Política de privadesa

Introduction

This Privacy Policy ('policy') applies to Nemeda Iparralde SL and its affiliates (hereinafter referred to as 'Nemeda or TWYD', 'we', 'us', 'our') and provides information on the collection, use and sharing of your personal information. This includes personal information collected via our websites and portals ('Website'), our products, services or personal information collected from you directly, such as in person, via telephone or email, or indirectly through third parties in the course of our business.

A current listing of our subsidiaries is available in our Annual Report. This policy applies to our subsidiaries to the extent they have access to your personal information.

This policy does not apply to the extent we process your personal information in the role of a processor or service provider on behalf of our customers.

Nemeda or TWYD supports the right to privacy and understands the importance of protecting personal information and complying with applicable data protection laws. We have appointed a Data Protection Officer for assisting with questions regarding this policy and the processing of your personal information. For details on how to contact us, see the Contact Information section below.

What Data We Collect

The personal information we process about you and how we collect it can vary depending on (a) the product(s) or service(s) you use; (b) how you use the product(s) or service(s); (c) how you have interacted with Nemeda or TWYD and (d) the personal information that we have obtained from a customer or from a third party with permission to share such information with us. Refer to the table below for more details on the categories of information collected and purposes of use.

Automated Decisions. To the extent permitted by applicable law, Nemeda or TWYD may collect data in an automated manner and make and use automated decisions about customers in order to provide or optimize the products and services, for security or analytics purposes, to display advertisements and offers based on individual preferences and for any other lawful purpose.

Why We Use Your Data

Nemeda or TWYD processes personal information to respond to your requests, to provide you Nemeda or TWYD products and services, including information, support and delivery and access to online resources. Some of the specific purposes of use of your personal information include:

• With customer or user consent,
• Where the processing is necessary for the performance of a contract,
• Where necessary to comply with law and
• Where the processing is necessary for the purposes of our legitimate interests, taking into account individual interests. Refer to Table 1 for list of legitimate interests.

Nemeda or TWYD may combine the personal information you provide with information that is not collected directly from you. Data not provided directly by you may be supplied by Nemeda or TWYD's vendors and/or partners. Refer to Personal Information Collected from Third Parties for additional information. Also, see Cookie Technology section for details on what and how we collect using cookies and similar tracking technologies.

In certain circumstances, if you do not provide us with personal information we need, we may not be able to provide certain products or services or comply with our legal obligations. We will let you know when we need personal information from you and the consequences of failing to provide us with that personal information.

The legal basis for collecting and using the personal information described above will depend on the personal information concerned, applicable privacy laws and specific context in which we collect it, such as:

How We Collect Your Data

We collect personal information through various means, for example, via our Website(s), order forms and through provision of products or services, from third-party service providers, customer support activities and at meetings, exhibitions and events (both physical or digital). Your employer, as a customer or partner of Nemeda or TWYD, may provide your contact information as required to provide Nemeda or TWYD products or services. We also collect personal information where you or your employer is a customer of a business we may acquire. We may also collect information about you on CCTV when you visit our premises or on other security cameras as part of our security and crime prevention measures. The Website(s) may also collect information about your visits to the Website without you actively submitting such information through cookie technology.

How We Share Your Data

Nemeda or TWYD may share personal information with its affiliates, business partners (including those who resell or distribute our products and services), service providers (including website, software, infrastructure and application providers), payment gateways, customer service, event/campaign management, cloud hosting providers, credit reference agencies, debt agencies, professional advisors, marketing agencies (including event or promotion partners or sponsors), third-party networks and websites, database providers, backup and disaster recovery specialists, analytics and email providers) and agents working on our behalf.

We may be required to share personal information with a third party or body where such disclosure is required to satisfy applicable law or other legal or regulatory requirement, or to protect the rights or property of Nemeda or TWYD or others. This can include in response to lawful requests from a competent authority or body and to meet national security or law enforcement requirements.

If all or any part of our business is re-organized or sold to or there is a joint venture with another organization, we may need to provide your information to that organization. We may also be the recipient of personal information when we acquire another organization or a part of their business or enter into a joint venture with them.

