FIRST LAYER

Summary of the privacy policy of the portal and APP

DATA CONTROLLERS

"INSPIRING BENEFITS S.L.

PURPOSE OF PROCESSING

To communicate and facilitate the use of offers and discounts within discount portals.

• Registration in the discount portal and piggy bank.
• Selection of offers of interest based on user profile.
• Communication of offers.
• Intermediation of offers.
• Transaction management and piggy bank payment.
• Incident resolution.
• Cancellation of membership in the Discount Portal.

LEGAL BASIS

• The performance of a contract to which the data subject is a party.
• The consent of the User, for ancillary processing. Accessory treatments are understood to be those different from those initially foreseen, and which complement the service provided to the User.

TARGET

Providers of technology infrastructure services, all in their capacity as data processors.

RIGHTS

Access, portability, restriction of processing, objection, information, rectification and deletion.
Withdrawal of consent.

The rights may be exercised in advance:
lopd@inspiringbenefits.com

PRIVACY POLICY

In this document we explain the processing of your personal data as a user of the services of this Platform.

Before submitting any data through the registration form, make sure you fully understand the terms of the privacy policy. If you need any clarification in this regard, you can write to us at the following email address: atencion.cliente@inspiringbenefits.com

The correct provision of the services we offer you is based on the data you provide being truthful. If you provide false information, you will be responsible for any damage that may be caused to INSPIRING, the contracting company or any other third party.

Who is responsible for my data?

On the other hand, INSPIRING BENEFITS, as the company providing the service, will be responsible for processing your data in order to provide you with offers and discounts that may be of interest to you. These are its identification and contact details:

Responsible for data processing
INSPIRING BENEFITS S.L.
Company address
Calle Velázquez 86-D - 28006 (Madrid)
CIF
B85936680
Email address
atencion.cliente@inspiringbenefits.com
Data Protection Officer e-mail
dpd@inspiringbenefits.com
Registration details
Registro Mercantil de Madrid, Tomo 28.105 Folio 125 Sección 8 Hoja M-506370.

INSPIRING BENEFITS is a company of the Aon Group in Spain (you can see a list of the companies that make up the Aon Group in Spain here [https://www.aon.com/spain/legal.jsp]). Aon Group companies in Spain are subsidiaries and/or affiliates of Aon Plc, a leading global professional services company offering a wide range of risk, retirement and health solutions. A full list of our group entities can be found at [https://www.aon.com/site/aonworldwide.jsp].

INSPIRING BENEFITS (hereinafter INSPIRING) makes these services available to you because it has been requested to do so by HolaBank ("HolaBank"). This organisation wishes to provide you with a range of benefits through discounts and offers on goods and services. To identify this organisation in this document, we will refer to it as a "Contracting Company". For more information, see the definitions in the Terms and Conditions.

How do we process your personal information?

1. Registration management via the website

In order to start using the services offered by the Platform, we will ask you to fill in a registration form in which we will ask you for some data that will allow us to verify that you are a member of the Beneficiary Collective and thus to register you on the website.

2. Management of user preferences

Once you have registered on the Website, you will have the opportunity to provide further information from your user profile. You are not required to complete your profile in order to use the Platform. If you choose to do so, we will use this information to personalise the service in accordance with your preferences.

3. Selecting content that may be of most interest to you and profiling your use of the Platform.

Based on the configuration you have made in your profile, the actions you have taken and the searches you have made on the Portal, we select the content that we believe is of most interest to you. This means that we will carry out an automated analysis of your profile and preferences in order to decide what type of content may be of most interest to you and to inform you about it, unless you indicate that you do not want us to carry out this analysis of your profile by exercising your opt-out rights as set out below.

4. Sending communications by electronic means

One of the main purposes of the service we offer is to keep you informed about the content of the Portal, which may be commercial in nature, depending on the services or functionalities activated by the contracting company.
If you do not want us to send you these communications, generally by e-mail, you can deselect this option in your profile during registration or at any time thereafter. You will also be given the opportunity to unsubscribe from any communication you receive. Please note that in this case you will not be able to hear about new content or services.

5. Management of commercial transactions in the event that Discount Portals or Money Boxes are activated.

If the Service has been enabled by the Merchant, when you start to benefit from the discounts by making purchases from the Portal, we will process the data relating to the transactions you make. In other words, we may know which products or services you purchase in order to manage and resolve any incidents that may arise in the management of your purchases. And to be able to transfer the money you save to your piggy bank. We will ask you for your bank account number so that we can transfer the money to the Piggy Bank.

6. Receive calls about product and service offers for specific campaigns that you request to be subscribed to, and push notifications from the APP if Discount Portals or Piggy Banks are enabled.

If the Contracting Company has enabled the service, you can sign up for specific campaigns that you want us to call you about.
When you download the APP, you can configure whether you want to receive push notifications and also whether you want to allow us to geolocate you in order to send you offers based on your location.

7. Manage the invitations you send to other users to join the Portal, if this functionality is enabled.

If the service is enabled by the contracting company, you can invite other people to join the service. We do not store the email address of the person you invite. If you want that person to join the service, you must register that person directly. We do keep track of the number of people you invite because it helps us to know how satisfied you are with the service.

8. Resolution of incidents

In the event that you have a problem arising from your use of the service and you contact us to resolve it, we will ask you for your personal details over the telephone in order to resolve the incident.

