Privacy policy

DATA CONTROLLER: The Mercantile "FULGENCIO SPA, SL“(hereinafter, “FULGENCIO SPA”) Tax ID of the CONTROLLER: B-18235598, informs users of its Internet portal (hereinafter, the "Users" and the "Portal") about its policy on the protection of personal data (hereinafter, "Personal Data") so that Users may freely and voluntarily decide whether they wish to provide FULGENCIO SPA with the Personal Data that may be requested or obtained from Users on the occasion of visiting the website, sending a C. Vitae, subscribing or registering for any of our informative newsletters, requesting information about any of our variety of fruit and vegetable products offered/ displayed in our product catalog, activities, events and promotions organized through our website, or using the corporate complaints channel.

FULGENCIO SPA reserves the right to modify this privacy policy to adapt it to new legislation or case law, as well as industry practices. In such cases, FULGENCIO SPA will announce the changes on this page with reasonable notice before they take effect. Certain products/services provided/offered on the Portal may contain specific terms and conditions regarding the protection of Personal Data.

FULGENCIO SPA, as the Data Controller of the personal data of ITS USERS, and other affected parties/owners with whom it maintains a relationship, informs you that this data will be processed in accordance with the provisions of the Regulation (EU) 2016/679 of 27 April 2016 (GDPR) relating to the protection of natural persons with regard to the processing of personal data and the current LOPD-GDD 3/2018 of December 5 (LOPD-GDD) relating to the protection of personal data.

INFORMATION / DATA PROCESSED: Basic identification data (name + surnames) and contact details where applicable (address, telephone number and email address), data necessary for certain contracts/participation in company events, registration in our corporate Newsletter service, CVs received by email, data provided at events or presentations, data supplied in the social media profiles owned by FULGENCIO SPA, training activities managed by the company, and data provided through the corporate complaints channel.

CONTROLLER OF THE PROCESSING:
• "FULGENCIO SPA, SL" CIF: B-18235598
• Address: Carretera nacional 340 km 343.5. 18730 - Carchuna. GRANADA.
• Email: hola@fsagro.com
• Phone number: (+34) 673 298 151
• Contact details for the Designated External DPO: dpo@fsagro.com

INTENDED PROCESSING PURPOSES:
MAINTAINING THE RELATIONSHIP with farmers, clients/suppliers, users (apps), employees, data processors, control and management of the relationship with employees and external collaborators, onboarding and offboarding, management of the existing contractualrelationship with collaborators and sponsors, and the
commercial relationship with suppliers, selection of FULGENCIO SPA staff, candidates in selection processes, users registered on our website, participants in activities and events, including the possibility of training activities managed or participated in by FULGENCIO SPA. In this regard, the planned processing operations are:

WHAT PERSONAL DATA DO WE PROCESS: When filling out any of ourforms, depending on each case:
• Contact Form
• Job Offers Published
• Corporate Whistleblowing Channel: accessible through our website and internal channels enabled by the company.

In the aforementioned forms/sections, you are allowed to provide, among other things, the following personal data:
• Your name and surname and contact details (address, telephone numbers and email), and a space for free text.
• Other contact details and preferences.
• We collect your data if you contact us through the Site.
• When you visit our website, we will collect your data if you fill out any of our data/contact forms, information requests, or newsletter subscriptions, whether current or future.
• If personal data has been provided by users, it must be truthful, and FULGENCIO SPA must be notified of any changes that occur in it, being responsible in any case for the truthfulness and accuracy of the data provided at any time.
• The interested party who provides their personal data to FULGENCIO SPA, declares
that they are of legal age and is entirely responsible for said declaration.

Other treatments
• SUBMISSION OF COMMERCIAL ADVERTISING COMMUNICATIONS: By email, SMS, WhatsApp, social media, or any other electronic or physical means, present or future, that allows for commercial communications. These communications will be sent by the CONTROLLER and will relate to the fruit and vegetable services/ products, activities, and events, or those of its collaborators or suppliers with whom it has reached a promotional agreement. In this case, third parties will never have access to personal data.

