CONECTIO COMPASS TERMS AND CONDITIONS

These General Terms and Conditions of Use and Contracting (hereinafter, the "Conditions" or the "Terms") govern the access, installation and use of the Chrome browser extension named "CONECTIO COMPASS" (hereinafter, the "Extension" or the "Solution"), developed and marketed by CONECTIO DIGITAL SOLUTIONS, S.L., with Tax ID (N.I.F.) B19956994 and registered office at Calle Manuel de Falla 13, 4º 2ª, Barcelona, 08034, Spain (hereinafter, "CONECTIO").

The Extension constitutes a SaaS ("Software as a Service") solution aimed at companies and professionals in the human resources field (hereinafter, the "Client"), enabling the analysis of public candidate profiles, the comparison of competencies and the provision of complementary information regarding potential personality traits and suitability for job positions, through the use of AI models.

Access to or installation of the Extension implies the full and unreserved acceptance of these Conditions, which are supplemented by the Privacy Policy, the Cookies Policy and any applicable technical annexes or specific agreements.

The Client declares that it has read, understood and accepted the Conditions in their entirety before using the Solution, undertaking to ensure that its employees, collaborators or authorised users likewise comply with them.

CONECTIO reserves the right to modify these Terms in order to adapt them to legal, technical or business changes, including developments arising from Regulation (EU) 2024/1689 on Artificial Intelligence ("AI Act"), Regulation (EU) 2016/679 (GDPR) and other applicable regulations. New versions will be published on the CONECTIO website and will be applicable from their date of publication.

Use of the Extension after such modifications shall entail express acceptance of the new Conditions. In the event of disagreement with them, the Client must uninstall the Extension and cancel its subscription in accordance with the established procedures.

1. ACCEPTANCE OF THE TERMS AND CONDITIONS

1.1. The installation, access or use of the CONECTIO COMPASS Extension implies the full and unreserved acceptance of these General Terms and Conditions of Use and Contracting.

1.2. The Client expressly acknowledges having read and understood all of the Conditions prior to its acceptance, and that it accepts them on its own behalf and, where applicable, on behalf of the organisation it represents, undertaking to ensure that all authorised personnel (employees, collaborators or assigned users) likewise comply with their provisions.

1.3. Acceptance of the Terms is formalised electronically during the registration, subscription or installation process of the Extension, by ticking the consent box or by any other action implying the use of the Solution (including its download or access to functionalities).

1.4. CONECTIO may require, in certain cases, the express and renewed acceptance of the Terms, particularly when substantial modifications arise from regulatory, technical or business changes.

1.5. The Client acknowledges that the absence of acceptance or the withdrawal of consent shall entail the impossibility of using the Extension or accessing its functionalities.

2. DETAILS OF THE PLATFORM OWNER

In compliance with the duty of information set forth in Article 10 of Ley 34/2002, of 11 July, on Information Society Services and Electronic Commerce (Law 34/2002, LSSI-CE), the details of the Platform's owner are provided below:

● Owner: CONECTIO DIGITAL SOLUTIONS, S.L. (hereinafter, "CONECTIO")

● Tax ID (N.I.F.): B-19.956.994.

● Registered Office: Calle Manuel de Falla 13, 4º 2ª, Barcelona, 08034, Spain.

3. USE OF THE SOLUTION

3.1. The Solution is designed as a support and automated analysis tool in the field of human resources, intended to provide complementary information about professional profiles and their suitability for certain positions, based on legitimately accessible sources (for example, public LinkedIn profiles) and the use of AI models developed by third parties.

3.2. The Client and authorised users shall:

a) Use the Extension diligently and exclusively for the intended purposes, refraining from using it to carry out unlawful, discriminatory activities or activities contrary to the fundamental rights of the persons analysed.

b) Ensure that any information they enter, upload or process through the Solution (for example, job descriptions, candidate data or internal notes) is truthful, lawful and obtained in accordance with Regulation (EU) 2016/679 (GDPR) and other data protection regulations.

c) Inform end users or candidates, where necessary, of the use of AI tools for the automated analysis of their professional data, in accordance with the principles of transparency of the AI Act and the GDPR.

d) Refrain from any attempt to decompile, modify, copy, sublicense, resell or redistribute the Extension, its source code or the results generated by the AI outside the framework authorised by CONECTIO.

e) Adopt the necessary internal measures to prevent unauthorised access and ensure the confidentiality of the access credentials for the assigned licences.

