FIVENT's PRIVACY POLICY

Fivent

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This is our Privacy Policy (“Policy”) that is applicable to the processing of personal data that we carry out at Berkshire 2410, S.L. (hereinafter "FIVENT") through our website https://www.fivent.com ("Web"), and other portals ("Portals").

FIVENT is a company that has the purpose of helping its clients and users to strengthen their finances through the analysis of the information they provide us through the use of algorithms and financial technology.

In FIVENT we consider it essential to protect your privacy and the security of your personal data, as described in this Policy.

OUR CONTACT INFORMATION

BERKSHIRE 2410, S.L. (“FIVENT”) We are located at 321 Llull Street (CINC Building), 08019, Barcelona CIF: B67384644 Contact email: informacion@fivent.com

You can contact our DATA PROTECTION DELEGATE at the following email address: info@fivent.com

APPLICABLE REGULATIONS AND PRINCIPLES OF PROTECTION OF PERSONAL DATA

The collection of personal data, the processing and its subsequent use by FIVENT is subject to EU Regulation 2016/671 General of Data Protection, dated April 27, 2016 (hereinafter, by its acronym “GDPR”), and the Law Organic 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (hereinafter “LOPDyGDD”).

In FIVENT we treat the personal data of our Users in accordance with the following principles (established in said regulations):

• Treat user data with legality, loyalty and transparency.
• Treat the data in a limited way to the purpose for which they were collected.
• Data minimization: Treat adequate, relevant and limited data as necessary.
• Accuracy: Treat accurate data and, when necessary, updated.
• Limitation of the period of conservation (no more than the time necessary for the purposes).
• Integrity and confidentiality (guaranteeing an adequate level of security).

WHAT LEGAL BASES ALLOW US TO TREAT YOUR PERSONAL DATA?

In FIVENT we only collect and process personal data when:

• We have your explicit consent, or
• It is necessary to provide you with our financial analysis services based on the fulfillment and execution of our contracts, or
• To comply with our legitimate interests for statistical purposes and / or when you ask us or request a service, or
• In case we must comply with our legal obligations.

WHY DO WE USE YOUR PERSONAL DATA?

FIVENT only uses your personal data for the following purposes:

• To provide you with our financial analysis services on the information you provide.
• To keep you informed about our services and news, as long as you request it.
• To attend your requests and / or doubts, manage our communications and provide you with all the information you request.
• To obtain statistics and know the traffic and use of our website and other Platforms, to determine your preferences.
• To comply with applicable laws and regulations.
• To provide you with personalized commercial offers of your own and / or third parties, provided we have your prior consent for such purposes.
• We may also use the information in another way, with your prior explicit consent.

In FIVENT we collect those personal data necessary to guarantee and enable the use and / or contracting of our financial analysis services, as well as to keep you informed of our services and comply with our legal obligations.

In particular, we treat your personal data when you use the services of FIVENT in any of our Platforms.

Therefore, when you interact with us, we may collect or process the following personal information:

• Identification data (Name, surname, etc.)
• Contact information (Telephone, email, etc.)
• Financial data (investment, savings, expenses, income, etc.)
• Lifestyle data related to your financial activity (spending and purchasing categories, etc.)
• Other lifestyle data (optional and for statistical purposes only)
• Activity data on our page for statistical purposes.

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In order to offer you our services, in accordance with the purposes indicated, in FIVENT we will share your personal data with our suppliers, in order to ensure the best service, guaranteeing adequate security for your personal data.

In FIVENT we do not share data with other entities if we do not have your explicit consent, in which case we would do so only for the purposes that you expressly indicate.

SECURITY MEASURES AND DATA CONSERVATION

In FIVENT it applies all appropriate technical and organizational measures to guarantee a level of security appropriate to the risk in all the personal data processing that it performs. The data will be kept for the time strictly necessary to comply with the purposes of the treatment and comply with our legal obligations.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your data will be kept until the moment of your definitive withdrawal as a user of FIVENT, as well as the time necessary for compliance with our legal obligations.

In case you are not a registered user, we keep the data for the time necessary to keep you informed and answer your questions and requests, as well as to comply with our legal obligations.

We also retain aggregated information for statistical purposes, ensuring that Users cannot be identified, respecting their privacy.

WHAT RIGHTS DO YOU HAVE IN PRIVACY AND HOW TO EXERCISE THEM?

As a FIVENT User you can exercise your privacy rights at any time and free of charge according to the applicable regulations, such as:

1. what personal data of the User have been collected and processed by FIVENT, for what purposes and with which third parties such data is shared;
2. obtain a copy of said data (the second and subsequent copies may generate administrative costs);
3. request the rectification of inaccurate personal data that concerns you, or that those that are incomplete are completed;
4. request the deletion of personal data concerning you when they are no longer necessary in relation to the purposes for which they were collected;
5. Request the limitation of the processing of personal data related to the User, as long as its potential inaccuracy and other assumptions provided in the applicable regulations are verified;
6. the right to have your personal data transmitted to another company in a common structured format (right to data portability); or
7. The right to object to said processing of your personal data by FIVENT.
8. You also have the right to file a claim with a competent supervisory authority https://www.aepd.es/.