• ACTIONS REQUESTED BY THE USER:To process applications or any type of request that, through the FULGENCIO SPA website, is made by the user/ farmer through any of the contact methods that are made available to him, events, contests, or by subscribing to our events and activities organized by/ with the participation of Fulgencio Spa.

• PROCESS REGISTRATIONS FOR EVENTS, DRAWINGS AND PROMOTIONAL ACTIVITIES: in which users wish to participate. In this case, images or videos taken of participants individually during the activities, and provided that express and unequivocal consent has been obtained, may be published on the entity's website, corporate publications and brochures, notice
boards, and any other similar communication medium owned by the company, for the purpose of promoting such activities or events. In the case of tournaments or similar activities, participants' data (name, surname, and age) may be published in the same media to publicize participation, rankings, or results of tournaments, contests, prizes or activities. If this data processing is not expressly consented to, it will only be known internally by the tournament participants, so that they know the corresponding ranking, a necessary requirement for the correct development of the tournament (legitimate interest).

• DATA STORED DURING YOUR VISIT: When you visit our website, our web servers typically store, among other data, information about the browser and operating system you are using, the website from which you visited us, the pages you visit on our website, and the date of your visit. For security reasons —for example, to detect potential attacks on our website—the IP address assigned to you by your Internet service provider is also stored for a period of seven days. With the exception of the IP address, personal data is only stored if you provide it to us, for example, in connection with a registration, a survey, a quote request, user registration, commercial promotion. FULGENCIO SPA uses your personal data for the technical administration of the websites, customer management, conducting product surveys and for marketing tasks, only to the extent necessary, and always informing the User and data owner beforehand.

• NEWSLETTER SUBSCRIPTION: By subscribing to any of our current or future newsletters, you consent to the use of your personal data for advertising and other marketing purposes. This data will be stored and used continuously for these purposes, such as sending the aforementioned newsletters, updates on our range of fruit and vegetable products, and information about our activities, through communication channels such as email, postal mail, or any other channel you authorize. We may use your data to create and maintain your user profile and send you personalized information about advertising campaigns or promotions. We may also use the data you provide to analyze and improve the effectiveness of our website services, advertising, marketing, market research, and sales activities.

• SUBMISSION OF C. VITAE BY CANDIDATES: In case of sending a C. Vitae to the email of FULGENCIO SPA hola@fsagro.com. The applicant authorizes FULGENCIO SPA to analyze the documents submitted, all content directly accessible through search engines (Google), profiles maintained on professional social networks such as LinkedIn or similar platforms, data obtained from entrance exams, and information disclosed during the job interview, for the purpose of evaluating their candidacy and, if applicable, offering them a position. If the candidate is not selected, FULGENCIO SPA may retain their CV for consideration in future job openings, unless the candidate objects.

EXISTENCE OF AN INTERNAL COMPLAINTS CHANNEL (LAW 2/2023):
In accordance with Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, FULGENCIO SPA has an Internal Information System (Whistleblowing Channel) available to its employees, collaborators and third parties related to the entity.
Data Controller: “FULGENCIO SPA, SL”, CIF: B-18235598, with registered office at Ctra. Nacional 340 km 343,5. 18730 - Carchuna. GRANADA. DPO contact: dpo@fsagro.com .
Purpose: The data collected through this channel, and that generated as a result of investigations, will be processed solely for the purpose of handling and deciding on the admissibility of complaints received within the framework of FULGENCIO SPA's crime prevention management model, analyzing them, preparing the files, and carrying out any necessary actions. The data requested is the minimum necessary for the stated purpose; refusal or partial provision of the data could result in the complaint not being admitted for processing.
Legitimation: (i) compliance with a legal obligation and the public interest in the prevention of crimes and offenses (Arts. 6.1.cy 6.1.e GDPR, in relation to Law 2/2023); (ii) the legitimate interest of FULGENCIO SPA in preventing irregularities and/or noncompliance with the provisions contemplated in its Protocol and in the overall management of human resources; and (iii) if the affected party is an employee of FULGENCIO SPA, the power of the entity to manage its workforce and, where appropriate, adopt the appropriate disciplinary measures within the framework of the employment contract.
Recipients: The Executive Committee and the system managers appointed by the Company, as well as other individuals or entities whose collaboration may be necessary within the framework of an investigation or for the audit of the Canal's operation, in accordance with its Protocol. Depending on the reported facts, the data may be communicated to the State Security Forces and Corps, competent Public Administration bodies, the Public Prosecutor's Office, and the Courts of Justice. In the event of a false report, the data may be communicated to the accused individuals so that they may exercise their legal rights.
Confidentiality and anonymity: The channel allows for anonymous reporting. The informant's identity is kept confidential and will not be disclosed to the affected parties or third parties, in accordance with the guarantees provided in Articles 31 seq. of Law 2/2023. The accused party's right to exercise their rights is also guaranteed without this implying the disclosure of the complainant's information.
Conservation: The data will be processed for the time necessary to decide whether to initiate an investigation and, if so, for its processing. If the investigation concludes with its dismissal, the data will be deleted. In any case, after three (3) months from the receipt of the complaint, the data will be deleted, unless its retention is necessary for the completion of the investigation or to address the irregularities detected through judicial, administrative, or labor channels. The information, previously anonymized, may be retained for audits of the Channel's operation.

