In compliance with the legislation, VIAFISIO, SL, as the owner of the website www.clinni.com, proceeds to communicate the identification data required by the aforementioned regulation:

Company Name: VIAFISIO, SL
Registered Office: AP 7034 - 41005, Sevilla
Tax ID (CIF): B-91622753
Email Address: info@viafisio.com / hola@clinni.com

Registration Data in the Commercial Registry: Commercial Registry of Seville, Volume 4615, Folio 47, Sheet SE 72411.

This information shapes and regulates the conditions of use, limitations of liability, and obligations that users of the Web pages, Blogs, Social Networks, and other platforms for which VIAFISIO, SL is responsible must abide by.

"Page", domain www.clinni.com made available to Internet Users.

"User", individual or legal entity that uses or navigates the Page.

"Content", the pages that make up the entirety of the domain www.clinni.com, which contain the information and services that VIAFISIO makes available to Internet Users. They include messages, texts, photographs, graphics, icons, logos, technology, links, textures, drawings, sound and/or image files, recordings, software, appearance, graphic design, source codes, and in general, any kind of material contained on the Page.

"Website", technical term that describes the system for accessing information via the Internet, configured through pages created with HTML or similar language, and programming mechanisms such as java, javascript, PHP, among others, etc... These pages designed and published under an Internet domain name are the result of the information that the owner makes available to Internet Users.

"Hyperlink", technique by which a User can navigate through different Web pages, or through the Internet, with a simple click on the text, icon, button, or indicator containing the link.

"Services", Web pages, social networks, Blogs, and other platforms where VIAFISIO has a presence, and through which it offers services to users or establishes a communication channel with them, or disseminates the activities carried out by VIAFISIO.

"Cookies", technical means for the "traceability" and tracking of navigation on websites. They are small text files written on the User's computer. This method has privacy implications, so VIAFISIO will promptly and clearly notify of their use at the time they are implemented on the Page.

The mere use of the Websites, Blogs for which VIAFISIO is responsible or participation in Social Networks in which it is present (hereinafter 'the services') grants the user status and obligatorily implies the complete, full and unconditional acceptance of each and every one of the clauses and general conditions included in the Legal Notice. If the User does not agree with the clauses and conditions of use of this Legal Notice, they shall refrain from using the Websites, Blogs or participating in the Social Networks. This Legal Notice is subject to changes and updates, so the version published by VIAFISIO may be different each time the User accesses the services offered. Therefore, the User must read the Legal Notice on each and every occasion they use the services offered. Through the Website, Users are provided with access to and use of various Contents published via the Internet by VIAFISIO or authorized third parties. The User is obliged and undertakes to use the Services and the Contents in accordance with current legislation, the Legal Notice, and any other notice or instructions brought to their attention, either through this legal notice or elsewhere within the Contents that make up the services, as well as with the rules of coexistence, morality and generally accepted good customs. For this purpose, the User undertakes and commits NOT to use any of the Contents for illegal purposes or effects prohibited in the Legal Notice or by current legislation, harmful to the rights and interests of third parties, or that may in any way damage, disable, overload, deteriorate or prevent the normal use of the Contents, computer equipment or documents, files and all kinds of content stored on any computer equipment owned or contracted by VIAFISIO, other Users or any Internet user (hardware and software). Likewise, in accordance with all of the above, the User may not delete, manipulate or in any way alter the 'copyright' and other identifying data of the rights reservation of VIAFISIO or its owners, the digital footprints and/or identifiers, or any other technical means established for their recognition. The User must refrain from obtaining or even attempting to obtain the Contents using means or procedures other than those, as appropriate, made available for this purpose or indicated for this purpose on the Web pages where the Contents are found or, in general, those commonly used on the Internet for this purpose as long as they do not entail a risk of damage or disablement of the Website, and/or the Contents.

