Privacy Policy

Privacy Policy

Last updated: July 2025

Introduction

In accordance with European data protection regulations contained in Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons (hereinafter, GDPR) and Spanish regulations, Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (hereinafter, LOPDGDD), this section aims to explain our Privacy Policy and detail the information regarding the processing of personal data we carry out, as well as to inform users of the rights they may exercise to maintain control over their data and comply with the duty of information required by the aforementioned legislation.

Identification of the controller of personal data

The owner, operator of the website, and data controller is:

• Company name: Neurovest Holding S.L.U.

•ID: B21837422

• Registered office: Paseo de Ronda, OTR 82, puerta B, 25006 Lleida, Spain

• Telephone: +34 690 36 53 60

• Email: joel@neurovestholding.com

How and why do we process your personal data?

As a User, you can browse our Website without providing personal data. However, any personal data collected directly from you, through forms, or through your voluntary submission, will be treated confidentially and as specified in this Privacy Policy, and will be incorporated into our corresponding processing activity log.

The data collected will always be collected with your consent and will be stored for the period strictly necessary to fulfill the purposes described above and in relation to each type of processing.

Below, we detail how we process your data based on the context and purpose of the data collected:

• PURPOSE OF PROCESSING: Manage any type of request, suggestion, or petition. Contact the sender of the information, respond to their request, petition, or query, and conduct subsequent follow-up.

SOURCE OF LEGAL BASIS (LEGAL BASIS): Consent of the data subjects. Legitimate interest to respond to information requests through communication channels.

RECIPIENTS: Data will not be transferred to third parties, except where legally required.

RETENTION PERIOD: Until your information request is resolved or as long as the business relationship continues.

• PURPOSE OF PROCESSING: Manage and control the client, pre-client, and supplier portfolio

SOURCE OF LEGAL BASIS (LEGAL BASIS): Contractual relationship for the execution of a contract.

RECIPIENTS: No transfer of data to third parties is planned, except under legal obligation or for the execution of the service provision contract itself.

RETENTION PERIOD: For the duration of the contractual relationship for the execution of a contract.

• PURPOSE OF PROCESSING: Provision of services and marketing of products: Offering services, products, and activities so that we can quote, provide, manage, and execute the services.

SOURCE OF LEGAL BASIS (LEGAL BASIS): Consent of the interested parties. Legitimate interest to respond to information requests through communication channels.

RECIPIENTS: No transfer of data to third parties is planned, except under legal obligation or for the execution of the service provision contract itself.

STORAGE PERIOD: Until your information request is resolved or for the duration of the business relationship.

• PURPOSE OF PROCESSING: Commercial communications. Sending promotional communications and newsletters via email. To provide information about activities, articles of interest, e-books, and general information about our services via email (email, SMS, WhatsApp), as well as by telephone.

SOURCE OF LEGITIMACY (LEGAL BASIS): Consent of the data subject and legitimate interest.

RECIPIENTS: Mailing service providers and collaborators within and outside the European Union who support us in sending communications.

RETENTION PERIOD: Data will be retained for the time necessary to fulfill the purpose for which it was collected or until the user revokes their consent.

• PURPOSE OF PROCESSING: Management of the exercise of User rights.

SOURCE OF LEGITIMACY (LEGAL BASIS): Legal obligation of the data controller.

RECIPIENTS: Data will not be transferred to third parties except under legal obligation.

RETENTION PERIOD: For the time necessary to respond and to comply with the legal deadlines established to address potential liabilities.

• PURPOSE OF PROCESSING: Tax, accounting, commercial, and legal management

SOURCE OF LEGAL BASIS: Legal obligation of the controller.

RECIPIENTS: Data is transferred to data processors under contract to provide services.

RETENTION PERIOD: For the time necessary to respond and comply with the legal deadlines established to address potential liabilities.

How do we obtain your personal data?

The personal data we process is collected through the information you provide directly to us, either through any form and/or the means we make available on our Website, or through the service provision contract or Data Processor.

By completing any form available on our Website, you give us your consent to: (i) process your personal data for the purposes mentioned above; (ii) receive communications and newsletters about news and Service offers; (iii) respond to your inquiries and requests.

The categories of data we process are:

• Identification data (first name and, where applicable, last name)

• Email address and/or telephone number (depending on the medium used)

• Postal address

• Commercial information

• Financial information

As well as any other data you include in the communications you send us. Specially protected data is not processed.

Necessary, up-to-date information and accuracy of the data

When you provide us with your information to use our services, you guarantee that the information provided is true, accurate, up-to-date, and yours.

To ensure that the information provided is always up-to-date and error-free, please notify us of any corrections or modifications to the data provided as soon as possible. You are responsible for the truthfulness and accuracy of the data provided at all times.