Full information on data processing by the Whistleblowing Channel is available in the information section of the Channel's form. GDPR rights may be exercised in accordance with the procedure described in this Policy, by contacting dpo@fsagro.com

DATA RETENTION CRITERIA: The data provided will generally be kept as long as there is a mutual interest in maintaining the purpose of the processing and when it is no longer necessary for that purpose, it will be deleted with appropriate security measures to guarantee the pseudonymization of the data or the total destruction of the data.

Given this general rule, the following questions arise the following possible variations:
• (i) Disaggregated Data: will be kept indefinitely,
• (ii) Data of users, companies and suppliers, etc… FULGENCIO SPA: retention period of 4 years (Article 66 et seq. of the General Tax Law), retention period of 6 years Article 30 of the Commercial Code regarding accounting books and invoices)
• (iii) Data provided for the purpose of subscribing to our newsletter: from the time the User gives their consent, until they withdraw it
• (iv) Documentation of a labor or social security nature: 4 years Article 21 of Royal Legislative Decree 5/2000, of August 4, which approves the consolidated text of the Law on Infringements and Sanctions in the Social Order, (v) data supplied by candidates through the submission of their C. Vitae: the C. Vitae may be kept for a maximum of two years for future selection processes unless the candidate states otherwise
• (vi) Images obtained by the video surveillance systems owned by FULGENCIO SPA: 30 days, in accordance with the instructions of the AEPD.

DATA COMMUNICATION: Your personal data may be shared with:
• Companies and entities and other organizations that have been contracted to provide services, such as: hosting, marketing services, market analysis and information society services.
• Partner/sponsor companies with which FULGENCIO SPA has reached a collaboration or sponsorship agreement.
• Companies or other organizations to which you have requested or agreed that we may share your personal data.
• For certain internal company activities/services, specific services must be subcontracted to third parties. These subcontractors may be external suppliers both within and outside the EU. FULGENCIO SPA guarantees that all subcontractors comply with the obligations and requirements assumed by FULGENCIO SPA in its Data Access Agreement; specifically, that its level of data protection meets the standard required by the relevant data protection laws. If a jurisdiction is outside the EU and is not on the list approved by the European Commission of satisfactory levels of data protection under the GDPR, then a specific agreement is established between FULGENCIO SPA and the subcontractor to ensure that all personal data will be kept in accordance with the requirements of applicable EU data protection
laws. The subcontractors that FULGENCIO SPA uses for certain areas are:

- Google Analytics: Google web analytics https://www.cookiebot.com/es/google-analytics-rgpd/
- Google Workspace (Google): Google application suite: https://cloud.google.com/security/gdpr?hl=es
- Masalbe Servicios Globales, SL: Appointed External DPO. https://masalbe.com/privacidad
- De Cara Mfo Asesores Fiscales SLP: Tax advisors. https://www.asesoriadecara.com/
- BNFIX AUDITORES, SL and BNFIX CONSULTORES, SL: http://www.bnfix.com/
- Hispatec Business Computing Group, SA: Internal ERP: https://www.hispatec.com/

