I. PRIVACY AND DATA PROTECTION POLICY



Respecting the provisions of current legislation, Harry Jo (hereinafter, also Website) commits to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data.



Laws incorporated in this privacy policy



This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it respects the following standards: 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 (GDPR).



Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).



Royal Decree 1720/2007, of December 21, which approves the Regulation implementing Organic Law 15/1999, of December 13, on Personal Data Protection (RDLOPD).



Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).



Identity of the controller of personal data processing



The controller of the personal data collected in Harry Jo is: Harry Jo Investment Strategy S.L.



Their contact details are as follows:

Address: Calle Colón 22 Primera planta – 46004 Valencia, Spain.

Contact phone: +34 960 814 570.



Registry of Personal Data.



In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Harry Jo, through the forms extended on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Harry Jo and the User or the maintenance of the relationship established in the forms that the latter fills out, or to attend to a request or query from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR is applicable, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.



Principles applicable to the processing of personal data



The processing of the User’s personal data will be subject to the following principles contained in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:



Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times after completely transparent information about the purposes for which personal data is collected.



Principle of purpose limitation: personal data will be collected for determined, explicit and legitimate purposes.



Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.



Principle of accuracy: personal data must be accurate and always up to date.



Principle of storage limitation: personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of its processing.



Principle of integrity and confidentiality: personal data will be processed in a way that ensures its security and confidentiality.



Principle of proactive responsibility: the Controller will be responsible for ensuring that the above principles are met.



Categories of personal data



The categories of data processed in Harry Jo are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.



Legal basis for the processing of personal data



The legal basis for the processing of personal data is consent. Harry Jo commits to obtaining the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.



The User shall have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.



On occasions when the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.



Purposes of processing for which personal data are intended



Personal data is collected and managed by Harry Jo with the purpose of being able to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend to a request or query.



Likewise, the data may be used for commercial purposes of personalization, operational and statistical, and activities proper to the corporate purpose of Harry Jo, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation through the Website.



At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data is intended; that is, the use or uses that will be given to the information collected.



Personal data retention periods



Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 120 months, or until the User requests its deletion.



At the time personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when that is not possible, the criteria used to determine this period.



Recipients of personal data



The User’s personal data will not be shared with third parties.



In any case, at the time personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.



Personal data of minors



Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of their personal data in a lawful manner by Harry Jo. If it is a minor under 14 years of age, the consent of parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.



Secrecy and security of personal data



Harry Jo commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the collected data, to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication or access to such data.



The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.



However, because Harry Jo cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to communicate to the User without undue delay when a personal data security breach occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data security breach is understood as any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication or access to such data.



Personal data will be treated as confidential by the Data Controller, who commits to inform and guarantee by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.



Rights derived from the processing of personal data



The User has over Harry Jo and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:



Right of access: It is the User’s right to obtain confirmation of whether Harry Jo is processing their personal data or not and, if so, obtain information about their specific personal data and the processing that Harry Jo has carried out or is carrying out, as well as, among other things, the available information on the origin of such data and the recipients of the communications made or planned of the same.



Right to rectification: It is the User’s right to have their personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.



Right to erasure (“the right to be forgotten”): It is the User’s right, unless current legislation establishes otherwise, to obtain the erasure of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a product of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of its application, shall take reasonable measures to inform controllers who are processing the personal data of the data subject’s request for erasure of any link to those personal data.



Right to restriction of processing: It is the User’s right to limit the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to processing.



Right to data portability: In case the processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.



Right to object: It is the User’s right to object to the processing of their personal data or to cease the processing of the same by Harry Jo.



Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise. Thus, the User may exercise their rights by telephone communication addressed to the Data Controller, specifying:



Name, surname of the User and sending a copy of the ID to the address provided by the controller by phone. In cases where representation is allowed, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the ID may be replaced by any other means valid in law that proves identity.



Request with the specific reasons for the request or information to be accessed.



Address for notifications.



Date and signature of the applicant when sending the ID.



Any document that supports the petition being made.



This request and any other attached document may be sent to the address and/or email that is provided during the phone call:



Postal address: Calle Colón 22 Primera planta – 46004 Valencia, Spain.



Links to third-party websites



The Website may include hyperlinks or links that allow access to third-party web pages different from Harry Jo, and therefore not operated by Harry Jo. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.



Complaints to the supervisory authority



In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State where they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es).



II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY



It is necessary for the User to have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website will imply acceptance of the Website’s Privacy Policy.