3.3. The Client is solely responsible for the use made by its employees, collaborators or third parties to whom it assigns licences, as well as for the decisions it adopts based, in whole or in part, on the results generated by the AI. Such results are indicative and not determinative in nature, and do not replace human or professional judgement.

3.4. CONECTIO shall not be liable for the interpretations, conclusions or actions that the Client derives from the use of the Solution, nor for any errors, inaccuracies or biases that may arise from the automated processing carried out by the third-party AI models.

4. INTELLECTUAL AND INDUSTRIAL PROPERTY

4.1. The installation and activation of the CONECTIO COMPASS Extension grants the Client a limited, non-exclusive, non-sublicensable, revocable and non-transferable right of use, to access and use the Solution during the term of the subscription contracted, in accordance with these Conditions.

4.2. Each licence or "slot" acquired by the Client confers the right of individual use to a designated user (employee, collaborator or authorised third party), the Client being responsible for the correct allocation and control of such licences.

4.3. The licence is granted for the sole purpose of allowing the Client to use the Extension and its functionalities within the framework of its professional or business activity. Under no circumstances shall the contracting imply the assignment, transfer or waiver of CONECTIO's intellectual property, industrial property or exploitation rights over the Solution or its associated developments.

4.4. The Client may not:

a) Copy, modify, alter, decompile, reverse-engineer, distribute, transmit, reproduce or create derivative works from the Extension or its components.

b) Allow access to or use of the Solution by unauthorised third parties, nor resell, rent, sublicense or assign its licences without the prior written consent of CONECTIO.

c) Use the Extension in a manner that adversely affects its functioning, causes overloads or compromises the security or integrity of the systems of CONECTIO or of third parties.

4.5. CONECTIO shall at all times retain full ownership of the intellectual and industrial property rights over the Extension, the source code, the databases, the algorithms, the user interface, the technical documentation and any other component or development linked to the Solution, as well as over the content and materials made available to the Client.

4.6. The functionalities of the Extension may include access to third-party artificial intelligence models, including ChatGPT-5 (OpenAI) or equivalents. The Client acknowledges that such technologies are provided under their own licences and usage policies, unrelated to CONECTIO, and that their operation, availability or results may depend on factors external to it.

4.7. CONECTIO may, at any time, modify, update or replace the integrated AI models, without this entailing a substantial alteration of the object of the licence, always maintaining an equivalent or higher functional level.

4.8. The use of the Extension and the associated AI models does not confer on the Client any proprietary rights over such models, their training, parameters, data or results, the licence being limited to the right to use them through the interface provided by CONECTIO.

5. SERVICES OF THE SOLUTION

5.1. The CONECTIO COMPASS Extension offers the Client a set of advanced functionalities based on automation and artificial intelligence (AI) technologies, intended to facilitate the identification, analysis and comparison of professional profiles in the field of human resources.

Specifically, the Solution allows:

a) Visualisation and analysis of public profiles from professional platforms (such as LinkedIn), displaying general information about experience, sectors, seniority, languages and other publicly available data.

b) Automated interpretation of potential personality traits and professional style, through the processing of information contained in such profiles, using generative language models developed by third parties.

c) Comparison between candidates and job positions, by cross-referencing information between the Job Descriptions uploaded by the Client and the profiles consulted.

d) Conversational assistance within the HR field, through an AI agent integrated into the Extension that allows queries to be formulated, recommendations to be obtained or automated responses to be generated relating to personnel selection, interviews or competency analysis.

e) Local or temporary management and storage of Job Descriptions or other files uploaded by the Client, in order to reuse them in future searches or comparisons.