All trademarks, trade names or distinctive signs of any kind appearing on the Website are the property of VIAFISIO or, where appropriate, third parties who have authorized their use, without it being understood that the use or access to the services and Contents grants the User any rights over said trademarks, trade names and/or distinctive signs, and without any of the exploitation rights that exist or may exist over said Contents being understood to be assigned to the User. Similarly, the Contents are the intellectual property of VIAFISIO, or third parties where appropriate who have authorized their use, who have the exclusive exercise of the exploitation rights thereof in any form and, in particular, the rights of reproduction, distribution, public communication and transformation. Unauthorized use of the information contained on this Website, as well as the infringement of the Intellectual or Industrial Property rights of VIAFISIO or third parties included on the Website who have provided content, will result in the legally established responsibilities. The images and contents that users may publish or link through the services offered by VIAFISIO are not subject to copyright. It will be the user's responsibility for any claim made against VIAFISIO for infringement of the copyright of the contents that the user has published. (Community)

Those persons who intend to establish hyperlinks between their website and the services must observe and comply with the following conditions:

• Prior authorization will not be necessary when the hyperlink only allows access to the homepage, but it may not reproduce it in any way. Any other form of hyperlink will require the express and unequivocal written authorization from VIAFISIO.
• "Frames" will not be created with VIAFISIO's web pages or over VIAFISIO's web pages.
• No false, inaccurate, or offensive statements or indications will be made about VIAFISIO, its directors, its employees or collaborators, or about the people related to the Page for any reason, or about the Users of the Page, or about the Contents provided.
• It will not be stated or implied that VIAFISIO has authorized the hyperlink or that it has supervised or assumed in any way the Contents offered or made available on the website where the hyperlink is established.
• The website where the hyperlink is established may only contain what is strictly necessary to identify the destination of the hyperlink.
• The website where the hyperlink is established will not contain illegal information or content, contrary to morality and generally accepted good customs and public order, nor will it contain content contrary to any third party rights.

The function of the Hyperlinks that appear on this Website is exclusively to inform the user about the existence of other Websites that contain information on the subject. VIAFISIO is not responsible for the contents of such linked pages, the operation or usefulness of the Hyperlinks, or the result of such links, nor does it guarantee the absence of viruses or other elements in them that may cause alterations in the computer system (hardware and software), documents or files of the user, excluding any liability for damages of any kind caused to the user for this reason.

VIAFISIO does not guarantee the absence of interruptions or errors in accessing the Page or its Contents, nor that they are updated, although it will use its best efforts to avoid, correct, or update them. Consequently, VIAFISIO is not responsible for damages or losses of any kind caused to the User that are due to failures or disconnections in the telecommunications networks that cause the suspension, cancellation, or interruption of the Portal service during the provision of the same or prior thereto.

VIAFISIO excludes any liability for damages of any nature that may be due to the lack of availability, continuity, or quality of the operation of the Page and the Contents, or the failure to meet the expectation of utility that users may have attributed to the Page, the Contents, and the programs and applications existing on www.clinni.com

Access to the Page does not imply any obligation on the part of VIAFISIO to control the absence of viruses, worms, or any other harmful computer element. It is the responsibility of the User, in all cases, to have adequate tools for the detection and disinfection of harmful computer programs, therefore, VIAFISIO is not responsible for possible security errors that may occur during the provision of the Page service, nor for possible damages that may be caused to the User's or third parties' computer system (hardware and software), the files or documents stored therein, as a result of the presence of viruses on the User's computer used to connect to the Web's services and content, a malfunction of the browser, or the use of non-updated versions of the same.

Given the dynamic and changing environment of the information and content provided through the services, VIAFISIO makes its best effort, but does not guarantee the complete truthfulness, accuracy, reliability, usefulness and/or timeliness of the Content.

VIAFISIO excludes all liability for the decisions that the User may make based on this information, as well as for possible typographical errors that may be contained in the documents and graphics of the services. The information is subject to possible periodic changes without prior notice to its content by expansion, improvement, correction or updating of the Content.

All notifications and communications from VIAFISIO to the User made by any means shall be deemed effective for all purposes.

The provision of the service of the Website and the Contents is, in principle, of indefinite duration. VIAFISIO, however, is authorized to terminate or suspend the provision of the service of the Website and/or any of the Contents at any time. When this is reasonably possible, VIAFISIO will give prior notice of the termination or suspension of the Website.

