Privacy Policy

At XHYPE FZCO, we are committed to protecting your privacy. Therefore, we treat your personal data and information in accordance with this Privacy Policy and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation or "GDPR"), and with the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights ("LOPD-GDD") and other implementing regulations.

This Privacy Policy applies to all activities carried out by XHYPE. By providing us with your personal data and using our website, we understand that you have read and understood the terms related to personal data protection information that are exposed.

1. Responsible for the processing of personal data

2. Personal data and special categories of personal data

Personal data is any information about an identified or identifiable natural person (the "data subject"), such as name, address, telephone number or email address. Personal data (or data) constitutes any information relating to an identified or identifiable natural person, even indirectly, by reference to any other information, including a personal identification number.

3. Personal data we collect and purposes of processing

3.1 Request for personal data

The personal data that we may request from you includes your contact details (e.g. name, address, telephone number, email address, etc.), identification data (e.g. national identity card, NIE or passport number, etc.), or any other data that is necessary to fulfill the purposes set out in this Privacy Policy.

If we collect special category personal data about you, we will inform you of this, ask for your express consent to the processing where necessary in accordance with the applicable regulations and inform you of its purposes, and we may collect other personal data during your relationship with XHYPE, in which case we will ask for your consent and inform you, among others, of the processing to be carried out, the purpose, the legitimacy of the processing and your rights in relation to your personal data.

3.2 Purposes of treatment

XHYPE collects your personal data for various purposes, depending on the use and origin of such personal data. Customers' personal data are processed for the performance of XHYPE's own functions. The use of customers' personal data is authorized by the prior, express and specific consent of their owners or legal representatives, which is given when contracting or browsing the website.

According to current regulations, the personal data that we may request for the fulfillment of the above tasks are those that are necessary for the formation and contracting of the service. We collect and treat personal data in order to manage service offerings and commercial or service relationship with customers and potential customers.

We may also use your data to provide you with information about our courses, services, products or information from XHYPE. At any time you can request not to be contacted or informed about our courses or services, as well as not to disclose your information to third parties for such purposes, either by contacting us directly or, where appropriate, by clicking the "unsubscribe" button on promotional emails.

3.3 Forms of data collection

We generally collect personal data directly from you. We collect information and personal data that you provide to us electronically, including information provided through the website, web chat, social networks, email, through the provision of our services and through forms or any other written or electronic means that you complete.

If we receive information or personal data about you that we have not requested or that is not relevant to the purposes stated above, we will destroy or anonymize the information, unless we are required to retain it in accordance with applicable law.

3.4 What happens if you do not provide your personal information and data or do not authorize their processing

If you are a student, customer or supplier, you have the right not to provide us with information or personal data, although in that case it may be impossible to enter into any type of contract or to provide services.

In the case of special category data, your explicit consent will always be requested, unless the processing is necessary for the performance of obligations and exercise of specific rights of the controller or the data subject in the field of labor law and social security and protection.

4. Legitimation for the processing of personal data

The legal basis for the processing of your data for the purposes mentioned above will always be one of those provided for by Article 6 of the GDPR, namely:

• Consent of the interested party
• Execution of a contract
• Compliance with a legal obligation applicable to the data controller
• Protection of vital interests of the data subject or another natural person
• Satisfaction of legitimate interests pursued by the data controller or by a third party

If the processing concerns special category personal data, it will always be based on one of the legal bases of Article 9 of the GDPR.

If the user is a minor, it is required to have the prior consent of their parents or guardians before proceeding to the inclusion of their personal data in the web forms. XHYPE disclaims any liability for failure to comply with this requirement.

5. Duration of the processing of personal data

In general, the personal data provided will be retained for the time necessary to fulfill the purposes described in this Privacy Policy or to fulfill any request from the data subjects, unless a longer retention period is legally permitted or required or as long as their deletion is not requested by the data subject.

When XHYPE is considered the data controller, it shall ensure that the data undergoing processing:

• Are appropriate for the purpose for which they were collected
• Are not used for purposes other than and/or incompatible with those for which they were collected and processed
• Are not kept indefinitely without justification
• Are cancelled when they are no longer necessary for the purpose for which they were collected and processed

6. Transfer of personal data to third parties

We may share or disclose your personal information to third parties for any of the above reasons. Such third parties may be educational institutions, universities, as well as their customers, external consultants, suppliers or subcontractors (e.g. postal service, support services, etc.), in fulfillment of contractual relationships entered into with such third parties, both within and outside the EU/EEA.

Where we are required to transfer or disclose your data to third parties, we will maintain our commitment to safeguard your personal data in accordance with this Privacy Policy and will take all reasonable steps and precautions to ensure that the third parties maintain confidentiality and secrecy commitments in relation to the protection of your personal data.

We will not share special categories of personal data relating to you that have not been transferred by you with any person or entity other than XHYPE, or group companies, our employees, XHYPE collaborators, government agencies and others in compliance with legal obligations or requirements, courts, tribunals and public administrations, or any other third party authorized by law.

7. Storage and security of your personal data

We store your personal data in paper or electronic files. We have put safeguards in place as required by applicable regulations to protect the personal data we store from misuse, interference and loss, unauthorized access, modification or disclosure.

XHYPE applies technical security measures such as encryption where reasonably possible. In addition, various systems such as secure archiving of original documents or limiting access to personal data to those persons appropriately authorized to do so provide security for the processing of your personal data.

8. Rights relating to your personal data

XHYPE strives to ensure that the information it holds about you is accurate, up to date, complete and relevant. However, you have the right to access such information and correct it if it is incorrect, inaccurate, out of date or incomplete, and you may withdraw your consent to the processing of your personal data.

If you have any questions about this Privacy Policy or wish to access or otherwise modify or rectify your personal data, you may contact our Data Protection Officer (DPO) by sending your communication to 128, CITY ROAD, LONDON, U.K. or by sending an email to info@xhype.io.

What rights do you have in relation to the processing of your data (ARSOPOL RIGHT)?

• Right to request access to your personal data
• Right to request its rectification or suppression
• Right to request the limitation of their treatment
• Right to object to the processing
• Right to data portability
• Right to withdraw the consent given

When will we respond to your request?

We will respond to your requests as soon as possible and, in any case, within one month of receiving your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests.

Where should you go to exercise your rights?

To exercise your rights, the interested party may send a letter with all your data, including a photocopy of your ID card or passport and indicating the right being exercised to XHYPE address 128, CITY ROAD, LONDON, U.K, or through info@xhype.io.

Please note that if you submit a request for the exercise of these rights and consider that it has not been adequately addressed by our institution, you can file a complaint with the Data Protection Agency.

9. Electronic communications

In compliance with Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce, we inform you that e-mail addresses may be used to send information about XHYPE.

If you do not wish to receive information or want to revoke the consent given for the processing of your data please do so in the manner indicated above or by contacting the following email address info@xhype.io.