5.2. CONECTIO may incorporate new functionalities, modify existing ones or remove those that become obsolete or redundant, without this altering the essential nature of the Solution.

The results generated by the AI are indicative in nature, do not constitute professional advice and cannot be considered binding automated decisions for the purposes of Regulation (EU) 2024/1689 on Artificial Intelligence (AI Act) or Regulation (EU) 2016/679 (GDPR). The Client is responsible for independently assessing and validating the information before making decisions based on it.

5.3. The Client acknowledges and accepts that the service is provided under a SaaS model and depends, in part, on the operation of external services (for example, OpenAI or storage and analytics providers), which may be subject to technical, availability or processing conditions outside CONECTIO's control.

5.4. CONECTIO reserves the right to temporarily interrupt or limit access to the Solution for reasons of maintenance, updating or improvement of the service, informing the Client with as much reasonable notice as possible.

6. FINANCIAL CONDITIONS

6.1. The contracting and use of the CONECTIO COMPASS Extension is carried out through a subscription model that grants the Client access to the Solution and to the licences selected during the registration process.

6.2. The subscription plans, prices, current promotions and functionalities included in each modality shall be available at all times on CONECTIO's official website or in the contracting interface enabled within the Extension itself.

6.3. CONECTIO may update, modify or remove published plans and tariffs, as well as introduce new service levels, subject to prior notice to the Client with a minimum advance of fifteen (15) calendar days before the entry into force of the new prices.

6.4. The Client may contract the Solution in any of the enabled modalities:

• Monthly subscription: with automatic renewal each calendar month, unless previously cancelled.

• Annual subscription: with automatic renewal each calendar year, unless previously cancelled.

Each licence or "slot" is equivalent to an individual right of use of the Extension and may be assigned by the Client to authorised users from its control panel.

6.5. The Client may benefit from a free trial period of fifteen (15) calendar days from the initial activation of the Solution. During such period, no charge will be made to the payment method provided. Once the trial period has elapsed without the Client having cancelled the subscription, the service will be activated automatically and the first charge corresponding to the chosen plan will be made.

6.6. Payment of subscriptions shall be made by bank card or other secure electronic means, managed through third-party payment platforms, subject to their own terms and security policies.

6.7. The Client expressly authorises CONECTIO to carry out the automatic charges corresponding to the contracted modality. In the event of non-payment or transaction error, CONECTIO may temporarily suspend access to the Solution until payment is regularised.

7. INTEGRATION WITH THIRD-PARTY SERVICES AND USE OF ARTIFICIAL INTELLIGENCE

7.1. The CONECTIO COMPASS Extension incorporates components and services provided by third-party technology providers, including OpenAI, which supplies the ChatGPT-5 generative language models, used to generate, process and analyse textual information from the data provided or visualised by the Client.

7.2. The operation of the Solution combines native capabilities of the Google Chrome browser with external artificial intelligence services hosted in the cloud, which process the information provided by the Client to offer results of a descriptive, analytical or predictive nature.

These services may include:

• Natural language processing (NLP).

• Automated text generation.

• Semantic and comparative analysis of profiles.

• Classification or inference of personality traits or professional competencies.

7.3. The results generated by the AI are automatic, probabilistic and non-deterministic, and may contain errors, biases or inaccuracies arising from the model or the source data.

7.4. The Client undertakes to use the Extension responsibly and in accordance with the provisions of Regulation (EU) 2024/1689 of the European Parliament and of the Council, laying down harmonised rules on artificial intelligence (AI Act).

In particular, the Client undertakes to:

• Not use the Solution to generate discriminatory, biased or unlawful profiles.

• Not use the AI to make automated decisions without human intervention where they may affect the rights or interests of third parties.

• Ensure transparency towards users or candidates whose data may be analysed, by informing them of the use of AI-based tools.

7.5. The results generated by the artificial intelligence are purely indicative in nature, and do not replace professional judgement nor constitute conclusive recommendations.