Harry Jo reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to stay informed about the latest changes or updates.



This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights.



III COOKIE POLICY AND LINKS



COOKIE POLICY



Access to this Website may involve the use of cookies. Cookies are small amounts of information stored in the browser used by each User — on different devices that may be used to navigate — so that the server can remember certain information that will only be read later by the server that implemented it. Cookies facilitate navigation, make it more user-friendly, and do not harm the navigation device.



The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website, and the sites visited immediately before and after the same. However, no cookie allows contact with the User’s phone number or any other personal contact method. No cookie can extract information from the User’s hard drive or steal personal information. The only way for the User’s private information to be part of the Cookie file is if the User personally provides that information to the server.



Cookies that allow identifying a person are considered personal data. Therefore, the same will be subject to the Privacy Policy described above. In this sense, the use of the same will require the User’s consent. This consent will be communicated, based on an authentic choice, offered through an affirmative and positive decision, before initial processing, removable, and documented.



Own Cookies



These are cookies that are sent to the User’s computer or device and managed exclusively by Harry Jo for the proper functioning of the Website. The information collected is used to improve the quality of the Website and its Content and the User’s experience. These cookies allow recognizing the User as a recurring visitor to the Website and adapting the content to offer them content that suits their preferences.



The entity(ies) responsible for supplying cookies may cede this information to third parties, whenever required by law or if a third party processes this information for said entities.



Social Network Cookies



Harry Jo may incorporate social network plugins, which allow access to them from the Website. Therefore, social network cookies may be stored in the User’s browser. The owners of these social networks have their own data protection and cookie policies, being responsible for their own files and privacy practices. The User must refer to them to be informed about these cookies and, if applicable, the processing of their personal data. For informational purposes only, the links to consult these privacy and/or cookie policies are indicated below:



Facebook: https://www.facebook.com/policies/cookies/



Twitter: https://twitter.com/es/privacy



Instagram: https://help.instagram.com/578547622496121164148830634370all?ref=ig



Youtube: https://policies.google.com/privacy



Google+: https://policies.google.com/technologies/cookies?hl=es



Pinterest: https://policy.pinterest.com/es/privacy-policy



LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies



Disabling, Rejecting, and Deleting Cookies



The User can disable, reject, and delete cookies — totally or partially — installed on their device through the browser settings (including, among others, Chrome, Firefox, Safari, Edge, Brave, etc.). In this sense, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must refer to the instructions provided by the Internet browser they are using. If they reject the use of cookies — totally or partially — they can continue using the Website, although they may have limited use of some of the Website’s features.



Changes to the Cookie Policy



It is possible that the Cookie Policy of the Website may change or be updated, so it is recommended that the User review this policy each time they access the Website to stay adequately informed about how and why we use cookies.



LINK POLICY



It is informed that the Harry Jo Website makes available to Users means of linking (such as, among others, links, banners, buttons), directories, and search engines that allow Users to access websites owned and/or managed by third parties.



The installation of these links, directories, and search engines on the Website is intended to facilitate Users’ search for and access to information available on the Internet, without it being considered a suggestion, recommendation, or invitation to visit them.



Harry Jo does not offer or commercialize, either directly or through third parties, the products and/or services available on these linked sites.



Furthermore, it does not guarantee the technical availability, accuracy, truthfulness, validity, or legality of external websites that can be accessed through these links.



Harry Jo will not review or control the content of other websites, nor will it approve, examine, or make its own the products and services, contents, files, and any other material existing on the linked sites.



Harry Jo will not assume any responsibility for the damages and harm that may be caused by accessing, using, quality, or legality of the contents, communications, opinions, products, and services of websites not managed by Harry Jo and linked to this Website.



The User or third party who creates a hyperlink from a page on another website to the Harry Jo Website should know that:





It is not permitted to reproduce — totally or partially — any of the Contents and/or Services of the Website without Harry Jo’s express authorization.



It is not permitted to make any false, inaccurate, or incorrect statement about the Harry Jo Website, nor about the Contents and/or Services of the same.



Except for the hyperlink, the website on which the hyperlink is established will not contain any element of this Website protected as intellectual property by Spanish law, unless authorized by Harry Jo.



The establishment of the hyperlink does not imply the existence of relationships between Harry Jo and the owner of the website from which it is created, nor the knowledge and acceptance of Harry Jo of the contents, services, and/or activities offered on said website, and vice versa.