CONFIDENTIALITY POLICY

01. GENERAL INFORMATION

INDUSTRIAS QUÍMICAS IRURENA S.A., a company domiciled in Azpeitia (20730 Gipuzkoa), Spain, Ctra. de Tolosa, s/nº apartado 30, telephone 943157099, holder of Tax Document (NIF) A20037370, registered in the Mercantile Register of Guipúzcoa in volume 1019 of the registration book, Folio 204, Sheet SS-866, Registration 3, states that it is the owner of this Website (www.irurenagroup.com).

The confidentiality policy described below applies only to this Website, defined as comprising all pages and subpages included in the domain www.irurenagroup.com, with INDUSTRIAS QUÍMICAS IRURENA S.A. being released from any liability for the different personal data protection and confidentiality policies which websites accessed through hyperlinks in this Website and not managed directly by our Webmaster may contain.

INDUSTRIAS QUÍMICAS IRURENA S.A. wishes to inform users of this Website that this declaration reflects the data protection policy followed by INDUSTRIAS QUÍMICAS IRURENA S.A. This policy has been drafted in strict compliance with current regulations on the protection of personal details, i.e., amongst others, Act 15/1999, of 13th December, on the Protection of Personal Data (hereinafter LOPD) and Royal Decree 994/1999, of 11th June, which approves the Regulation on security measures for electronic files containing personal data (hereinafter Regulation 994/1999).

02. COLLECTION OF PERSONAL DATA

INDUSTRIAS QUÍMICAS IRURENA S.A. does not collect personal information from users of this Website, which, if the user so desires, may be navigated in a perfectly anonymous manner. INDUSTRIAS QUÍMICAS IRURENA S.A. shall only have access to the personal data of those users who voluntarily provide such data using the contact email address established for this purpose. Whenever the User so wishes, he or she may voluntarily inform INDUSTRIAS QUÍMICAS IRURENA S.A. of the personal data he or she deems appropriate.

All data voluntarily provided by the user will stored on an electronic file under the name “Website Users”, duly registered in the General Data Protection Register, owned by INDUSTRIAS QUÍMICAS IRURENA S.A. and created for the purpose of “Informing users of the services offered by the Company”.  In consequence, all users who provide their personal details to INDUSTRIAS QUÍMICAS IRURENA S.A. expressly accept the processing of these details in order for INDUSTRIAS QUÍMICAS IRURENA S.A. to inform them of the business services it develops.

INDUSTRIAS QUÍMICAS IRURENA S.A. does not use cookies or similar tools which automatically collect information (cookies are small files which are downloaded to the Website user’s hard drive and can be used to recognise the browser of a specific computer; they do not, in themselves, provide personal details of the user of the system).

03. SAFETY MEASURES

All personal data collected by INDUSTRIAS QUÍMICAS IRURENA S.A. are stored in databases owned exclusively by INDUSTRIAS QUÍMICAS IRURENA S.A., which assumes all the technical, organisational and security measures necessary to guarantee the confidentiality, integrity and quality of the information they contain, in accordance with the Data Protection Act and Regulation 994/1999.

The electronic files containing personal details owned by INDUSTRIAS QUÍMICAS IRURENA S.A. may be accessed by third parties or entities as part of the rendering of website maintenance and hosting services, in which case any access will be carried out in accordance with the provisions of Article 12 of the Data Protection Act on access to data by third parties.

Communications between users and INDUSTRIAS QUÍMICAS IRURENA S.A. are not made through a secure channel and the data are not encrypted; in consequence, users should refrain from sending any personal details which are considered specially protected data, in accordance with the provisions of Article 7 of the Data Protection Act, since the absence of security measures makes this inadvisable.

04. PURPOSE OF DATA PROCESSING

All personal data voluntarily provided by the user to INDUSTRIAS QUÍMICAS IRURENA S.A. will be used solely for the purpose of informing the user, at his or her request, of the services provided by the Company. Use of such data will always be in line with lawful purposes related to the business activity of INDUSTRIAS QUÍMICAS IRURENA S.A. All data received will be treated with absolute confidentiality and used only for the purposes for which they were collected, in the terms made known expressly to the User at the moment of collection.

Users who voluntarily provide their details to INDUSTRIAS QUÍMICAS IRURENA S.A. through this Website expressly consent to the use of this personal information in order to send out commercial information on new products and services of INDUSTRIAS QUÍMICAS IRURENA S.A., in strict compliance with current legislation on the sending of commercial communications in Information Society Services.

05. DATA TRANSFER

The personal data collected through this Website will not be transferred to any other person or company, save for those cases in which such transfer is obligatory in accordance with the Data Protection Act.

The data collected will always be treated in accordance with current legislation on the protection of personal data.

06. DATA QUALITY: RIGHTS OF ACCESS, OPPOSITION, RECTIFICATION AND CANCELLATION

INDUSTRIAS QUÍMICAS IRURENA S.A. agrees to keep the personal information voluntarily provided by users of this Website up-to-date at all times, thus ensuring accuracy in the identity and personal characteristics of users. Any User may, at any time, exercise his or her right to access, rectify and, where appropriate, cancel any personal details provided to INDUSTRIAS QUÍMICAS IRURENA S.A., to which end he or she should use one of the following forms of contact:

IRURENA GROUP

Ctra. de Tolosa, s/nº Apartado 30

20730 Azpeitia (Gipuzkoa)

SPAIN

Telephone: +34 943 157 099

Fax: +34 943 810 911

e-mail: info@irurenagroup.com

www.irurenagroup.com