7.6. CONECTIO does not guarantee the accuracy, completeness or suitability of the responses generated by the AI and assumes no liability for the decisions, interpretations or conclusions that the Client derives from such results.

7.7. The Client is solely responsible for the decisions adopted on the basis of the results obtained through the Solution, and must assess by its own means the veracity, coherence and relevance of the information generated.

7.8. The Client acts as Data Controller with regard to the personal data that it decides to process through the Extension, and CONECTIO acts as Data Processor, limited to providing technical and support services based on the documented instructions of the Client. CONECTIO does not determine the purposes or essential means of the processing carried out by the Client.

7.9. It is exclusively for the Client, in its capacity as Data Controller, to determine and document the legal basis applicable to the processing of personal data carried out with the Extension (Art. 6 GDPR), as well as to comply with the principles of lawfulness, fairness, transparency, minimisation and purpose limitation.

8. OBLIGATIONS OF THE CLIENT

8.1. The Client undertakes to use the CONECTIO COMPASS Extension in accordance with the law, good faith and these Conditions.

8.2. The Client shall use the Solution exclusively for the legitimate purposes intended, within the framework of its professional or business activity, and shall refrain from using it for unlawful, fraudulent, discriminatory purposes or purposes contrary to the rights of third parties.

8.3. The use of the Extension is prohibited for:

• Drawing up profiles or analyses based on sensitive or protected characteristics (ethnic origin, political opinions, religion, health, sexual orientation or other special categories of data).

• Making automated decisions that produce legal effects or similarly significant effects on natural persons without effective human supervision.

• Manipulating, altering or suppressing information with the aim of deceiving AI models or modifying the results generated.

8.4. The Client shall be responsible for the accuracy, lawfulness and relevance of the data or documents that it enters, uploads or processes through the Extension, including Job Descriptions, candidate data or other content.

8.5. The Client shall at all times exercise adequate human supervision over the outputs generated by the AI, assessing their coherence, accuracy and relevance before basing any decision or professional action upon them.

8.6. The Client undertakes not to present the results generated by the Solution as objective statements, official reports or conclusive judgements about natural persons, unless they have been duly verified and validated.

8.7. The Client shall maintain the confidentiality of the access credentials assigned to each user and ensure that only authorised persons use the contracted licences.

8.8. It shall likewise be responsible for any improper or unauthorised use carried out through its credentials, and must notify CONECTIO of any security incident, loss of access or suspicion of data breach without undue delay.

8.9. The Client undertakes not to enter or process through the Extension special categories of data under Art. 9 GDPR (unless an applicable legal exception applies and reinforced safeguards are documented), nor to adopt decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect persons (Art. 22 GDPR), without the due human intervention, transparent information and guarantees required by the GDPR and, where applicable, by the AI Act.

9. RESPONSIBILITIES AND WARRANTIES OF CONECTIO

9.1. CONECTIO undertakes to provide the CONECTIO COMPASS Solution with due professional diligence, guaranteeing a reasonable level of availability and continuity in accordance with SaaS industry standards.

Notwithstanding the above, the Client acknowledges that the service may be temporarily interrupted or limited due to maintenance tasks, updates, technical incidents or causes beyond the control of CONECTIO, including network failures, outages of external providers or changes in the services of OpenAI or other integrated third parties.

9.2. CONECTIO guarantees that the Extension:

a) Has been developed in accordance with applicable legislation, in particular Regulation (EU) 2024/1689 (AI Act), Regulation (EU) 2016/679 (GDPR) and other complementary regulations.

b) Complies with the principles of security, transparency and human supervision required by European regulations on artificial intelligence.

However, CONECTIO does not guarantee that the Solution is free from errors, interruptions or minor defects, nor that the results generated by the AI are accurate, exhaustive or applicable to all professional contexts.

9.3. CONECTIO does not guarantee the veracity, suitability or consistency of the results generated by the AI, and assumes no liability for the use, interpretation or decisions that the Client adopts on the basis of such results.

The content generated by the AI is merely indicative in nature and does not constitute technical, psychological, employment-related or professional advice of any kind.

