PRIVACY POLICY
1. Who are we?

Cartonajes F.X. Sanmartí was founded in Barcelona in 1925. Its current facilities cover 7,000 square metres in Terrassa (Barcelona), devoted exclusively to cardboard manufacturing, beside the Terrassa-Ronda exit of the C-58 motorway. Our experience and constant drive for innovation allow us to help our customers with fast deliveries and unbeatable quality. We are backed by 90 years in corrugated cardboard recycling and manufacturing. Our technical team can advise you on any questions that arise when packaging new products.

Cartonajes F.X. Sanmartí undertakes to collect, maintain and use personal information about our customers and business contacts in a responsible manner. The provisions of data protection laws in the European Union and elsewhere impose strict conditions on Cartonajes F.X. Sanmartí

This privacy policy explains how we may collect, use and disclose information about customers, suppliers, shareholders and other business and business contacts, and describes the rights you may have with respect to your own personal information. Please read it carefully.

2. Who is responsible for the processing of your data?

Name or business name: FX SANMARTI S.A.

Social address: Calle Geminis 8-14 08228 Terrassa Website: https://www.fxsanmanti.com

3. Who does this Privacy Policy apply to?

Customers

This policy applies to the individual contacts of the customers we deal with, including potential clients. It applies to the personal information that is collected as part of our customer incorporation and disconnection process, as well as to the information collected during the course of a customer relationship.

It also applies to the personal information of employees of client entities whose details we may receive as part of the provision of products and services. In these circumstances, our primary contact with the customer is responsible for ensuring that all affected persons know that their personal data will be provided to us and the purposes for which we will use that information, for example by showing them a copy of this policy.

Shareholders

The above description applies equally to our shareholders.

Suppliers

The above description applies equally to our Suppliers.

Business Contacts

In addition, this policy covers the personal information of individuals who are not existing or former customers or shareholders, but who interact with Cartonajes F.X. Sanmartí registering to receive communications such as email alerts and publications, or attending events managed by Cartonajes F.X. Sanmartí (either alone or in conjunction with partner organizations).

Other Contacts

This policy also covers the personal information of people with whom Cartonajes F.X. Sanmartí has a commercial agreement or contact in the course of its business, such as agents, other stakeholders and adverse parties.

4. What information is included?

In this privacy policy, "personal information" means any information (either electronic or written) related to an individual that can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

It also includes special categories of personal information (“special category data”) from which we can determine or infer an individual's racial or ethnic origin, political opinions, religious or other beliefs of a similar nature, trade union membership, physical or mental health or condition (including biometric and genetic data), sex life/sexual orientation or judicial data (including information about the commission or alleged commission of a criminal offence and any penalty or sanction imposed).

Cartonajes F.X. Sanmartí will only collect data from special categories if necessary for any of the purposes described below. You can find more information about when and why we should do this in section 4 "The information we collect and how we use it" below.

5. The information we collect and how we use it

Cartonajes F.X. Sanmartí may use your personal information for a variety of purposes, as described in the following sections.

Cartonajes F.X. Sanmartí undertakes to collect and use only the personal information necessary to provide products and services to our customers; establish and/or maintain its business relationship with business contacts; and keep individuals informed about products, services and events that it reasonably believes may interest them and/or that they have in some way confirmed they prefer to receive from Cartonajes F.X. Sanmartí. You can find further details about the purposes, the information we may collect, the source of the information and the legal authority relied upon by Cartonajes F.X. Sanmartí by sending a request to: info@fxsanmarti.com.

In some cases, you will be required to provide personal information to Cartonajes F.X. Sanmartí so that we can provide products and services to you (or your employer), interact with you or comply with Cartonajes F.X. Sanmartí's legal obligations

Supplier of Products and Services

Cartonajes F.X. Sanmartí may collect or generate additional details about you during the course of our contract in order to provide products and services.

We may also use your personal information: • To manage our relationship and maintain contractual relationships • For accounting and tax purposes • For marketing and business development • To comply with Cartonajes F.X. Sanmartí's regulatory obligations • To establish, exercise or defend legal rights • For crime prevention and detection • For historical and statistical purposes Other Business Interactions

As part of your business or other business transactions with Cartonajes F.X. Sanmartí, we may collect or generate details about you. We may use this personal information to manage our relationship and maintain contractual relationships, for accounting and tax purposes and to comply with our regulatory obligations.

Information Collected in our Facilities

If you visit our facilities, your image can be captured through CCTV systems operated by Cartonajes F.X. Sanmartí or the entity that manages our facilities. Access control systems for our facilities can also capture the location, time and date of your entry and departure from our offices.

Communications

Where permitted by applicable law, Cartonajes F.X. Sanmartí may record and/or monitor incoming and outgoing telephone calls and electronic communications sent or received over Cartonajes F.X. Sanmartí networks to protect our business and verify compliance with our policies and relevant legal requirements. Any such recording and/or monitoring will be carried out for lawful business purposes and in accordance with applicable laws and regulations. This may include the following purposes: • Recording data (including converting voice messages into text) • Establishing compliance with Cartonajes F.X. Sanmartí policies and procedures • Complying with applicable laws and regulations • Preventing and detecting crime • Monitoring the effective use and management of Cartonajes F.X. Sanmartí networks and systems

To communicate efficiently, correspondence and documents can be sent by unencrypted email. You should know that this is not guaranteed as a safe method of communication, nor are there service standards for delivery. If you prefer not to use the unencrypted email, please talk to your contact at Cartonajes F.X. Sanmartí.

