PRIVACY AND COOKIES POLICY

1. WHO ARE WE?

We are Alebat, S.L. and we process your personal data as the data controller.

2. WHAT DO WE USE YOUR DATA FOR?

We will use your data (obtained online, by telephone or in person), among other purposes, to manage the contracting of services or purchase of products, manage your registration as a user, answer your queries, as well as, if you wish, to send you our personalized communications.

3. WHY DO WE USE THEM?

We are entitled to process your data for different reasons. The main reason is that we need to process your data to perform the contract you accept with us when you sign up for our services or features and register with us. We also use your data for other reasons, for example, to answer your queries or to send you newsletters that you have requested to receive.

4. WITH WHOM DO WE SHARE YOUR INFORMATION?

We will share your data with service providers that help or support us, whether they are companies of the AE Group itself or external collaborators with whom we have signed the corresponding contract for the processing of personal data.

5. YOUR RIGHTS.

You have the right to access, rectification, cancellation, opposition, portability and limitation of your data, as well as the right to withdraw the consent given at any time, as we explain in detail below.

We invite you to read our complete Privacy and Cookies Policy below to understand in detail the use we will make of your personal data and the rights you have in relation to them.

SECOND LAYER OF INFORMATION

In this Privacy and Cookie Policy you will find all the relevant information that applies to the use we make of the personal data of our customers and users, regardless of the channel or medium (online, telephone or in person) that you use to interact with us.

For information on how we use cookies and other similar devices that may be installed in the terminals of our customers and users, we recommend that you consult the Cookies Policy.

We are transparent about what we do with your personal data, so that you understand the implications of the uses we carry out or the rights you have in relation to your data:

Some names we will use in this Privacy and Cookies Policy:

1. WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR DATA?

Data controller: ALEBAT, S.L., a company that currently operates in Spain selling training products under the brand AE (hereinafter AE).

2. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

Depending on the services, functionalities or products that you want to enjoy at any given time we will need to process some data or others, which in general will be, depending on the case, the following:

Remember that, when we ask you to fill in your personal data to give you access to a feature or service, we will mark some fields as mandatory, as these are data that we need in order to provide you with the service or give you access to the feature in question. Please note that if you choose not to provide us with this information, you may not be able to complete your registration as a user or you may not be able to enjoy those services or features.

In other cases, we may passively collect information by using tracking tools, such as browser cookies or other similar technologies on our Web site or in communications we send to you. In certain cases, a third party may have provided us with information about you when contracting a service for you to enjoy. In such cases, we will only process your information in connection with that functionality or service in accordance with this Privacy and Cookie Policy.

Depending on how you interact with our website, we will process your personal data for the following purposes:

| 1. To manage your registration as a user of the AE Courses Website | In case of signing up for a course of the AE you must register as a user on our website, and we need to treat your data to identify you as a user of the same and give you access to its various features, products and services that are available to you as a registered user. You can cancel your registered user account by contacting us through the data indicated in the first paragraph. We inform you that the data we collect about your activity, obtained through the different channels of the Web, and which include the contracted services, will remain linked to your account so that all the information can be accessed at once. | For the development, fulfillment and execution of the contract of services that you have contracted with Us on the Web | This purpose includes the treatment of your data for, mainly:

| To attend the requests or requests that you make to Customer Service. We only process the personal data that are strictly necessary to manage or resolve your request or request. If you use the telephone channel, the call may be recorded in order to attend to your request and guarantee its quality. If available, and you decide to communicate with us through the chat service of a social network or other partner, some of your data, such as your name or username, will be imported from your social network or partner account. You should also be aware that the data you enter in this service will be available to your social network or partner and will be subject to their privacy policies. Therefore, we recommend that you review your privacy settings and read the privacy policy of the social network or partner to obtain detailed information about the use they make of your personal data when using their services. | For marketing purposes: This purpose includes the processing of your data mainly for the following purposes: - Personalize the services we offer you and be able to make recommendations based on your interaction with us on the Web and analysis of your user profile (for example, based on your purchase and browsing history).