9.4. The Client expressly acknowledges that the artificial intelligence models used operate under probabilistic criteria and may produce biases, errors or incorrect inferences, without this implying a breach on the part of CONECTIO.

9.5. To the maximum extent permitted by law, CONECTIO shall not be liable for:

• Indirect, incidental or consequential damages, loss of profits, data or reputation arising from the use or inability to use the Solution.

• Any business or human resources decision adopted by the Client based, in whole or in part, on information generated by the AI.

• Delays, interruptions or failures caused by third-party service providers or by causes of force majeure.

9.6. CONECTIO's overall liability towards the Client, for any cause and on any basis, shall be limited, in any event, to an amount equivalent to the fees actually paid by the Client in the three (3) months prior to the event giving rise to the claim.

9.7. CONECTIO shall be exempt from any liability arising from the improper, unlawful or contrary-to-these-Terms use that the Client or its authorised users make of the Solution, including the introduction of personal data without a legal basis, the use of AI for discriminatory purposes or the adoption of automated decisions without due human intervention.

10. SUSPENSION AND CANCELLATION OF SERVICES

10.1. CONECTIO may temporarily suspend access to or operation of the Extension in the following cases:

a) To carry out maintenance, updating or improvement tasks of the Solution.

b) In the event of contractual breach by the Client, including non-payment of fees or unauthorised use of licences.

c) For security or data protection reasons, when there are reasonable indications of improper access, vulnerability or fraudulent use of the Extension.

d) In compliance with a legal requirement or that of a competent authority.

During the suspension period, CONECTIO shall endeavour to minimise the impact on the Client and will inform, whenever possible, of the cause and estimated duration of the suspension.

10.2. CONECTIO may terminate the contract by operation of law and definitively cancel the Client's access in the event of:

• Use of the Solution for unlawful purposes or purposes contrary to the AI Act or the GDPR.

• Unauthorised resale, sublicensing or assignment of the contracted licences.

• Non-payment after more than fifteen (15) calendar days from the due date.

• Introduction of personal data or confidential information without a legal basis or without the consent of the data subjects.

• Serious infringement of CONECTIO's or third parties' intellectual or industrial property rights.

Termination shall take effect upon written communication to the Client, without prejudice to CONECTIO's right to claim damages arising from the breach.

10.3. Once the subscription has been cancelled or the contract terminated:

• All active licences shall be automatically revoked.

• The data stored in CONECTIO's systems shall be deleted or anonymised, in accordance with its Data Retention Policy and the GDPR.

• Access to histories, Job Descriptions or previous results shall not be permitted, except by express request for export before the date of termination.

CONECTIO shall retain only such information as is necessary for the fulfilment of legal, tax or audit obligations, during the periods established by applicable legislation.

11. INDEMNITY

11.1. Clients undertake to protect and hold CONECTIO, its directors, representatives or employees harmless from any damage, liability or cost that may arise from third-party claims against CONECTIO due to the material provided by the Users, misuse of CONECTIO's services or breach of these GTC, including any claim, sanction or damage arising from the processing of personal data in which the Client acts as Controller without a valid legal basis, without complying with the duties of information or in which it breaches the guarantees of Art. 22 GDPR on automated decisions.

11.2. CONECTIO shall inform the Users of any claim using the data provided when registering for the services. By accepting these GTC, the Users acknowledge that CONECTIO has no direct or indirect liability in the services contracted between the Client and each User or third parties.

12. DATA PROTECTION

Both Parties declare that they comply with the provisions of 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 (hereinafter, "GDPR") and Ley Orgánica 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (Organic Law 3/2018, LOPDGDD) in the possible processing of personal data that may arise under this Contract.

● Provision of the Services

The purpose of this Clause is to establish the conditions under which CONECTIO, as Data Processor, shall carry out the processing of personal data inherent to the service commissioned by the Client, in its capacity as Data Controller.