You can contact us at the following email at joel@neurovestholding.com

What are your rights regarding the processing of your data?

Everyone has the right to obtain confirmation as to whether their personal data is being processed. Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

The rights you have and are recognized in current regulations are the following:

Right --> What does it mean?

Right of access --> You have the right to obtain from us: a) confirmation of whether or not we are using your personal data and, where appropriate, access to said data; b) obtain detailed information about certain aspects of the processing being carried out; c) obtain a copy of your personal data being processed.

Right to rectification --> You have the right to obtain: a) the rectification of your inaccurate personal data; b) the completion of incomplete or inaccurate data.

Right to erasure (right to be "forgotten") --> Allows you to request the deletion or removal of your personal data when there is no reason to continue using it. In any case, deletion will be subject to the limits established in the regulatory standard.

Right to restriction of processing --> You have the right to request restriction of the processing of your personal data, in which case we will only retain it for the exercise or defense of legal claims. You have the right to "block" or delete further use of your personal data.

Right to data portability You have the right to access your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller when: (i) the processing is based on previously granted consent; and (ii) the processing is carried out by automated means.

Right to object to processing For reasons relating to your particular situation, you have the right to object to the processing of your data for direct marketing purposes and not to be subject to a decision based solely on automated processing, including profiling. In such a case, we will stop processing the data except for legitimate, compelling reasons, or the exercise or defense of potential legal claims.

Right to withdraw consent --> If you have given your consent for the processing of personal data, you have the right to withdraw it at any time.

How can you exercise your rights?

As the affected party in the management of personal data, you may exercise the aforementioned rights at any time by contacting us, as the data controller, through the following email address: joel@neurovestholding.com, stating the right exercised in the "Subject", or by submitting a letter, along with your identification, to the postal address: Paseo de Ronda, OTR 82, puerta B, 25006 Lleida, Spain.

You can obtain more information about your rights in the Citizen's Guide published by the AEPD, which you will find at the following link:

https://www.aepd.es/sites/default/files/2020-05/guia-ciudadano.pdf

How do we protect your data? Security measures

The data of our customers and suppliers is a very important asset to us. Therefore, we have adopted the legally required security levels and ensure that we implement and install all additional technical means and measures within our reach to prevent the loss, misuse, alteration, unauthorized access, and theft of the personal data you may have provided to us.

Data transfers, third-party services, and international data transfers

We contract third-party service providers to provide us with a variety of services and functions, such as web server hosting, system maintenance, technical support, and marketing communications.

We may share personal data with our service providers subject to confidentiality obligations consistent with this Policy and on the condition that the service providers use your personal data only on our behalf and in accordance with our instructions.

Likewise, in the course of processing your personal data, it may be transferred or transmitted outside of your country of origin, for example, to the United States. These transfers support the actions and purposes of processing personal data described above.

When we transfer personal data to other countries, we seek highly trusted partners and establish appropriate safeguards (such as data processor contracts, international transfer agreements, or clauses) in accordance with relevant legal requirements and in compliance with the standards of the local data protection authority.

Website Navigation and Cookie Policy

This Website may use Cookies for analytical, statistical, and advertising purposes.

In such cases, Users will be notified to obtain their appropriate consent and will be offered management tools to restrict or apply the use of Cookies.

Under no circumstances will cookies or other similar means be used to store information that allows the identification of the natural person using the Website.

For more information, see the Cookie Policy section.

Embedded Content and Links to Third Parties

Our Website may provide links to other websites, but we do not assume any responsibility, directly or indirectly, for the privacy policies adopted by the linked pages.

Links to other websites are provided only as a suggestion and do not imply any guarantee or responsibility on our part regarding the quality, accuracy, or content of the information provided therein.

In addition, some of our services contain embedded content controlled by third parties that is used to share information via social media or to display videos or images.

When you interact with these services, they may collect information about you and your interaction with their content. This activity will be subject to the privacy policy and settings of the third party's network or service.

Please note that they may track your activity through the use of cookies or similar tracking technologies, without you having to interact with them. If this concerns you, be sure to log out before using our Website and carefully read our Cookie Policy.

Privacy Policy Changes

We reserve the right to modify our data processing policy at any time and without prior notice.

The modification of this Privacy Policy will be available to users and will be applicable from the moment it is published on the Website. Whenever new consent is required, it will be properly collected.

Complaints and Supervisory Body

If you believe that your rights have not been adequately respected, you can file a complaint with the Spanish Data Protection Agency (hereinafter, AEPD) by contacting: C/. Jorge Juan, 6, 28001, Madrid, or by accessing its website at: www.agpd.es