| Usability and quality analysis to improve our services | If you access our website, we inform you that we will treat your navigation data for analytical and statistical purposes, that is, to understand how users interact with our website and with the actions that we can carry out on other websites and apps and thus be able to make improvements. Likewise, we sometimes carry out actions and quality surveys to know the degree of satisfaction of our customers and users and detect those areas in which we can improve. |

3. WHAT IS THE LEGITIMACY FOR THE TREATMENT OF YOUR DATA?

The legal basis that allows us to process your personal data also depends on the purpose for which we process them, as explained in the following table:

|---------------|------------------| 1. To manage your registration as a user of the Site | The processing of your data is necessary for the execution of the terms that regulate the use of the Site. In other words, in order for you to register as a user on the Website, we need to process your personal data, otherwise we would not be able to manage your registration. We consider that we have a legitimate interest in linking your purchases and the data we collect about your activity through the different channels of the Website to your account. | Development, fulfillment and execution of the service contract | The processing of your data is necessary for the execution of the service contract that binds us to you. In these cases, the basis on which we process your data is your consent. In addition, we process your location data when you give us your consent, in order to offer you specific services through the Web when you visit some of our pages. We consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud or fraudulent use when you use the Web, for example, when making a purchase or return. We understand that the processing of this data is in the best interests of all parties: you, because it allows us to take steps to protect you against fraudulent attempts by third parties; Us, because it allows us to prevent misuse of the Site; all our customers and society, because it also protects their interest in ensuring that fraudulent activities are discouraged and detected when they occur. | Customer Service | We believe that we have a legitimate interest in responding to requests or inquiries that you submit to us through the various existing means of contact. We understand that the processing of this data is also beneficial to you insofar as it allows us to be able to attend to you properly and resolve the queries raised. When you contact us, in particular, for the management of incidents related to your course or the product/service purchased through the Web, the treatment is necessary for the execution of the purchase contract. When your query is related to the exercise of the rights about which we inform you below, or claims related to our products or services, what legitimizes us to treat your data is the fulfillment of legal obligations on our part. | Marketing | The legitimate basis for processing your data for marketing purposes is the consent you give us, for example: when you agree to receive personalized information through various means, when you give your consent by setting cookies or privacy settings on your device, or when you accept the legal basis to participate in a promotional action or to publish your photos on the Web or on our social media channels. In order to offer you personalized services or to show you personalized information, either on our website or on third party websites, as well as to carry out data enrichment, we consider that we have a legitimate interest to perform a profiling with the information we have about you (such as your browsing, preferences or course history) and the personal data you have provided us with such as age range or language, as we understand that the processing of this data is also beneficial to you because it allows you to improve your user experience and access information according to your preferences. | Usability and quality analysis | We consider that we have a legitimate interest to analyze the usability of the Web and the degree of user satisfaction as we understand that the processing of this data is also beneficial to you because the purpose is to improve the user experience and provide a higher quality service. |

4. HOW LONG WILL WE KEEP YOUR DATA?

The length of time we keep your information will depend on the purposes for which we process it, as explained below:

|---------------|---------------------------| | 1. To manage your registration as a user of the Web | We will treat your data during the time that you maintain the condition of registered user (that is to say, until the end of the contracted service or you want to cancel it). | Development, fulfillment and execution of the contract of sale or services | We will treat your data during the necessary time to manage the contracting of services that you have acquired, including possible complaints or claims associated with the contracting of the service in particular. In some occasions, we will only treat the data until the moment you decide. | Customer Service | We will process your information for as long as necessary to fulfill your request or inquiry. | Marketing | We will process your data until you unsubscribe or cancel your subscription to the newsletter. We will also show you personalized ads until you change your device, browser or cookie settings, which will revoke this permission. If you participate in promotional activities, we will retain your information for six (6) months after the promotional activity ends. | Usability and quality analysis | We will treat your data from time to time for as long as we proceed to perform a specific action or quality survey or until we anonymize your browsing data. |

Regardless of the fact that we process your data for the time strictly necessary to fulfill the corresponding purpose, we will subsequently keep them duly stored and protected for as long as liabilities arising from the processing may arise, in compliance with the regulations in force at any given time. Once the possible actions in each case are prescribed, we will proceed to the deletion of the personal data.

