1st LAYER OF THE PRIVACY POLICY

CV SUBMISSION FORM

EXTENDED PRIVACY POLICY OF MIDOKURA (2nd LAYER)

MIDOKURA wishes to provide the users of the website www.midokura.com (hereinafter, the “Website”) with all the information about the processing we carry out with their personal data in a transparent way. Therefore, MIDOKURA makes accessible at its Website this extended privacy policy (hereinafter, the “Privacy Policy”) so that the users of the Website are informed of the purposes for which We process their personal data and the rights they can exercise according to the EU 2016/679 General Data Protection Regulation (hereinafter, the “GDPR”).

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA AND HOW CAN YOU CONTACT US?

The company responsible for processing the personal data of the users of the Website (hereinafter, the “Users” or the “Personal Data Subjects” or “You”) is MIDOKURA IBERICA, S.L. (hereinafter, “MIDOKURA” or the “Data Controller” or “We”), company holder of Tax Identification Number B-67006965, with registered office in C/ Tanger 37, 08018 Barcelona (Barcelona) Spain and duly registered in the Mercantile Registry of Barcelona, in the Book 45970, Page 68, Section 8, Sheet 505488, inscription 1^st.  As set forth in the GDPR, MIDOKURA processes the personal data of its Website Users as a Data Controller.

If you have any questions about the processing we carry out on your personal data, you can contact us by email sent to info@midokura.com.

• WHAT IS A PERSONAL DATA AND WHAT IS PERSONAL DATA PROCESSING?

Personal data is any information that identifies or that can identify a person, for example, the name and surnames, the ID number, the telephone number, email address, date of birth and gender, numerical identifiers such as the IP address of your computer or the information obtained through cookies, amongst others. On the other hand, a personal data processing is any operation or set of operations that we carry out on your personal data, such as, for example, the collection, registration, conservation, use and communication of your data.

• WHAT PERSONAL DATA WE COLLECT FROM USERS?

In order to carry out the data processing that we specify in this Privacy Policy, we need to collect certain information about the Users of the Website. Therefore, we collect the information provided by Users through the different channels of interaction and communication of MIDOKURA for each processing. The data we may collect are the following:

• Name and surname.
• Address, email address, telephone number.
• Information contained in the Curriculum Vitae such as date of birth, residence permit, academic record, professional career, titles, skills, certifications, references, etc.
• Information about your use and browsing through the Website (web page from which you arrived at the Website, layers of it visited, processes initiated and abandoned, IP address, type of device from which to access, time you have stayed on the Website, etc.).
• Any information you may provide us when contacting us by any channel.

• THROUGH WHAT CHANNELS DO WE COLLECT USERS’ PERSONAL DATA?

In MIDOKURA we collect and process the information provided by Users through the following channels:

• CV submission form on the Website.
• Interaction with MIDOKURA contacting us by email. 
• Interaction with the Website and with MIDOKURA in social networks: through the use you make of the Website when browsing it and through the interaction you may have with MIDOKURA through the company’s corporate profiles on social networks such as, for example, Facebook, Instagram, Linkedin or Twitter.

• WHAT RIGHTS CAN USERS EXERCISE REGARDING THEIR PERSONAL DATA?

1. Right of access

You have the right to know if MIDOKURA is processing your personal data and, in such a case, you have the right to know what data We process.

• Right of modification

You have the right to modify those personal data of yours that are inaccurate or incomplete. To do this, you must indicate what personal data you want Us to modify and prove them properly to be accurate and true.

• Right to object

In the cases set forth in the GPDR You can object at any time for reasons related to your particular situation, to our processing of your personal data. In the particular case of the personal data processing we carry out, You can object to all of them, except for the maintenance of the deletion lists, as it is a legal obligation of MIDOKURA.

• Right of erasure

You can request Us to delete your personal data. This does not mean that your data will be totally deleted, but that your data will be kept duly blocked in such a way as to prevent its processing, without prejudice to its making available to public entities, judges and courts for the attention of possible responsibilities that derive from the processing an only for the limited period of prescription of such responsibilites.

• Right to data portability

You have the right to receive and/or transfer to another data controller different to MIDOKURA those personal data concerning You and that You have provided to us.

• Right to limit the processing

You have the right to ask us to suspend the processing of your data where (i) you have complained about the accuracy of your personal data, while MIDOKURA verifies such accuracy; or (ii) you have exercised your right to object to the processing of your data, while verifying whether the legitimate reasons of MIDOKURA prevail over yours as an interested party. Likewise, this right allows you to request MIDOKURA to keep your personal data when (i) the data processing is unlawful and as a data subject You object to the deletion of your data, requesting instead a limitation of its use; or (ii) MIDOKURA no longer needs your personal data for the purposes of the processing, but needs them for the formulation, exercise or defense of claims.

You can exercise your rights always and at any time by sending your request in writing to Us by email to the address info@midokura.com and proving in any case your identity. We also inform You that, in the event that you consider that MIDOKURA has not correctly satisfied the exercise of your rights, you can file a claim at the Spanish Agency for Data Protection (AEPD), as You can see in its website http://www.aepd.es.