• The purpose of communicating the data to the aforementioned companies, which comprise and are integrated with the controller, will be the same as those previously announced, as companies in charge of processing the controller.
• Professional service providers, such as lawyers, solicitors, arbitrators, notaries, registrars or other similar professionals in certain cases.
• Public bodies, courts, regulators and other administrative authorities, when we consider it necessary to comply with a legal or regulatory obligation, or otherwise to protect ourselves from claims against us or third parties, or the safety of people, as well as to prevent, or otherwise combat, fraud or for reasons of security or protection.
• Any third party that buys, or to whom we transfer, all or a substantial part of our assets and business. In the event of such a sale or transfer, we will make all reasonable efforts to ensure that the entity to which we transfer your personal data uses it in accordance with this Privacy Policy.

In such cases, we will ensure that your data is used for appropriate purposes in accordance with this Privacy Policy and will subscribe to the corresponding contracts or clauses for the processing of data (Standard Clauses - SCC), applying the same or similar security measures to those applied by FULGENCIO SPA.
The data will be processed based on the explicit consent of the person providing it. This consent may be withdrawn at any time, although this will not affect the lawfulness of any processing carried out prior to its withdrawal. Providing the data is voluntary, but if it is not provided, it cannot be processed for the purposes indicated. If third-party data is provided through this website, the person providing it assumes responsibility for having obtained prior consent and informing them of everything stipulated in Article 14 of the General Data Protection Regulation.

INTERNATIONAL DATA TRANSFERS:
On July 10, 2023, the European Commission adopted a new adequacy decision to enable international transfers of personal data between entities in the European Union (EU) and the United States (US) under the EU-US Data Privacy Framework. Following the judgment of the Court of Justice of the European Union (CJEU) of July 16, 2020, known as the Schrems II ruling, international transfers of personal data to the US were called into question due to the problems identified by the CJEU related to US surveillance practices and the lack of mechanisms for European citizens to address interference with their rights.

With this adequacy decision, the European Commission acknowledges that the UE guarantees a level of protection equivalent to that offered by the EU, but only when international transfers occur with entities certified under the EU-US Data Privacy Framework. Therefore, personal data can be securely transferred from the European Union to US companies adhering to the Framework, without the need for additional data protection safeguards.

For the rest of the international transfers that FULGENCIO SPA may carry out outside the aforementioned Framework (for example, to technology providers), the guarantees provided for in Articles 44 et seq. of the GDPR will apply, such as standard contractual clauses (SCC) or binding corporate rules, and the corresponding Transfer Impact Assessment will be carried out where appropriate.

LEGITIMACY FOR THE INFORMED PROCESSING:
As a general rule, prior to processing personal data, FULGENCIO SPA obtains the express and unequivocal consent of the data subject by incorporating informed consent clauses into the various information collection systems, and based on the legitimate interest of the User. If the data subject's consent is not required, the legal basis for the processing on which FULGENCIO SPA relies is the existence of a FARMER CONTRACT, AGREEMENT OF MARKETING, CUSTOMER REGISTRATION CONTRACT, collaboration document, FULGENCIO SPA facility visit form.

Notwithstanding the foregoing, the bases for legitimacy are as follows:
• When the treatment is necessary for the performance of a contract to which you are a party or the data are necessary within the framework of a pre-contractual relationship.
• When the use of your personal data is necessary for the satisfaction of our legitimate interests or those of the companies with which we have shared your personal data.
• When the processing of data is necessary to be able to comply with the legislation/regulations governing the legal obligations of the sector, GDPR and LOPD-GDD legislation and similar applicable legislation in force at any given time, including those relating to the placing on the market of services of FULGENCIO SPA or of third parties, defense of consumers and users, regulation of retail trade, and other applicable regulations.
• In accordance with the provisions of the applicable regulations on Information Society Services (LSSI-CE), if a demonstrable prior relationship exists,The data may be used for sending electronic commercial communications relating to that specific activity, unless you object to it in the manner provided for that purpose.
• When we deem it necessary to process your personal data to comply with a legal or regulatory obligation, or a vital interest.
• When we have your consent, to, for example, collect technical information such as cookie data and similar technologies as described in: “Information on the Use of Cookies”.