5. WILL WE SHARE YOUR DATA WITH THIRD PARTIES?

In order to fulfill the purposes indicated in this Privacy and Cookies Policy, it is necessary that we give access to your personal data to entities of the AE Group and to third parties that support us in the services we offer you, namely:

Due to service efficiency, some of the above-mentioned service providers are located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate guarantees and always maintaining the security of your data, as we use the most appropriate tools for the international transfer of data, such as the Standard Contractual Clauses or any other relevant complementary measures. You can consult the contents of the Standard Contractual Clauses at the following link: Standard Contractual Clauses.

In the event that we transfer all or part of our business or assets to another company within or outside the AE Group, or engage in any other business activity as a result of a corporate reorganization, we may disclose your personal data to the potential recipient of the business or assets. In the event of such a sale or transfer, we would use reasonable efforts to ensure that the recipient treats the personal information you have provided to us in accordance with our Privacy Policy. In this case, we believe that we have a legitimate interest based on the reorganization of our corporate structure.

On the other hand, if you choose to use the Site in different markets (i.e., creating registered user accounts in different markets with the same email address), we may need to disclose or transfer the information linked to your account or your activity to brand companies operating in those markets, to the extent they are directly involved in achieving any of the objectives described in section 2. We consider this necessary to satisfy our mutual interests and preferences.

6. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR INFORMATION?

We are committed to respecting the confidentiality of your personal data and to guaranteeing you the exercise of your rights. The Correspondents have agreed that you can exercise these rights free of charge by sending us an e-mail to a unique e-mail address dpd@alebateducation.com, simply indicating the reason for your request and the right you wish to exercise. If we consider it necessary to identify you, we may ask you for a copy of a document proving your identity.

We may also offer you the possibility of exercising your rights and configuring your privacy preferences when using some of our services or by making specific channels available to you within our website.

In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

In the event that you do not want information to be sent to third parties to show you ads, you have several ways, such as changing the preferences on your device, browser or cookie settings, reviewing the privacy policy and settings of social networks in which you have a profile or send us an email with your request to the address above.

When our legitimacy for the processing of your data is your consent or the execution of the contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, so that it can be transmitted to another entity directly, where technically possible.

Moreover, when the processing of your data is based on our legitimate interest, you also have the right to object to the processing of your data.

Finally, we inform you of your right to lodge a complaint with the relevant data protection supervisory authority, in particular with the Spanish Data Protection Agency (https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).

7. WHAT HAPPENS IF YOU PROVIDE US WITH THIRD PARTY DATA OR IF A THIRD PARTY HAS PROVIDED US WITH YOUR DATA?

We offer functionalities or services that require us to process the personal data of a third party that you as a user or customer provide to us. If you provide us with Personal Data of third parties or if it is necessary for them to provide it to us in connection with a third party’s collection of an order on your behalf, you warrant that you have informed them about the purposes for which and the manner in which we need to process their Personal Data.

If a third party has provided us with your data or you have provided them yourself as a result of a functionality or service requested by one of our users, we will use them to manage the functionality or service that is being developed in each case, within the purposes set out in this Privacy Policy and Cookies, whose link we usually include in our communications.

8. CHANGES TO THE PRIVACY AND COOKIES POLICY

We may modify the information contained in this Privacy and Cookies Policy when we deem it appropriate. In case we do so, we will notify you in different ways through the Web (for example, through a banner, a pop-up or a push notification), or even communicate it to your email address when the change in question is significant to your privacy, so that you can review the changes, assess them and, if necessary, oppose or unsubscribe to any service or functionality. In any case, we suggest that you review this Privacy and Cookies Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our website and our App.

9. INFORMATION ABOUT COOKIES

We use cookies and similar devices to facilitate your navigation on the Web, to know how you interact with Us and, in certain cases, to be able to show you advertising based on your browsing habits. Please read our Cookies Policy to learn more about the cookies and similar devices we use, their purpose and how to manage your preferences, as well as other information of interest.