Marketing and Commercial Development

Cartonajes F.X. Sanmartí collects information for marketing and business development purposes and as part of the general management of customer relationships. We may use certain personal information for customer entertainment purposes, including recording your interests and preferences.

We may use your personal data to send you information by email or post, or through social media or social networking sites, about our products and services, industry news, brochures, press releases, seminar invitations and presentations. You can select the areas and topics that interest you when you register on our website. You can update your preferences or unsubscribe at any time. For more information on exercising your rights, see section 11: “Your Rights”.

Cookies

If you use our websites, we inform you that they use cookies and other web traffic analysis tools. Click on our Cookies Policy to learn more about our use of these tools or request it through: info@fxsanmarti.com

6. International data transfers.

The personal information we collect resides in Spain.

7. Disclosures

Cartonajes F.X. Sanmartí may disclose your personal information (i) where necessary for the stated purposes, including within Cartonajes F.X. Sanmartí if required by applicable law; (iii) in connection with a reorganisation or merger of our firm with another company; (iv) if we believe disclosure is necessary to enforce or apply the terms of the contract and other agreements or to protect and defend the rights, property or safety of Cartonajes F.X. Sanmartí; (v) to comply with legal proceedings, a court order or another legal obligation, or a regulatory or governmental inquiry; or (vi) with your consent.

We would particularly like to point out that, in some jurisdictions, Cartonajes F.X. Sanmartí has a legal obligation to report suspicious transactions and other activities to the relevant regulatory authorities under legislation relating to money laundering, terrorist financing, insider trading or related matters. Cartonajes F.X. Sanmartí may also report suspected criminal activity to the police and other law enforcement agencies. We may not be permitted to inform you of this before disclosure, or at all

Third-party recipients of personal information relating to the company's customers, businesses and contacts may include: • Tax, Customs and Excise Authorities • Regulatory bodies and other professional bodies • Stock exchange and listing authorities • Public registers of company directors and shareholders • Identity verification service providers • Credit reference agencies • The courts, police and law enforcement agencies • Government departments and agencies • Auditors and professional advisers (including insurers and professional indemnity advisers)

Cartonajes F.X. Sanmartí will make every reasonable effort to disclose the minimum personal information required in each case.

8. Service providers

Third parties providing services to Cartonajes F.X. Sanmartí are called “Subcontractors”. Cartonajes F.X. Sanmartí will enter into contracts with subcontractors addressing the requirements of the relevant privacy laws. Subcontractors must use appropriate security measures to protect personal information and will be prohibited from using personal information in any way other than as instructed by Cartonajes F.X. Sanmartí

For more information about the subcontractors we work with, please contact the Data Protection Officer by sending a request to the following email: info#fxsanmarti.com

9. Keeping your information up to date

Cartonajes F.X. Sanmartí makes every effort to maintain the accuracy and completeness of the personal information held by Cartonajes F.X. Sanmartí. To help us ensure we have the most up-to-date information about you, please inform us of any changes to your contact details or other personal information. Contact the person you normally deal with at Cartonajes F.X. Sanmartí. You can also contact the Data Protection Officer by sending a request to the following email address: info@fxsanmarti.com

10. Retention

Cartonajes F.X. Sanmartí will retain personal information only for as long as is necessary for the purposes described in section 4 above: “The information we collect and how we use it”. Please note that retention periods may vary in different jurisdictions. Personal data are usually stored for a minimum period of 2 years and may be kept for an additional period defined by the applicable statute of limitation.

We may need to retain information for significant periods of time to establish, exercise or defend our legal and historical and archival rights. Whenever possible and practical, personal information will be anonymous by removing, replacing or blocking details that identify individuals.

For more information on the retention policy, please contact the Data Protection Officer by sending a request to the following email address: info@fxsanmarti.com

11. Your rights

You have the following rights regarding your personal information: •To access the personal information Cartonajes F.X. Sanmartí holds about you; •To correct your personal information, for example, if it is incomplete or incorrect; •To opt out of marketing communications at any time; •In certain circumstances and subject to applicable law, the right to restrict or object to the processing of your personal information, or to request that your personal information be erased; •In certain circumstances and subject to applicable law, the right to receive a copy of the personal information you have provided to Cartonajes F.X. Sanmartí in a structured, commonly used and machine-readable format (known as "Data Portability"); •Where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent; •The right to lodge a complaint with a data protection authority (see below)

If you wish to exercise your rights, please contact the Data Protection Officer by sending a request to the following email: info@fxsanmarti.com

What happens if you are under 18?

If you are under the age of 18, be sure to have the permission of your parents or legal representative before providing us with your personal information. Persons under 18 years of age cannot provide us with their personal data without such authorization.

Right to lodge a complaint

If our response does not satisfy you or if you consider that we do not process your personal data in accordance with the law, you may file a complaint with the relevant data protection supervisory authority of your country.

Amendments to this statement

This Privacy Policy has been updated in January 2020. We may make occasional changes or modify them as necessary to comply with any applicable data protection law. You may want to review it again when you consider it necessary. Any change to any provision of the Privacy Policy shall apply from the date of publication on our websites.

Enquiries

If you have any questions about this Privacy Policy, please contact the Data Protection Officer by sending a request to the following email address: info@fxsanmarti.com