CONECTIO, as Data Processor, undertakes to:

I. Carry out the processing of personal data necessary for the correct provision of the Services supplied to the Client, adhering to the instructions that the Client indicates at any given time. Under no circumstances may it use the data for its own purposes or for any purposes other than those established. However, CONECTIO reserves the right to use the data in anonymised form for analysis, market research, statistics or other uses that allow the improvement of the user experience or the optimisation of services, always respecting data protection regulations.

II. Process the data in accordance with the Client's instructions, as indicated in this Contract. If CONECTIO considers it necessary to carry out data processing for a purpose other than the one indicated, it must first request written authorisation from the Client. In the absence of such authorisation, CONECTIO may not carry out such processing. In the event that CONECTIO considers that any of the instructions provided by the Client infringe the GDPR or LOPDGDD, it shall immediately inform the Client.

III. CONECTIO shall keep and guard under its control the personal data of the Client, to which it has access as a consequence of the provision of its Services, and may not disclose, copy, reveal, transfer, assign or communicate in any other form, whether verbally or in writing, by electronic means, paper or through computer access —not even for their conservation— to any third party, nor the aforementioned elaborations, evaluations or similar processes, save in the cases necessary to carry out the requested service and/or the authorisations that may have been granted.

IV. Therefore, the processing of personal data derived from this Contract obliges CONECTIO to the duty of secrecy and confidentiality during the term of the relationship with the Client.

V. Ensure that the personal data to which it has access are processed only by those employees whose intervention is strictly necessary for the provision of the service and who must know them in order to properly carry out the performance of their functions. CONECTIO shall communicate to the employees the security measures that shall be applied and the duty of secrecy and confidentiality they must observe in relation to the personal data.

VI. Adopt such technical and organisational measures as may be necessary to guarantee the security of the personal data to which it has access and to prevent their alteration, loss, unauthorised processing or access, taking into account the state of the art, the cost of implementation, the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for the rights and freedoms of the data subjects, which, where appropriate, shall include:

a) Ensure the permanent confidentiality, integrity, availability and resilience of processing systems and services.

b) Restore the availability of and access to personal data in a timely manner in the event of a physical or technical incident.

c) Pseudonymise and encrypt personal data, where applicable.

d) Process for regularly verifying, evaluating and assessing the effectiveness of the technical and organisational measures for ensuring the security of the processing.

VII. CONECTIO undertakes to keep a record of all categories of processing on behalf of the Client.

VIII. Notify the Client, without undue delay, and, in any case, within a maximum period of 72 hours and through any reliable means provided for in the Communications clause, of any personal data security breaches under its responsibility of which it becomes aware, together with all information relevant to the documentation and communication of the incident. However, notification shall not be necessary where it is unlikely that such security breach constitutes a risk to the rights and freedoms of natural persons.

Specifically, at a minimum, the following information shall be provided in clear and simple language:

a) Description of the nature of the personal data security breach, including, where possible, the categories and approximate number of data subjects affected.

b) The name and contact details of the data protection officer or other point of contact from which further information may be obtained.

c) Description of the possible consequences of the personal data security breach.

d) Description of the measures taken or proposed to remedy the personal data security breach, including, where appropriate, the measures taken to mitigate possible negative effects.

If it is not possible to provide the information simultaneously, and to the extent that it is not, the information shall be provided in a phased manner without undue delay.

IX. Support or collaborate with the Client, where necessary, in carrying out privacy impact assessments relating to the personal data to which it has access, as well as in carrying out prior consultations with the supervisory authority, where applicable. Likewise, cooperate with the competent Supervisory Authority, at its request, in the performance of its duties. To this end, it shall provide all the technical and organisational information that may be necessary.

X. Make available to the Client, upon request, all the information necessary to demonstrate compliance with the obligations established in this Contract, for the purposes of verifying compliance with the provision of the services.

XI. Once the provision of services has ended, CONECTIO shall, at the Client's option, return any type of medium or document containing personal data, without retaining any copy of them or of the information generated or supplied, or proceed to the secure and confidential destruction of the same from any medium, adopting the organisational and technical measures necessary to guarantee the non-recovery of the data and, therefore, its non-subsequent use or access by unauthorised third parties.