VIAFISIO is present on social networks and/or platforms, and Blogs:
https://www.facebook.com/clinni/ https://twitter.com/ClinniApp https://www.youtube.com/channel/UCuyPjmFki27z6icyMd0JRVw

Any other unrelated account or Blog does not represent any official link with VIAFISIO, and therefore is exempt from any responsibility for content published on such social networks as it cannot exercise effective control over them. In any case, if the user experiences any type of incident regarding a link to a social network or blog accessed through VIAFISIO services, it can be reported to info@viafisio.com.

VIAFISIO will place within its services the corresponding access to each Social Network where it may have a presence. VIAFISIO will manage communications according to the terms and conditions of each platform or social network, and if assistance is needed regarding the management of the corresponding data, it can be directed to info@viafisio.com.

By becoming a fan or following us on the Social Networks where VIAFISIO may be present, the user expresses consent to:

1st) The processing of their personal data in the environment of the Social Networks where VIAFISIO may be present, in accordance with their privacy policies that can be consulted at
http://www.facebook.com/policy.php?ref=pf
https://twitter.com/privacy?lang=es
https://www.google.es/intl/es/policies/privacy/
https://blog.clinni.com/

2nd) VIAFISIO's access to the data contained in the Social Networks where the User registers; and

3rd) for news published about events related to VIAFISIO to appear on the wall or profile of the users of the Social Networks in which they participate.

VIAFISIO will not use the data for purposes other than those expressly referred to. To unsubscribe from the social networks where VIAFISIO is present and of which the user is a follower, it is only necessary to click on the hyperlink that appears with the text "Unlike", "stop following".

In case it is necessary to exercise the rights of access, rectification, cancellation, and opposition, it will be necessary to contact info@viafisio.com, indicating the intention to unsubscribe.

Likewise, in the context of this treatment, VIAFISIO can only consult the user's data as a follower of the Social Network in which they participate, or unsubscribe them.

Any additional rectification must be made through the user's account of the Social Networks in which the User participates.

User Conduct in the community, forums, blogs, and Social Networks where VIAFISIO may be present:

VIAFISIO does not guarantee that users of the services in which VIAFISIO may be present use the content offered in them in accordance with the law, morality, public order. Likewise, it does not guarantee the truth and accuracy, completeness and/or authenticity of the data provided by the Users.

VIAFISIO will not be responsible, neither directly nor indirectly, nor subsidiarily, for damages of any nature derived from the use of the Services and Contents of the Portals by Users or that may arise from the lack of truthfulness, accuracy and/or authenticity of the data or information provided by Users, or from the impersonation of a third party's identity carried out by a User in any kind of action through the services offered by VIAFISIO.

By way of example, but not limited to, VIAFISIO will not be directly, indirectly, or subsidiarily responsible for:

• the content, information, opinions, and statements of any User or third parties or entities communicated or displayed through the services offered by VIAFISIO.
• damages caused to third parties derived from the User's use of the services and contents offered by VIAFISIO.
• Damages caused by the lack of truthfulness, accuracy, or incorrectness of the users' identity and all the information they provide or make accessible to other users;
• damages derived from any user's infringements affecting the rights of another user, or third parties, including copyright, trademark, patents, confidential information, and any other intellectual and industrial property rights, as well as the use of users' images.

The user undertakes not to transmit, introduce, disseminate, and make available to third parties any type of material and information (data, content, messages, opinions, drawings, sound and image files, photographs, software, etc.) that are contrary to the law, morality, public order, and this Legal Notice. By way of example, and in no case limiting or excluding, the User undertakes to:

1. Not to publish content or propaganda of a racist, xenophobic, pornographic nature, promoting terrorism, or that infringe on human rights or the dignity of individuals.
2. Not to publish or disseminate data programs (viruses and harmful software) on the network that could cause damage to the computer systems of the access provider, its suppliers, or other Internet users.
3. Not to disseminate, transmit, or make available to third parties any type of information, element, or content that constitutes illegal or unfair advertising. The use of Users' email addresses for sending unsolicited advertising, links to websites, and any other type of communication that directly or indirectly promotes the activity of a third party is expressly prohibited.
4. Likewise, sending Users' email addresses "spam", "chain letters", "pyramid schemes", and offensive communications, attacks on the dignity of the advertiser, or contrary to laws and good customs is prohibited.
5. Publish false, ambiguous, or inaccurate information and content in a way that misleads information recipients.
6. Not to impersonate other users using their registration keys for the different services and/or contents of the Portals.
7. Not to use the distinctive signs, logos, trademarks of VIAFISIO for the user's exclusive benefit, and in any case without the proper authorization offered by VIAFISIO.
8. Not to publish, transmit, or make available to third parties any type of information, element, or content that constitutes a violation of intellectual and industrial property rights, patents, trademarks, or copyrights belonging to the owners of the Portals or third parties.
9. Not to disseminate, transmit, or make available to third parties any type of information, element, or content that constitutes a violation of communication secrecy and personal data legislation.

In order to control the content, we ask users to inform us by email at info@viafisio.com of any false or erroneous information, user attitudes and behavior, offensive comments, identifiable images that may be distasteful or offensive to morals and good customs, as well as any possible errors in the information provided, in order to remove the information or images, block certain users if necessary, and correct any erroneous information.

The Legal Notice is governed by Spanish law.
Copyright © 2020 - VIAFISIO, SL.
All rights reserved by the laws and international treaties on intellectual property. Its total or partial copying, reproduction or dissemination by any means is expressly prohibited.

Cookies are small data files that are received on the terminal from the visited website and are used to record certain browsing interactions on a website by storing data that can be updated and retrieved. These files are stored on the user's computer and contain anonymous data that is not harmful to their equipment. They are used to remember user preferences, such as the selected language, login data, or page customization.

Our website uses strictly necessary and essential cookies for you to use our websites and allow you to move freely, use secure areas, customized options, etc. In addition, we use cookies that collect data regarding the analysis of website usage. These are used to help improve customer service, measuring the usage and performance of the page, to optimize and personalize it. Our sites may also have links to social media (such as Facebook or Twitter). ViaFisio does not control the cookies used by these external websites. For more information about social media cookies or other third-party websites, we recommend reviewing their own cookie policies.

Cookie '_ga' from Google Analytics (Third-party. Generated by an external service) Every time a user visits a service, a tool from an external provider (Google Analytics) provides a web analytics service. This service is provided by Google, Inc., a company located at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States. Google uses cookies to carry out statistical analysis on the Web. The information collected by the cookies (including the IP address) is managed and stored by Google on its servers in the United States. Google uses this information and provides VIAFISIO with statistical data about the use of the website, being able to transmit this information to third parties in the specific legal cases provided for, or when such third parties process the information on behalf of Google. Google will not associate your IP address with any other data held by Google. The purpose of these cookies is:

• To know the number of visitors, and the browsing time on our website.
• To know which are the most visited contents.
• To know if the user is new, or has previously visited the website.

What if I do not want to have these cookies or do nothing about it?

To comply with current legislation, we have to ask for your permission to manage cookies. If you decide not to authorize the processing by indicating your non-conformity, we would only use technical cookies, as they are essential for browsing our website. In this case, we would not store any cookies. If you continue browsing our website without denying your authorization, it implies that you accept their use. Please note that if you reject or delete cookies for browsing our website, we will not be able to maintain your preferences, some features of the pages will not be operational, we will not be able to offer you personalized services, and every time you browse our website, we will have to request your authorization again for the use of cookies. If you still decide to modify the settings of your access to the website, you should know that it is possible to delete cookies or prevent this information from being recorded on your device at any time by modifying the configuration parameters of your browser:

• Internet Explorer cookie settings: https://windows.microsoft.com/es-es/windows-vista/block-or-allow-cookies
• Firefox cookie settings: https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we
• Google Chrome cookie settings: https://support.google.com/chrome/answer/95647?hl=es
• Safari cookie settings: https://support.apple.com/kb/HT1677?viewlocale=es_ES&locale=es_ES

These browsers are subject to updates or modifications, so we cannot guarantee that they fully match the version of your browser. It may also be that you use another browser not covered in these links such as Konqueror, Arora, Flock, etc. To avoid these discrepancies, you can directly access from the options of your browser, generally found in the Options menu, in the "Privacy" section. (Please consult your browser's help for more information.)