• HOW DO WE PROCESS YOUR PERSONAL DATA AND FOR WHAT PURPOSES?

In order to inform Users transparently and in detail about the purposes for which we process their personal data, we have proceeded to separate the information related to each processing in independent tables. Thus, you will be able to find all the specific information on each of the processings that we carry out on your data in its corresponding table individually. Each descriptive table of the corresponding processings includes the following information:  

• For what purposes do we process your data? 

In this column we explain for what purpose We process your personal data.

• On what legal basis do we process your data? 

This column explains the legal basis or justification that allows us to lawfully process your personal data. Data protection regulations require that we process your data on a legal basis or justification that legitimizes such processing. Thus, to process the personal information of the Users we can base ourselves on different bases or legal justifications depending on the processing that we carry out of your data. The legal bases for the processing of your personal data can be:   

• Legitimate interest: MIDOKURA may have a legitimate interest in performing certain processing of the personal data of Users. In any case, this legitimate interest is based on an analysis of the proper balance of our interests in processing your personal data and the rights and freedoms of the Interested Parties. The result of said analysis will determine whether we can use your personal information for the processings described in this Privacy Policy.

• The execution of a contract: If MIDOKURA should necessarily process personal data of the Users to comply with an existing contract between the Users and MIDOKURA. In order to be able to do so, the refusal to provide us with those personal data that are necessary to execute said contract or to carry out data processing inherent to it by an Interested Party, would imply the impossibility of being able to execute said contract.

• Compliance with a legal obligation: MIDOKURA acts as the controller of the personal data of the Interested Parties and must comply with a series of obligations imposed by accounting, tax, commercial, crime prevention, etc. regulations. In those cases, in which the legal justification for the processing of personal data is the fulfilment of a legal obligation, the Interested Parties may not oppose their processing.   

• Your consent: If MIDOKURA wishes to carry out any processing of your data whose legal justification cannot be based on any of the reasons explained above, we will previously request your consent for such processing. In any case, we will duly inform the User in advance of all the aspects derived from said processing and the User can always withdraw their consent once they have provided it.

• How long do we keep your personal data? 

This column informs as a guide for how long your data will be kept. The conservation time will depend in any case on the processing that is carried out of your personal information. Users must consider that certain data protection regulations, among others, may oblige us to keep certain data of the Data Subjects for a certain time.

Below, you will find the different processing that MIDOKURA carries out of your personal data described in greater detail:  

1. Recruiting processes

• Maintenance of updated deletion lists

• Analysis of use, operation and improvement of the Website

• WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Under this Privacy Policy and only when necessary, according to the nature of each data processing, MIDOKURA will communicate the personal data of the Users to the company belonging to the Midokura Group, specified in https://www.midokura.com/contact/ , for which You sent your job application so that this company can assess your application and consider your CV in the corresponding recruiting process.

Likewise, upon legal, judicial or administrative request in writing and/or when necessary for the fulfilment of a legal obligation required of MIDOKURA that legitimizes the communication, MIDOKURA may communicate the personal data of the Users to the following entities:

• Legal advisers
• Courts and tribunals
• Tax administration
• Government bodies and Public Administrations
• Security forces and bodies
• Spanish Data Protection Agency

Likewise, we may communicate your personal information in the following cases:

1. If We, or substantially all our assets, are acquired by a third party, in which case, personal data we hold about our users will be one of the transferred assets. type Users will be duly informed and communicated if any operation of this kind takes place.

• To protect the security and rights of our staff, our users, and our information systems. This includes exchanging information with security forces and bodies or Courts in cases of detection of fraud, identity theft or any other use, processing or illicit act.

• ARE YOUR PERSONAL DATA SAFE?

In order to ensure a fair and transparent processing of your personal information, we will adopt the appropriate procedures that will include the implementation of technical and organizational measures that consider the possible risk and correct any inaccuracies identified in the personal data processed, so that the risk of any error is minimized, processing your data in a fair and secure manner. We do not transfer your personal data outside the European Economic Area except if You send Us your CV for applicating for a job position in the company part of the Midokura Corporate Group based in Japan. In this case, we must inform you that Japan was considered in 2019 a safe country by the European Commission by the Commission Implementing Decision (EU) 2019/419 of 23 January 2019 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by Japan under the Act on the Protection of Personal Information.

All the information you provide to us will be stored on secure servers. Thus, once we have received all your information, we will use strict security procedures to try to prevent any unauthorized access. Unfortunately, the transmission or communication of information over the Internet is not completely secure.

Likewise, we ensure that our service providers do also have adequate security standards for the protection of personal data to which they have or may have access, in accordance with the applicable data protection legislation in force every moment.

• CHANGES IN THIS PRIVACY POLICY

This Privacy Policy may vary over time due to possible changes in criteria followed at any time by the Spanish Agency for Data Protection, the legislative changes that may take place and the jurisprudential pronouncements that are applicable to this Privacy Policy as well as the procedures and needs of MIDOKURA and its corporate group. MIDOKURA therefore reserves the right to modify this Privacy Policy in order to adapt it to said criteria, as well as to new jurisprudence or legislation or any change of the company and its processes and needs.

Current version as of: 2022