For the exercise of these rights you can go to our Privacy Office by writing to the following email address: info@fivent.com

Additionally, you can fill in any of the following forms and send it to us by email to info@fivent.com: Right of Access, Right of Rectification, Right of Suppression, Right of Opposition, Right of Portability, Right of Limitation of Treatment.

COMMITMENT OF DATA TRUTH

We remind that each User is responsible for the information provided and is responsible for its adequacy and truthfulness. Therefore, FIVENT will not be responsible for data (or analyzes performed on said data) that are not true, adequate and / or true.

CHANGES IN THE PRIVACY POLICY

FIVENT reserves the right to modify its Privacy Policy at any time. In any case, FIVENT will always reflect and communicate all changes in a transparent and visible way.

Cookies Policy

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FIVENT uses cookies to help improve the Website's User service, measuring its use and performance, in order to optimize it, customize it and offer the best user experience.

Access and navigation on the FIVENT page implies the use of Cookies. The conditions set out in our Cookies Policy are detailed below. Please read them carefully.

What is a cookie?

Cookie is a file that is downloaded to your computer when accessing certain web pages. Cookies allow a web page, among other things, to store and retrieve information about the browsing habits of a user or their equipment and, depending on the information they contain and the way they use their equipment, they can be used to recognize to user.

The user's browser memorizes cookies on the hard disk only during the current session occupying a minimum memory space and not harming the computer. Cookies do not contain any specific personal information, and most of them are deleted from the hard drive at the end of the browser session (the so-called session cookies).

Most browsers accept cookies as standard and, regardless of them, allow or prevent temporary or memorized cookies in security settings.

Without your express consent - through the activation of cookies in your browser - this website will not link in the cookies the data stored with your personal data provided at the time of registration or purchase.

The first purpose of cookies is to provide the User with faster access to the selected services. In addition, Cookies personalize the services offered by the website, providing and offering each user information that is of interest or that may be of interest, in response to the use made of the website's services.

Users registered on the website may benefit from more personalized and profile-oriented services, thanks to the combination of data stored in cookies with personal data used at the time of registration. These Users expressly authorize the use of this information for the indicated purpose, without prejudice to their right to refuse or disable the use of cookies.

Likewise, the website may know all the services requested by the Users, so that they can provide or offer adequate information to the tastes and preferences of each User.

It is possible that the website contains links to other websites, in these cases, FIVENT does not control the cookies used by these external websites. For more information about the cookies of third-party websites, we recommend reviewing your own cookie policies.

Current legislation requires us to request the User's agreement to manage cookies. In the event that the User decides not to authorize its use, FIVENT will not store any cookies and only technical cookies would be used since without them it is not possible to navigate the website.

If you continue browsing the website and do not deny authorization, such activity will imply acceptance of its use.

What types of cookies does this website use?

Technical cookies: These are those that allow the user to navigate through a web page, platform or application and use the different options or services that exist there, such as, for example, control traffic and data communication, identify the session, access restricted access parts, remember the elements that make up an order, make the purchase process of an order, make the request for registration or participation in an event, use security elements during navigation, store content for dissemination of videos or sound or share content through social networks.

Personalization cookies: These are those that allow the user to access the service with some predefined general characteristics based on a series of criteria in the user's terminal such as the language, the type of browser through which the service is accessed , the regional configuration from where you access the service, etc.

Third-party cookies: This website uses Google Analytics cookies to collect information for statistical purposes. Google Analytics is an analytical web service provided by Google, Inc. based in the United States with headquarters at 1600 Amphitheater Parkway, Mountain View, California 94043.

For the provision of these services, they use cookies that collect information, including the user's IP address, which will be transmitted, processed and stored by Google in the terms set on the Google.com website. Including the possible transmission of said information to third parties for reasons of legal requirement or when said third parties process the information on behalf of Google.

ADDITIONAL INFORMATION

ANALITYCAL COOKIES

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TECHNICAL COOKIES

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How to configure or disable cookies?

The User accepts, for the use of this website, the treatment of the information collected in the manner and for the purposes mentioned above.

Likewise, you acknowledge knowing the possibility of rejecting the processing of such data or information by rejecting the use of Cookies by selecting the appropriate settings for this purpose in your browser. Although this option to block cookies in your browser may not allow you to fully use all the features of the website.

You can allow, block or delete the cookies installed on your computer by configuring the browser options installed on your computer:

• Google Chrome
• Mozilla Firefox
• Internet Explorer
• Safari