NEW HORIZONS 81 S.L. informs the Users of its SKIANA® App through this Privacy Policy about the treatment and protection of the personal data of the Users that may be collected through their use, navigation or contracting of services that NEW HORIZONS 81 S.L. performs in the App. Use of this APP by the User implies acceptance by User of this Privacy Policy.

NEW HORIZONS 81 S.L. adopts the necessary measures to guarantee the security, integrity and confidentiality of the data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of the same, and in matters not provided for by the Organic Law 3/2018 of December 5, Protection of Personal Data and guarantee of digital rights, the Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of the Organic Law on Data Protection, and Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce.

Through the forms and sections of the App or the sending of email, personal data of each User is collected and processed that is necessary for the management and maintenance of some of the services provided and whose treatment is governed by this Privacy Policy.

1. Responsible for the Processing of Personal Data

The person responsible for the treatment of personal data that the User provides when accessing and using the App, is, as the owner, NEW HORIZONS 81 S.L., with CIF B98814106, with registered office at calle Luis Santangel 22-9, 46005-Valencia (Spain), registered in the Commercial Registry of Valencia, VOLUME 10.113, PAGE 49, PAGE V-1704445, telephone +34636496315 e-mail info@thenewhorizons.es.

NEW HORIZONS 81 S.L. undertakes to apply the computer security measures provided for in the aforementioned regulations, in order to prevent access or improper use of the data, its manipulation, deterioration or loss.

2. Data Storage Duration

NEW HORIZONS 81 S.L., as the controller, undertakes to store and manage the personal data and information collected through the App with due confidentiality as long as the relationship arising from the use of the App and its services is maintained and the interested person does not request its deletion, and in its case, for a period not exceeding 5 years, counting from the end of the relationship established between the User and NEW HORIZONS 81 S.L.- However, the data controller may keep, duly blocked, the data to attend to possible administrative or jurisdictional responsibilities.

3. Purposes of Data Processing

The operations, procedures and technical procedures, whether carried out in an automated or non-automated manner, that enable the collection, storage, modification, transfer and other actions on personal data, are considered to be personal data processing.

At NEW HORIZONS 81 S.L. we treat the personal data that the User provides us through SKIANA® in order to offer him the best experience of use and navigation, manage his account in SKIANA®, contact the User in the event of any incident in the service, answer the user’s queries, send the User commercial communications.

In addition, the treatment of this collected data also implies managing the sending of the information that is requested and being able to respond to queries or questions that the User sends through the communication channels, in turn facilitating to the Users the offers of services and products that are of interest to him/her.

The fields of the records must be completed compulsorily so that NEW HORIZONS 81 S.L. can fulfill the purposes abovementioned.

The App can use the data provided by Users through the App services to draw general conclusions based on this data and statistical reports to improve the services. When preparing these reports, the data will be in aggregated form, so they will always be used anonymously and without any element that identifies the user who provides said data. Therefore, identification data such as the email account, name and surname of any User will not be included in these statistical reports.

The User can oppose the sending of commercial communications at any time by sending an email message to the indicated address info@thenewhorizons.es.

4. Legitimation for the Treatment of the Data

The processing of personal data provided by the User is carried out based on the following legal bases that legitimize it:

• The use of the SKIANA® App and associated services, whose terms and conditions have been previously made available to the User. In order to carry out this relationship, the User is obliged to provide their data.

• Free, specific, informed and unequivocal consent, since after reading this Privacy Policy the User is informed and, if they agree, can accept it by means of a declaration or a clear affirmative action, such as marking a box provided for this purpose.

In the event that the User does not provide the aforementioned data or they are erroneous or inaccurate, NEW HORIZONS 81 S.L. will not be able to attend to the request, making it impossible to provide the requested information or carry out the contracting of the services. Therefore, the data controller, NEW HORIZONS 81 S.L., will be exonerated from any responsibility that may arise from the consequences that derive from this inaccurate or erroneous information.

5. Data communication

In general, NEW HORIZONS 81 S.L. will not communicate these personal data to third parties, with the exception that the provision of a service implies the need for a contractual relationship with a data processor and this is strictly necessary to manage and maintain the relationship between the User and the aforementioned company, prior express authorization by the User. This will be done only during the time necessary to enable the execution of the commission contract, and under the same conditions and with the same responsibilities that are required of the person responsible.

Once the order is finished, the person in charge of the treatment will return to the Controller the personal data and will delete any copy that it has.

The provision of SKIANA® services requires the subcontracting of accommodation services and other technological issues. Specifically, technological services for storage, server hosting and processing are contracted with the following companies:

• Microsoft Azure (North Europe, Ireland; West Europe, Netherlands)

The data processing carried out by the data processors is regulated by a contract by which they are obliged to treat the data in a secure manner and respecting data protection.

Notwithstanding the foregoing, the User knows and accepts that NEW HORIZONS 81 S.L. may substitute the data processors for other service providers, for which it is guaranteed that the new provider will also respect privacy and the relationship will be contractually regulated.

Both companies are subscribed to the Privacy Shield agreement, so they have a commitment to data protection and NEW HORIZONS 81 S.L. has their commitment so that the data is not stored outside the European Union.

NEW HORIZONS 81 S.L. does not foresee that the rest of the subcontracting carried out implies access to the User’s files. However, in the event that such access is necessary to fulfill the object and purpose of the aforementioned Contract, the User may authorize such subcontracting, in accordance with the provisions of article 28.2 Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016, by prior written or specific authorization. In any case, the document that regulates such relationship will contain the provision of sufficient guarantees of application of appropriate technical and organizational measures, so that the treatment is in accordance with data protection regulations.

On the other hand, only will have right to access to the personal data third parties with whom NEW HORIZONS 81 S.L. has a legal or contractual obligation to provide them, including, for example, the Ombudsman and Judges and Courts interested in the procedures related to the claims presented.

6. Rights of the Interested Parties

The User may exercise at all times, under the terms established in current legislation, the rights of access, rectification or deletion of data, request that treatment be limited, oppose it, request the portability of their data, as well as revoke the consent given, rights recognized in Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016. The exercise of these rights can be done by the User himself by contacting NEW HORIZONS 81 S.L. at the address of its registered office indicated above; by sending an email to the following address info@thenewhorizons.es or to the postal address C/Luis Santangel 22-9 CP 46005, Valencia (Spain).

For the effective exercise of these rights, the User must prove their identity by providing their name and surname, photocopy of their ID or equivalent identification document that proves their identity, request in which the request is made, address for the purposes of notifications, and date and signature of the applicant.

Likewise, the User may claim before the Spanish Agency for Data Protection (Control Authority competent in this matter), especially when they have not obtained satisfaction in the exercise of their rights, by writing addressed to it, C / Jorge Juan, nº 6 , 28001 – Madrid, or through the web: https://www.agpd.es