The CLINNI application has all the tools to comply with the security measures that guarantee data processing in accordance with the principles established in Regulation (EU) 2016/679 General Data Protection Regulation.

The mere use of the CLINNI application DOES NOT IMPLY compliance with all the provisions of Regulation (EU) 2016/679 General Data Protection Regulation. To comply with the security measures, it is necessary to implement them (assign profiles, establish periodic change of access keys, lock out after a certain number of access attempts is exceeded, in short, make the necessary adjustments in the application so that high-level security measures are met).

VIAFISIO is not responsible for the non-compliance by CLINNI users with the provisions of data protection legislation.
We provide you with the email address of our collaborator in data protection matters: pgaytan@pegysa.es

VIAFISIO, SL informs you that the personal data provided, as well as those you provide us throughout the contractual relationship, will be incorporated into files owned by the entity. The purpose of these is to manage the existing contractual relationship, as well as to inform you through the application itself about improvements to the CLINNI application.

If you wish to receive information by email about new products or services that VIAFISIO understands may be of interest to its customers, about acts and events organized or participated in by VIAFISIO, as well as to inform you about products from companies with which VIAFISIO collaborates, please send us an email to info@clinni.com indicating your willingness to receive them. The rights of access, rectification, erasure, and opposition may be exercised by written communication to the address of VIAFISIO, indicated in the heading of the legal notice, attaching reliable proof of the identity of the data subject, or by email to info@clinni.com

VIAFISIO, S.L., aware that the information managed in the design, development, hosting (websites) and maintenance of software: websites, management software and applications for mobile devices, is a resource of great value, has established an Information Security Management System (ISMS) in accordance with the requirements of the ISO/IEC 27001: 2005 standard to guarantee the continuity of information systems, minimize the risks of damage and ensure compliance with the established objectives.

The objective of the Security Policy is to set the necessary framework for action to protect information resources against internal or external, deliberate or accidental threats, in order to ensure information security, preserving its confidentiality, integrity, and availability.

The effectiveness and application of the Information Security Management System is the direct responsibility of the Information Security Commission, which is responsible for the approval, dissemination, and compliance with this Security Policy. In its name and representation, an Information Security Management System Manager has been appointed, who has sufficient authority to play an active role in the ISMS, supervising its implementation, development, and maintenance.

The Information Security Commission will proceed to develop and approve the risk analysis methodology used in the Information Security Management System.

Every person whose activity may, directly or indirectly, be affected by the requirements of the Information Security Management System, is obliged to strictly comply with the Security Policy.

VIAFISIO, S.L. will implement all necessary measures to comply with the applicable regulations regarding security in general and computer security, relating to the computer policy, the security of buildings and facilities, and the behaviour of its own employees and external users in the use of information systems. Likewise, the use of company-owned information without authorization or for purposes other than those for which it was conceived is prohibited, and appropriate disciplinary actions will be established against people who do not comply with the provisions established in this policy. The necessary measures to guarantee information security through the application of rules, procedures and controls must allow for securing the confidentiality, integrity, and availability of the information, which are essential for:

 
• Complying with current legislation regarding information systems.
 
• Ensuring the confidentiality of the data obtained and managed by VIAFISIO, S.L.
 
• Ensuring the availability of information systems, both in the services offered to clients and in internal management.
 
• Ensuring the capacity to respond to emergency situations, restoring the operation of critical services in the shortest possible time.
 
• Preventing undue alterations to the information.
 
• Promoting awareness and training in information security.

To register in CLINNI and be able to use the application you will have to follow these steps:

• Step 1: Free Registration.
• Step 2: Enter email.
• Step 3: Receive email with a link to verify the email.
• Step 4: Upon verifying the email, the clinni application opens in the browser, and at the same time an email with a link to the application is received.
• Step 5: Before using the application, it is necessary to fill in some data and accept the terms of use.
• Step 6: The requested data are the following: Name and password.