Where third parties are performing processing on our behalf, Nemeda or TWYD will require these organizations to adopt adequate technical and organizational security measures to protect personal information and to ensure the processing of personal information is only performed as instructed by Nemeda or TWYD and for no other purposes.

Personal information may be processed outside the country of your residence by our affiliates, partners or service providers and agents working on our behalf. The transfer to other countries by Nemeda or TWYD and its affiliates shall be in accordance with applicable data protection legislation, which may include an adequacy decision or appropriate safeguards. Appropriate safeguards may include: Nemeda or TWYD and third parties entering into the EU Model Clauses approved by the European Commission.

How We Protect Your Data

Protecting your data, both online and offline, is a priority for us. We have implemented appropriate technical and organizational measures to protect your personal information and ensure a level of security appropriate to the risk.

All our employees are subject to confidentiality agreements and undergo annual training on the proper handling of personal information.

Nemeda or TWYD is committed to protect all personal information and is cognizant of its obligations under applicable data protection laws. For further details, including information on industry standard certifications of our products, please refer here.

Links to other websites or locations may be provided for your convenience but do not signify our endorsement of such other websites or locations or their contents. When you click on such links, you will leave the Nemeda or TWYD website and go to another site. When this happens, a third party may collect personal information from you. Please be aware that the terms of this policy do not apply to such outside websites or content or to any collection of data after you click on a link to a third-party website or location. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy notice of any website you visit.

How Long We Store Your Data

Nemeda or TWYD will retain personal information for as long as needed to provide the relevant products or services or to fulfil the purposes for which the personal information was collected or as per the specific contractual terms. Nemeda or TWYD may also retain and use this information for a longer period as permitted or required by law, to comply with our legal, tax or regulatory obligations (e.g., audit and accounting requirements), handle disputes, to exercise or defend claims and enforce our agreements. We ensure that personal information we dispose of is de-identified or destroyed in a secure manner.

Your Privacy Rights

Your local applicable law may provide certain rights regarding the collection, use and sharing of your personal information. You may request from Nemeda or TWYD access to, correction of, updating of and/or deletion of your personal information, or object to our use of your personal information in certain circumstances, in line with applicable data protection law. Your rights may differ according to your place of residence.

Choice/Opting out of Marketing: Nemeda or TWYD offers you the choice of receiving different types of communications and information related to our products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism in all our marketing communications or you may contact us.

Note that if you opt out of marketing, you may still receive service-related messages from us (and you may still receive marketing messages for a short period after opting out while we update our records).

Under GDPR and UK data protection law (and other applicable data protection regulations), you have rights we need to make you aware of. The rights available to you depend on your jurisdiction and our reason for processing your information:

• Your right of access - You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
• Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
• Your right to object to processing - You have the right to object to processing if we are able to process your information because the process forms part of our public tasks or is in our legitimate interests.
• Your right to data portability - This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of this notice.

Exercise Your Privacy Rights: To exercise your privacy rights, please fill out the Data Subject Request form.

Please direct any complaints or questions you may have with regard to our privacy practices to Nemeda or TWYD's Data Protection Officer.

You may also have the right to complain to the competent supervisory authority. Contact details of Data Protection Authorities in the European Economic Area can be found here, and in the UK here.

Customer Data: If your personal data has been submitted to us by or on behalf of a customer to our products and services who is the controller of that personal information and we are the processor on their behalf, you will need to contact them directly if you wish to exercise any rights you may have under applicable data protection laws. If you make your request to us, we will need the name of that customer who submitted your data to us, and we will refer it on to them.

Children's Privacy

Nemeda or TWYD encourages parents and guardians to take an active role in their children's online activities. Our Services are not aimed at people under 18 and Nemeda or TWYD does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the age of 13 (or the applicable age of consent) without proper consent, please submit your complaint in writing to the address found in the Contact Information section.

Contact Information

Nemeda or TWYD's Data Protection Officer can be reached at serice@Nemeda.io or by mail at:

UK and EU representatives for Nemeda or TWYD and its affiliates can be reached at serivce@nemeda.io

Changes to this Privacy Policy

Nemeda or TWYD may update this policy from time to time. If we modify this policy, we will post the revised version here. You should review this page periodically for updates.

If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use personal information, we will notify you by way of a prominent notice or pop-up on our Website.

This policy was last updated September 2025.