Notwithstanding the foregoing, in the event that there is a legal obligation under which CONECTIO must retain certain information for a period of time, such information must remain blocked, and may not be used for other purposes, being kept solely at the disposal of the relevant Authorities to address any liabilities arising from the processing, for the period during which they may be claimed, after which its definitive deletion must be carried out.

XII. If it should be necessary to subcontract any processing or part thereof that involves the access to and/or processing, in whole or in part, of personal data, the prior authorisation of the Client shall be required before the commencement of the services, or alternatively, that there is a previous Contract that obliges the Sub-processor to conditions substantially similar to those of the processing of the Client's personal data by CONECTIO in accordance with the provisions of this clause. CONECTIO must inform the CLIENT of the identity and details of the third party. The provision of services necessary for the execution of this Contract by the companies that form part of the Business Group to which CONECTIO belongs shall not be considered subcontracting.

CONECTIO shall be obliged to transfer and communicate to the subcontracted third party the content of this Clause. Therefore, CONECTIO shall have to enter into an agreement with the third party that includes, as a minimum, the same content as this one, so that the third party is subject to the same conditions and obligations in relation to the proper processing of personal data.

In this way, the access of the third party to the personal data of the Client shall have as its sole cause and limit the subcontracting of all or some of the Services contracted by the Client to CONECTIO, being restricted to all those personal data strictly necessary for the performance of the subcontracted services.

XIII. CONECTIO shall process the Personal Data within the European Economic Area or another area considered by the applicable regulations as being of equivalent security, processing them outside this area in any case, through sub-processors that guarantee an adequate protection framework under the applicable regulations or the formalisation of standard contractual clauses adopted by the European Commission or, where appropriate, obtaining the authorisation for the transfer from the Competent Supervisory Authority.

Hereby, each Party shall be subject to liability and shall indemnify the other, for any type of claim that arises or is alleged to have arisen as a result of negligent or wilful acts or omissions on the part of either of them, or of the personnel under their charge, which infringe the provisions of the regulations in force, including the assumption of any administrative sanctions that may have been incurred.

● Right to information

Each of the signing Parties and, where applicable, their representative, are informed that the personal data of their representatives and employees will be processed by the other Party for the purpose of allowing the development, fulfilment and control of the agreed service provision relationship, as well as the data that may be exchanged during the provision of the Services, the basis of the processing being the fulfilment of the contractual relationship. The identification of the Parties is a necessary requirement for the formalisation of this Contract, and therefore the latter cannot be carried out without said requirement being met.

The data shall be retained for the entire time that the contract subsists and even thereafter, until any liabilities arising from it have lapsed. The Parties' data may be communicated to banks and financial entities for the management of collections and payments and to Public Administrations in the cases provided for by Law for the purposes defined therein.

The Parties must transfer the information contained in this Clause to any person involved in the provision of the agreed Services, which entails the processing of their personal data.

The data subjects may request access to the personal data, their rectification, erasure, objection, data portability and restriction of their processing, at the address of the other Party indicated at the heading of this Contract, as well as file a claim with the Supervisory Authority for Data Protection.

International transfers

Certain processing operations may involve the international transfer of data outside the European Economic Area (EEA), in particular to the United States, due to the use of AI models provided by OpenAI.

In such cases, CONECTIO shall ensure that the transfer is carried out in accordance with an adequacy decision or through the signing of the Standard Contractual Clauses (SCC) approved by the European Commission, guaranteeing a level of protection essentially equivalent to that of the GDPR.

13. LANGUAGE

CONECTIO may translate these Terms and Conditions or any other policy that may be published on the Platform. The Spanish version shall prevail in the event of conflict with other translations.

14. APPLICABLE LEGISLATION AND JURISDICTION

The parties undertake to agree in good faith on their intention to resolve any dispute with regard to these GTC. CONECTIO's GTC are subject to Spanish legislation. The parties submit to the Courts and Tribunals of Barcelona.