Once registered in Clinni, you have one month free full use of the application. After that period, you must activate the subscription if you want to continue enjoying the use of Clinni. The process is as follows:


• Step 7: Access Settings / Account (requires being an administrator of the center in Clinni) and click the button to activate the subscription.
• Step 8: Acceptance of the general Contracting conditions.
• Step 9: Payment. Payment will be made through the STRIPE payment application.
• Step 10: Once the payment is verified, you will receive an email confirming the payment, and the correct completion of the purchase process, and you can resume using Clinni.

The CLINNI application has all the tools to implement the technical and organizational measures that guarantee the security, confidentiality, availability, and control of unauthorized access and the principles provided for in the General Data Protection Regulation (679/2016 EU) and in Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights. The mere use of the CLINNI application DOES NOT IMPLY compliance with the provisions of the Data Protection regulations, nor compliance with the security measures provided for therein. It is necessary to have a Record of Processing Activities. To comply with security measures, it is necessary to implement them (assign profiles, establish periodic change of access keys, block after a certain number of access attempts, ultimately, make the necessary adjustments in the application, so that security measures are met). It is also necessary to regulate through data processing agreements the services provided by suppliers that may involve access to personal data. In short, it is necessary to comply with all the provisions of data protection legislation, both security measures (The CLINNI application has the tools to comply with them), and legal measures, compliance with which will be the responsibility of the Application administrator user. VIAFISIO is not responsible for CLINNI users' failure to comply with the provisions of data protection legislation.

The prices reflected on the website for subscribing to Clinni are shown WITHOUT the corresponding taxes since these are calculated based on the user's billing address. During the subscription activation process, the final monthly amount will appear on the screen with the taxes detailed for your specific case.

Payment will be made through the STRIPE payment platform. There is only one way to pay in Clinni: by clicking the button that implies the user's intention to activate a monthly subscription to Clinni. To do this, you must fill in the payment details (credit card) and billing information that Clinni will use on the user's invoice. If they were filled in on previous occasions, Clinni will remember them. Activating the subscription to Clinni involves activating a monthly payment, so unless the user indicates otherwise, a series of monthly payments will be initiated to keep the subscription active. The user has complete control over the status of their subscription, being able to cancel it at any time from the same place where it was activated. The system will always send an email before each monthly payment to notify the user. If the user cancels the subscription, they will still have access to Clinni activated for the remaining time they had already paid for, being canceled from the scheduled renewal date and, after canceling the subscription, it will not occur. More information about the payment and subscription processing platform (Stripe) can be found at https://stripe.com. The CLINNI application has all the tools to comply with the provisions of Organic Law 15/1999, of December 13, on the Protection of Personal Data, and the high-level computer and technical security measures provided for in RD 1720/2007, of December 21, which approves the regulation that develops it. The mere use of the CLINNI application DOES NOT imply compliance with the provisions of the GDPR, nor compliance with the security measures provided for in the implementing Regulation. It is necessary to register files with personal data in the General Data Protection Register. Likewise, for compliance with security measures, it is necessary to implement them (assign profiles, establish periodic password changes, block access after a certain number of failed attempts, ultimately, make the necessary adjustments in the application to comply with high-level security measures). VIAFISIO is not responsible for CLINNI users' failure to comply with the GDPR provisions. We provide you with the email address of our data protection collaborator: pgaytan@pegysa.es.

The CLIENT's data will become part of VIAFISIO, SL files for the following purposes:

• Control and management of the contractual relationship, of our activity, as well as for the management of the communications that may be maintained with the client during the execution of the contract.
• Maintenance of data for internal Historical and Statistical purposes of the organization.

To exercise the rights of Access, Rectification, Deletion, Opposition, Portability and Limitation of Treatment, you can do so by email, with conclusive proof of the requester's identity, addressed to info@viafisio.com or in writing addressed to VIAFISIO, SL, AP 7034 - 41005, Seville.

