https://privacy.microsoft.com/es-es/privacystatement

GOOGLE ANALYTICS

__Name of Cookies: ga, gid

• Issuer website: google.com
• Type of cookie: Analytical Cookie
• Description: Web traffic analysis / Analysis of visits and source of web traffic.
• Data storage period: 2 years
• Link to the privacy policy: https://policies.google.com/privacy

Who are the recipients of the information? Where are they located?

The information collected through Cookies may be used as much by PACKLINK as by third party collaborating companies, like web analysis operators and agents, for the purposes described in the previous section.

Some of these third parties may be located in third countries whose legislation does not offer an equal level of data protection; however, the user will be able to consult the appropriate guarantees that they offer for international data transfers that are made taking the rights and liberties of the interested parties into account.

The user can learn more about these third parties, as well as the types of Cookies they install, the purposes for which they process data, the guarantees they offer to accomplish international transfers, the retention periods and how they can configure the preferences with respect to them, through their privacy policies. In any case, PACKLINK is not responsible for the accuracy and content of the privacy policies offered by those third parties on their websites.

Management of cookies

Taking into account the information provided through the present Cookies Policy, below we offer information about how you can manage the cookies used on the website through the different options that the common browsers offer (Explorer, Firefox, Chrome, Safari and Opera). In the Help function of most browsers, it will indicate how to configure your browser to not accept Cookies, so that it notifies you each time it receives a new Cookie, as well as how to completely deactivate all Cookies.

For example, you can find information about how to manage your Cookie preferences in the most common browsers through the following links:

• Firefox from [here](https://support.mozilla.org/en-US/kb/third-party-cookies-firefox-tracking-protection"Firefox - cookies").
• Chrome from here.
• Explorer from here.
• Safari from here.
• Opera from here.

If your browser is not found among those we have listed, consult the specific documentation from your browser.

If the installation of Cookies from the webpage is blocked, some functionalities of the same page, such as some content, may be affected.

Additional Information

You can contact PACKLINK through privacy@packlink.com, where you can write to exercise your rights to access, rectification, treatment limitation, opposition, data portability or to not be subject to a decision based solely on automatised treatment, as well as to withdraw the consent given.

Notwithstanding the above, to the extent that the processed information is related only to unique codes or identifiers of devices or browsers used by the user, and is not related to data that directly identifies the user, the previous rights will not be applicable unless the user provides additional information that allows their identification.

Note for ecommerce and marketplace users

Once you have registered as a user on PACKLINK PRO, you can allow us to access your Ecommerce or Marketplace account as long as it is compatible, to download information about merchandise transportation as well as delivery details. This access will only be used if you have given us permission to do so; otherwise we will not have access. Your PACKLINK password and that of your Marketplace or Ecommerce should be different.

Changes in our privacy and cookies policy

Any change that we make in the future will be published on this page and if applicable, we will notify you by email. Please frequently check the updates or changes in our Privacy and Cookies Policy. This version has been updated as of the 2 of February For previous versions please contact us.

Claims

If you wish to make a claim about the collection and use of your personal data, please contact us on the first instance so that we can resolve it. You can submit your claim directly by accessing the Help Portal

Contact

Our Data Protection Representative can be contacted through the email address privacy@packlink.com or through the following mailing address:

Auctane, S.L.U.

Calle Amaltea 9, 3rdFloor

28045 Madrid