RECOGNIZED RIGHTS:
And these are your rights as a data subject or owner of personal data:
Right of access: You have the right to obtain confirmation from the company as to whether or not personal data concerning you is being processed. FULGENCIO SPA, in that case, you will provide a copy of the personal data being processed.
Right of rectification: You have the right to obtain without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of tthe processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right of erasure: You have the right to obtain without undue delay the erasure of inaccurate personal data concerning you. At FULGENCIO SPA, we will be obliged to delete such personal data without delay when any of the following circumstances apply:
a. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b. you withdraw the consent on which the processing is based and it is not based on another legal ground;
c. you object to the treatment and provided that there are no other legitimate grounds for the treatment;
d. your data has been processed unlawfully;
e. your data must be deleted to comply with a legal obligation;
f. or if your personal data has been obtained in relation to the offer of information society services to children (under 14 years of age, in accordance with art. 7 LOPDGDD).
Right to limit processing: When the processing of your personal data has been restricted at your request, such data may only be processed, with the exception of storage, with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest. You have the right to obtain restriction of processing of your personal data when one of the following conditions applies:
a. When you contest the accuracy of personal data, for a period that allows FULGENCIO SPA to verify its accuracy;
b. the processing is unlawful and, as the data subject, you oppose the erasure of the personal data and request, instead, the restriction of its use;
c. FULGENCIO SPA no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims;
d. When you have objected to the treatment, while it is being verified whether the legitimate reasons of FULGENCIO SPA prevail over those of the interested party.
Right to data portability: You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format, and to transmit it to another data controller without hindrance from FULGENCIO SPA, when:
a. the treatment is based on your consent, and
b. the treatment is carried out by automated means.
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on public interest or the legitimate interests of the controller. Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data. If you object to the processing of your data for direct marketing purposes, your personal data will no longer be processed for such purposes.

We remind you that whenever the legal basis for processing your data is your consent, you have the right to revoke said consent always and in every case, and as easily as you gave it. You also have the right to lodge a complaint with the relevant supervisory authority, generally, the Spanish Data Protection Agency. For more information, you can visit their website at the following link: https://www.aepd.es
Finally, you have the right not to be subject to a decision by FULGENCIO SPA based solely on automated processing, including profiling, that produces legal effects or similarly significantly affects you.

CONTACT DETAILS TO EXERCISE YOUR RIGHTS: FULGENCIO SPA, in compliance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR), and the recent LOPD-GDD 3/2018 of 5 December, has an internal designated manager, and a Data Protection Officer (DPO) appointed for the management of Data Protection and whose contact details are provided below:
• Address: National Highway 340 km 343.5. 18730 - Carchuna. GRANADA.
• Email: hola@fsagro.com
• Phone number: (+34) 673 298 151

To exercise your rights you must: provide sufficient data and information to process the request (for this purpose, you may use the form templates provided by the Spanish Data Protection Agency at https://www.aepd.es/es/derechos-y-deberes/conoce-tus-derechos); sign the request by hand or, if you have a recognized digital certificate, electronically; if acting on behalf of a third party, provide documentation proving such representation; and send it by any of the indicated means. In case of reasonable doubt about the identity of the applicant, data subject, and/or their representative, the provision of a copy of ID card, Passport, NIE or other equivalent identification document may be required.
Additional information regarding your request: FULGENCIO SPA will analyze whether the request is legally valid and will inform the requester of its decision, proceeding accordingly: if the request is granted, it will take the appropriate measures based on the right exercised; if it is denied, it will indicate the legally available appeals process. In cases where requests are manifestly unfounded or excessive (e.g., repetitive), FULGENCIO SPA may: (i) charge a fee proportional to the administrative costs incurred, or (ii) refuse to act.
If a user/data subject believes there is a problem with how FULGENCIO SPA is processing their data, they can address their complaints to the Data Protection Officer indicated above, or through the Spanish Supervisory Authority, in this case, the AEPD: https://www.aepd.es

MANDATORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED:
The data collected through any of the contact forms enabled on this Website, or even for the provision of information, or those provided by the Users as a result of their participation in activities/events developed by FULGENCIO SPA, will be incorporated, depending on their purpose, into Record of Processing Activities Internal (Article 30 of Regulation (EU) 2016/679 of 27 April 2016). The Record of Processing Activities is available to the Supervisory Authority.

By checking the corresponding boxes and entering data in the various fields marked with an asterisk (*) on the contact form or presented in download/ contract forms, Users expressly and freely and unequivocally accept that their data is necessary for FULGENCIO SPA to process their request. Providing data in the remaining fields is voluntary. The User guarantees that the personal data provided is truthful and is responsible for communicating any changes to it.

FULGENCIO SPA expressly informs and guarantees users that their personal data will not be transferred to third parties other than those indicated in this Policy and that, whenever it plans to make any other transfer in the future, it will first request the express, informed, and unambiguous consent of the Users, informing them about the recipient's details and the purpose of the
transfer. All data requested through the website is mandatory, as it is necessary for providing optimal service to the User.
If all the data is not provided, it is not guaranteed that the information and services provided will be fully tailored to your needs.

SECURITY MEASURES:
In accordance with the provisions of current regulations on the protection of personal data, and in particular in the Regulation (EU) 2016/679 of 27 April 2016, and the LOPD-GDD 3/2018 for the processing of personal data under its responsibility, and expressly with the principles described in Article 5 of the GDPR, whereby they are processed lawfully, fairly and transparently in relation to the data subject and adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

In any case, FULGENCIO SPA has implemented sufficient mechanisms to:
1. Guarantee the ongoing confidentiality, integrity, availability and resilience of treatment systems and services.
2. Restore the availability and access to personal data quickly, in the event of a physical or technical incident.
3. Regularly verify, evaluate and assess the effectiveness of the technical and organizational measures implemented to ensure the security of the processing.
4. Pseudonymize and encrypt personal data, where appropriate.

FULGENCIO SPA guarantees that it has implemented appropriate technical and organizational policies to apply the security measures established by the GDPR679/2016 and LOPD-GDD 3/2018 In order to protect the rights and freedoms of Users, FULGENCIO SPA has provided them with the necessary information to exercise those rights. FULGENCIO SPA has implemented all available technical means and measures to prevent the loss, misuse, alteration, unauthorized access, and theft of Personal Data provided by the data subject to FULGENCIO SPA. However, Users should be aware that internet security measures are not infallible.

Personal data included in the Internal Processing Activities Register will be treated with the utmost confidentiality and security. The Data Controller may send you commercial information relating to NEWS AND PROMOTIONS ABOUT THE SERVICES/PRODUCTS CONTRACTED AND OFFERED BY FULGENCIO SPA. In this case, the sender undertakes to indicate its advertising purpose when sending the message, and to coordinate a simple, clear and free system in case you wish to stop receiving them.

The services of FULGENCIO SPA contained on the website are intended exclusively to adults, in the event that FULGENCIO SPA offers any promotional activity, event, contest or similar, in which the collection of Personal Data of minors may occur, FULGENCIO SPA will always request parental consent so that minors can access them and their Personal Data can be subject to automated processing as provided in this notice on the Data Protection Policy.

As previously informed, the collection and automated processing of Personal Data is intended to maintain the contractual relationship, if any, established with FULGENCIO SPA, the management, administration, provision, expansion and improvement of the services that the User decides to contract, register for, or use, the adaptation of said services to the preferences and tastes of the Users, the study of the use of the services by the Users, the design of new services/products, the sending of service updates, the sending, by traditional and electronic means, of technical, operational and commercial information about our agricultural products and related services offered by FULGENCIO SPA currently and in the future.