For the provision of our CLINNI management services, it is necessary to access information with personal data included in files of the CLIENT, and in many cases for the CLIENT to provide us with their databases, to host them in our information systems. This implies the performance of VIAFISIO as data processor. In compliance with the provisions of Article 28 of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter GDPR), and for the data controller to fulfill its obligation of diligence when choosing a data processor that offers sufficient guarantees to implement appropriate technical and organizational measures in accordance with the requirements of the GDPR, and ensures the protection of the data subject's rights, the requirements reflected in the aforementioned Article 28 are detailed below. The CLIENT files that will be accessed and processed by VIAFISIO, depending on the service provided, are as follows: CLIENTS. SUPPLIERS. MEMBERS. PATIENTS. HR PERSONNEL MANAGEMENT. COMMUNICATIONS MANAGEMENT. These processes will be included in the VIAFISIO Treatment Activities Register.

The duration of the treatment and the performance of VIAFISIO as data processor will be for as long as the contractual relationship is in force, which will be renewed annually if neither party expresses its decision to terminate the contract before its automatic renewal. Upon termination of the contractual relationship, VIAFISIO will return to the client the processed information in an editable and intelligible format, compatible with the client's programs or applications. VIAFISIO may only retain the processed information for the purpose of its defense against any actions that may be taken against it due to the service provided, and until such actions are time-barred. VIAFISIO is allowed to retain the data for Historical, statistical, scientific purposes, as well as for the development of internal company programs and IT solutions.

VIAFISIO will process the data following the CLIENT's instructions, and will process them only for the purposes provided for in the service contract. In no case may it use the data for its own purposes.

It will have a Record of Processing Activities, as provided for in article 30 of the GDPR, which will include the processing carried out on behalf of the CLIENT.

VIAFISIO subcontracts CLINNI's hosting services to AMAZON WEB SERVICES, or to the company that provides the hosting services should it change. Any other subcontracting of services not foreseen in this agreement will be informed to the clients and VIAFISIO will proceed to sign a data processing agreement with them.

VIAFISIO will inform all its personnel who, by virtue of this agreement, may access the CLIENT's information, and will proceed to sign a document that reflects their obligation of secrecy and confidentiality regarding the information they access. The CLIENT may demand to be shown the signed documents.

The security measures reflected in the VIAFISIO Procedures Manual, which will be available to clients who request it, are applied to the Customer's personal data.

VIAFISIO will notify the CLIENT of security breaches that may have occurred in the shortest possible time after becoming aware of them, which allows for studies on whether the information has been compromised.

A report will be sent regarding what happened, the measures that have been carried out to block the risk situation, and if customer personal data has been stolen or lost, what data, and whether the stolen information is susceptible to being accessed and used.

The report will include the following information:

1. Description of the nature of the personal data breach, including, where possible, the categories and approximate number of data subjects affected, and the categories and approximate number of personal data records affected.
2. Contact details for obtaining more information.
3. Description of the possible consequences of the personal data breach. Description of the measures adopted or proposed to remedy the personal data breach, including, where appropriate, measures adopted to mitigate possible negative effects.

If it is not possible to provide the information simultaneously, and to the extent that it is not, the information will be provided gradually without undue delay.

VIAFISIO, at the request of the CLIENT, will make the necessary information available to the controller to demonstrate compliance with its obligations, specifically the following:

Carrying out audits or inspections carried out by the controller or another external auditor authorized by him.

The Procedures Manual with the technical and organizational security measures implemented to guarantee the confidentiality, integrity, availability, and resilience of the processing systems and services.

The Technical description of the application(s) in which the data provided by the CLIENT for processing are processed.

Return the personal data and, if applicable, the media on which they are recorded, to the data controller once the service has been completed.

Attend to the requests of data subjects who exercise the rights recognized by law, which are communicated by the CLIENT.

Obligations of the data controller (CLIENT).

It is the responsibility of the data controller to:

1. Deliver the necessary data to the processor so that it can provide the service.
2. Have obtained verifiable consent for all the purposes for which the data provided for processing is intended to be processed.
3. Ensure, prior to and throughout the processing, compliance with the GDPR by the processor.
4. For the sending of information, Databases that are going to be subject to processing, the method in which the information will be delivered, the support, and the security measures that are applied to guarantee the confidentiality of the information will be agreed upon between the CLIENT and VIAFISIO.