9. To facilitate communication with other users where this functionality is enabled.

Where the service is enabled, users can communicate with each other via a notice board. The purpose of the bulletin board is to allow users to coordinate activities, post announcements, etc.
If you choose to use the notice board, the only information we will process is what you choose to post on the notice board. Please note that all portal members will be able to see the information you choose to post.

Why do we require you to accept this privacy policy?

Data protection legislation demands the existence of legal grounds that justify the processing of personal information of individuals.

The following table indicates the legal basis that legitimises the different processing of your personal data that we carry out:

Legal Basis

Provision of the service through the contractual relationship you establish with Inspiring.
When you register for the Discount Portal or the Piggy Bank Service and accept the Service Terms and Conditions and this Privacy Policy, you enter into a contractual relationship with INSPIRING for the following purposes:

• Registration on the platform and management of your user profile.
• Selecting offers that may be of interest to you based on the configuration of your profile and your shopping preferences.
• The management of transactions and the payment of piggy banks.
• The resolution of incidents.
• The organisation of events, activities and competitions, which are also governed by their own legal bases.

If you do not accept the Terms of Use and Privacy Policy, we will not be able to provide you with the service.
You may at any time object to us creating profiles of your preferences in order to inform you of offers.

Legitimate interest in relation to the functionalities you use.

To keep you informed by electronic means, generally by e-mail, about products and services related to the functionalities you use.

If you wish to opt-out of this processing, you can do so in two ways: unsubscribe from each communication you receive or modify your profile during registration or at a later point to indicate that you do not wish to receive any further electronic communications. In this instance, you will solely receive emails pertaining to technical matters and the functioning of the platform, like updates to privacy policies or terms of use.

Consent

Occasionally, we may ask your consent for processing that is not originally intended, such as accepting cookies that record your browsing and are not necessary for the operation of the platform or application.

You may also terminate your subscription to the service at any time by deleting your account in your profile.

Moreover, you're able to assert the rights detailed below and enquire about how we use your data.

Who are the recipients of your information?

The portal's services are available to you due to the decision of the contracting company to work with INSPIRING. For this reason, where applicable, we will provide the contracting company with a user ID (usually the employee ID or other similar ID) and your email address for the purposes of checking your registration and cancelling your membership of the Portal. This information is strictly used for administrative purposes.

Apart from what has already been stated, providing the service does not entail sharing data with third parties, unless we first obtain your consent.

Notwithstanding the above, we depend on suppliers to provide services, some of whom are situated outside the European Economic Area. In such instances, as well as having the relevant data access contract or Data Processing Addendum where we insist on the implementation of the most rigorous security measures, we also ask for adequate assurances to protect your privacy as a user.

If you require further details on the disclosure of your information to overseas recipients or the safeguards we have implemented (including a copy of the applicable contractual commitments, subject to confidentiality considerations), ensuring adequate protection of your personal data, kindly contact us.

Termination of the service by the contracting company

This data will be kept blocked for five years to solely respond to administrative or judicial requests. After this period, the User's data will be permanently deleted.

What rights do you have to guarantee that we take good care of your information?

As the data owner, you have certain rights to regulate the use of your data:

You may exercise your rights of access, portability, restriction of processing, objection, rectification and deletion of your data. Additionally, you may withdraw your consent for consent-based processing, though this will not impact any processing conducted prior to the withdrawal.
You have the right to object to the processing of your data for receiving commercial communications via electronic means.
You may also exercise your right to object to the analysis of your purchase profile for determining which offers may be of greater interest to you.

To exercise any of these rights, please contact us via email at lopd@inspiringbenefits.com.
And if you feel that your rights have not been sufficiently addressed, you can make a complaint to the Data Protection Officer we have appointed (dpd@inspiringbenefits.com) or, if necessary, to the UK Data Protection Authority.

How long will your data be retained?

Your personal data will be stored for as long as you use our services.

If you choose to unsubscribe, your data will only be processed for the Portal's services. We will retain your data for five years after blocking them to be able to respond to any requests from administrative or judicial authorities. Afterward, we will delete them without exception.

Do we ensure the security of your data?

INSPIRING has implemented the required technical and organisational measures to prevent the loss, misuse, alteration, unauthorised access, and theft of your personal data.
Additionally, we have established protocols to address any security breaches regarding your personal data within appropriate legal deadlines.

We commit to selecting suppliers who implement sufficient security measures to protect your data when hosting our technology. Additionally, we ensure your data is located within the European Economic Area or, if outside, with equivalent guarantees.
These suppliers process the data on our behalf as data processors.

What are cookies used for?

Cookies are utilized to analyse your browsing data. Please see our cookie policy for detailed information about the types of cookies used and the purposes served.

How does the portal handle links leading to external websites?

The portal may contain links directing to external webpages. However, INSPIRING has no authority over how these websites manage your personal information. Please refer to their privacy policies for information on how they will handle your personal data.

Will this privacy policy be revised?

Yes, this policy may be subject to alterations due to regulatory or business modifications, and in such case, we will inform you via email and post the changes at this location.

SPECIFIC POLICIES

Savings plugin

If you choose to install the discount button on your browser, it does not collect data on your identity or the activity you carry out. The button is limited to identifying and informing you of offers available at the portal related to the product or service you are visiting when you browse the Internet. These actions are carried out in your browser, without any information being sent to our platform about your browsing history.