RIGHT TO INFORMATION.
Upon receiving your request, FULGENCIO SPA will immediately inform you in writing, in accordance with applicable law, whether and if we hold any of your personal data. If you are a registered user, you will have the opportunity to view your data personally and, if necessary, delete, modify, and/or update it.

DESCRIPTION OF MEASURES ADOPTED BY FULGENCIO SPA DERIVED FROM THE GDPR:
FULGENCIO SPA informs its Users/farmers, employees, clients and suppliers that, in accordance with the GDPR and LOPD-GDD regulations applicable to the activity carried out by the company, the measures adopted to obtain an optimal level of compliance are detailed below:
• Prepare a record of processing activities in accordance with Article 30 of the GDPR.
• Identify the legal bases for the processing of data, in accordance with Articles 6 and 9 of the GDPR.
• Audit the channels for receiving information and internal forms/documents and inform interested parties regarding the processing of their data, in accordance with Articles 13 and 14 of the GDPR.
• To address the rights of interested parties, in relation to their rights of: access, rectification and erasure, limitation of processing, data portability (Article 20 of the GDPR), objection and automated decisions, establishing a direct channel of attention: dpo@fsagro.com
• Audit and request compliance guarantees from the company's data processors, and sign a data processing agreement, in accordance with Article 28 of the GDPR. FULGENCIO SPA facilitates this process by making the following documents accessible through our DPO: 1) a compliance guarantee document and details of the measures adopted, 2) a sample data access agreement from FULGENCIO SPA.
• Carry out a risk analysis and, where applicable, an impact assessment; to facilitate compliance with these obligations, you can consult the AEPD website: https://www.aepd.es/es/prensa-y-comunicacion/notas-de-prensa/la-aepd-publica-un-modelo-de-informe-para-ayudar-las-empresas
• FULGENCIO SPA, as a responsible company committed to regulatory compliance, recommends that its clients, users and interested parties subscribe to the alert bulletins of INCIBE (www.incibe.es), OSI (www.osi.es) and CERT (www.incibe-cert.es)

The links to subscribe to the different portals mentioned will allow you to know in advance about possible threats and incidents:
• INCIBE ALERTS: https://www.incibe.es/newsletter/subscriptions
• OSI ALERTS: https://www.osi.es/es/boletines/subscribe
• Incibe-Cert alerts: https://www.incibe-cert.es/newsletter/subscriptions

• Existence of an internal protocol for notifying data security breaches to the data protection authorities (Article 33 of the GDPR) and to the individuals whose data has been compromised (Article 34 of the GDPR). To this end, in the event of any incident that poses a risk to the rights and freedoms of the affected parties, FULGENCIO SPA will notify the CLIENT as soon as possible and will assist them in making such notifications.
• The company has officially appointed a Data Protection Officer and registered it with the Spanish Data Protection Agency (AEPD) (www.aepd.es) in accordance with the Articles 37, 38 and 39 of the GDPR. FULGENCIO SPA provides CLIENTS/ users and interested parties with the following contact email address for the designated DPO regarding data protection/exercise of rights: dpo@fsagro.com
• FULGENCIO SPA, in compliance with current regulations, also informs you of your right to file a complaint/request further information from the supervisory authority (www.aepd.es)

RELATED REGULATIONS:
If you would like more information on the regulations that support, protect and establish your rights, we provide you with the regulations that have inspired this Privacy Policy: Regulation (EU) 2016/679, of 27 April 2016 (GDPR); Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD); Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE); and Law 2/2023, of 20 February, regulating the protection of persons who report
regulatory infringements and the fight against corruption.

CONTACT: Should you require any clarification regarding this Privacy Policy, wish to raise any questions or complaints, or exercise any rights, please contact our internal Data Protection Officer in writing using the contact details shown below, indicating "Data Protection" in the subject line.
• Address: Carretera nacional 340 km 343.5. 18730 - Carchuna. GRANADA.
• Email: hola@fsagro.com
• Phone number: (+34) 673 298 151

Privacy Policy drafted and revised as of September 29, 2026.