PRIVACY POLICY

In accordance with Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR”) and the Austrian Data Protection Act (DSG), Inspiralia GmbH processes the Customer’s personal data for the proper performance of the contractual relationship, sends commercial/advertising communications based on the Customer’s commercial profile about products and/or services related to the effectively concluded contracts, as well as about financial services, technical and business consulting services, services of intermediation and commercial development, development of products and technological applications, as well as consulting services and intermediation in the search for financial resources. This processing is legitimized on the basis of the signing of this contract and the legitimate interest of Inspiralia Ltd in maintaining the business relationship. The data will be kept for as long as this relationship lasts and beyond, until the possible liabilities resulting from it have lapsed.In addition, the data of all the signatories of this service and consultancy contract belonging to the Customer (the “Signatories”) may be transferred to other companies of the Inspiralia Group, such as Tecnologías Avanzadas Inspiralia SL, Toro Ventures Financial and Management Services SL, Future Sense SL, Fen Technology Ltd and Inspiralia USA Inc (which in the latter case would constitute an international transfer of its data to the USA). The adequate level of protection is derived from an adequacy decision of the European Commission under Art 45 GDPR. The undersigned may exercise their rights of access, rectification, erasure, opposition, restriction and portability of their data at any time and may request this in writing by sending an email to dach@inspiralia.com. The customer has the right to file a complaint with the Austrian Data Protection Authority (Barichgasse 40-42, 1030 Vienna). (according to §24 para. 1 DSG).

Likewise, during the provision of the services, the parties may have access to personal data for which the Customer is responsible. In this context, with regard to compliance with the regulations on the protection of personal data, Inspiralia GmbH as the data processor, whereby Inspiralia GmbH undertakes to comply with the DSGVO and to ensure that the parties undertake as follows:a) The processing of personal data is carried out exclusively for the purpose of fulfilling the contractual services and adapting to the instructions of the customer.

b) To maintain confidentiality in respect of all personal data to which access is given, this obligation continuing after termination of the contractual relationship for whatever reason, and to ensure that all persons providing services to Inspiralia GmbH have undertaken to comply with this obligation.

c) Ensuring a level of security appropriate to the risk, taking into account the state of the art and its nature, the scope and context, and the purposes of the processing, as well as any risks of likelihood and significance for the rights and freedoms of data subjects for which they must implement appropriate technical and organizational measures. In assessing the adequacy of the level of security, Inspiralia GmbH shall take into account the ability to ensure the continued confidentiality, integrity, availability and resilience of processing systems and services, in particular as a result of the accidental or unlawful destruction, loss or alteration of, or unauthorized disclosure of or access to, personal data transmitted, stored or otherwise processed.

d) not to disclose personal data to third parties (except for the Inspiralia Group companies mentioned in point 1, investors and relevant funding bodies), including for the purpose of onward transfer, and not to disclose it to persons who are not members of the Inspiralia Group without prior written consent. In all cases where Inspiralia GmbH has to assign another service provider to access the data (sub-processor), Inspiralia GmbH has to identify the third party in advance (name, address), and this can only be done with the express prior written consent of the customer.

e) Upon written request of the Data Controller, how to delete or return all personal data to which Inspiralia GmbH had access in order to provide the Service or to fulfill its obligations under this Contract. In this case, Inspiralia GmbH undertakes to destroy all existing copies, except in cases where there is a provision requiring their retention and/or where it proves necessary in order for Inspiralia GmbH to fulfill its contractual obligations and enforce its own contractual claims, in which case retention shall be reasonably limited.

You can reach our data protection officer at:

Michael Schmidbauer

michael.schmidbauer@inspiralia.com

+43 (316) 23 23 232 23