Privacy Policy

This Privacy Policy describes how VORTIA AND VORTIA EU (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from vortia.eu (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. Please read this Privacy Policy carefully.

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Changes to This Privacy Policy

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We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

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How We Collect and Use Your Personal Information

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To provide the Services, we collect personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us. In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

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What Personal Information We Collect

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The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

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Information We Collect Directly from You

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Information that you directly submit to us through our Services may include:

Contact details including your name, address, phone number, and email.

Order information including your name, billing address, shipping address, paymentconfirmation, email address, and phone number.

Account information including your username, password, security questions andother information used for account security purposes.

Shopping information including the items you view, put in your cart, saved into youraccount like loyalty points, reviews, referrals or gift cards, or purchases.

Loyalty points/product reviews/referrals/gift cards saved

Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

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Information We Collect about Your Usage

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We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

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Information We Obtain from Third Parties

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Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

Companies who support our Site and Services.

Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.

When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

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How We Use Your Personal Information

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Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account. We may also enhance your shopping experience by enabling VORTIA to match your account with other VORTIA services that you may choose to use. In this case, VORTIA will process your information as set forth in its Privacy Policy and Consumer Privacy Policy.

Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in selling our products, according to Art. 6 (1) (f) GDPR.

Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.

Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.

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Cookies

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Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with VORTIA Technologies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

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How We Disclose Personal Information

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In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).

With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.

When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.

With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.

In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We disclose the following categories of personal information and sensitive personal information about users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":

Category                    Categories of Recipients

•  Identifiers such as basic contact details and certain order and account information

•  Commercial information such as order information, shopping information and customer support

information

•  Internet or other similar network activity, such as Usage Data

•  Geolocation data such as locations determined by an IP address or other technical

measures

•  Vendors and third parties who perform services on our behalf (such as Internet service

providers, payment processors, fulfillment partners, customer support partners and data analytics

providers)

•  Business and marketing partners

•  Affiliates

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We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.

With your consent we share personal information for the purpose of engaging in advertising and marketing activities, as follows.

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Third Party Websites and Links

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Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

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Children´s Data

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The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

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Security and Retention of Your Information

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Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

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Your Rights

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Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.

Right to Delete: You may have a right to request that we delete personal information we maintain about you.

Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.

Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

Right to Opt out of Sale or Sharing or Targeted Advertising: You may have a right to direct us not to "sell" or "share" your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the "sale" or "sharing" of information for the device and browser that you use to visit the Site.

Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.

Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.

Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.

Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

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Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here: https://edpb.europa.eu/about-edpb/about-edpb/members

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International Users

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Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

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Contact

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Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please call or email us at:

BLUE OCEAN MARKETING AND CONSULTING LLC

Delaware, 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex

Email: info@blueoceanmarketings.com

For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.

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Website Privacy Policy

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https://vortia.eu/

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, VORTIA (hereinafter also the Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws that incorporate this privacy policy

This privacy policy is adapted to current European regulations on the protection of personal data on the internet. Specifically, it complies with the following regulations:

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).

Royal Decree 1720/2007, of December 21, approving the Regulation implementing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).

Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

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Identity of the Controller of Personal Data

The controller of the personal data collected by VORTIA is: BLUE OCEAN MARKETING AND CONSULTING LLC, with Tax Identification Number: 32-0780146 (hereinafter, the Data Controller). Its contact details are as follows:

The controller of the personal data collected by VORTIA is: , with Tax Identification Number: and registered at: with the following registration details: , whose representative is: (hereinafter, the Data Controller). Its contact details are as follows:

Address: Delaware, 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA

Contact email: info@blueoceanmarketings.com

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Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by VORTIA through the forms on its pages will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between VORTIA and the User or to maintain the relationship established in the forms completed by the User, or to respond to a request or query from the User. Furthermore, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is kept, which specifies, according to their purposes, the processing activities carried out, and the other circumstances established in the GDPR.

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Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set forth in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

Principle of legality, loyalty, and transparency: the User's consent will always be required after fully transparent information about the purposes for which the personal data is collected.

Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes.

Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.

Principle of accuracy: personal data must be accurate and always up-to-date.

Principle of retention limitation: personal data will only be kept in a manner that allows the User to be identified for the time necessary for the purposes of its processing.

Principle of integrity and confidentiality: Personal data will be processed in a manner that guarantees its security and confidentiality.

Principle of proactive accountability: The data controller will be responsible for ensuring that the above principles are met.

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Categories of Personal Data

The categories of data processed by VORTIA are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed by VORTIA are both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are defined as those that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data intended to uniquely identify a natural person, data relating to health, or data relating to a natural person's sex life or sexual orientation.

For the processing of special categories of personal data, the User's explicit consent will always be required for one or more specific purposes.

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Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data is consent. VORTIA undertakes to obtain the User's express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. Withdrawing consent is as easy as giving it. As a general rule, withdrawing consent will not affect use of the Website.

When the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if completing any of these forms is mandatory because they are essential for the proper performance of the transaction.

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Purposes of Personal Data Processing

Personal data is collected and managed by VORTIA to facilitate, streamline, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms completed by the User, or to respond to a request or query.

The data may also be used for commercial purposes, including personalization, operational, and statistical purposes, and for activities related to the corporate purpose of VORTIA, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

At the time the personal data is collected, the User will be informed of the specific purpose(s) for which the personal data will be processed; that is, the use(s) to which the information collected will be used.

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Personal data retention periods

Personal data will only be retained for the minimum period necessary for the purposes of its processing and, in any case, only for the following period: 36 days, or until the User requests its deletion.

At the time personal data is obtained, the User will be informed of the period for which the personal data will be retained or, if this is not possible, the criteria used to determine this period.

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Recipients of Personal Data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is collected, the User will be informed of the recipients or categories of recipients of the personal data.

The User's personal data will be shared with the following recipients or categories of recipients:

Company: BLUE OCEAN MARKETING AND CONSULTING LLC (Reg. Code 32-0780146), Delaware, 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA

If the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is collected, the User will be informed of the third country or international organization to which the data is intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

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Personal data of minors

In compliance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by VORTIA. If the person is under 14 years of age, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and Security of Personal Data

VORTIA undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as data transmission between the server and the User, and in feedback, is fully encrypted.

However, since VORTIA cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay in the event of a personal data breach that is likely to entail a high risk to the rights and freedoms of natural persons. Pursuant to Article 4 of the GDPR, a personal data breach is understood to be any breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform the User of this and to ensure, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, partners, and any person to whom the information is made accessible.

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Rights arising from the processing of personal data

The User has rights over VORTIA and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights against the Data Controller:

Right of access: This is the User's right to obtain confirmation of whether or not VORTIA is processing their personal data and, if so, to obtain information about their specific personal data and the processing that VORTIA has carried out or is carrying out, as well as, among other things, information available about the origin of said data and the recipients of any communications made or planned.

Right to rectification: This is the User's right to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.

Right to erasure ("the right to be forgotten"): This is the User's right, unless otherwise provided by current legislation, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for this; the User objects to the processing and there is no other legitimate reason to continue; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of its implementation, must take reasonable measures to inform the data controllers processing the personal data of the data subject's request to erase any links to that personal data.

Right to restriction of processing: This is the User's right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make legal claims; and when the User has objected to the processing.

Right to data portability: If processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format and to transmit it to another data controller. Whenever technically feasible, the Data Controller shall transmit the data directly to that other controller.

Right to object: This is the User's right to request that their personal data not be processed or that VORTIA cease processing them.

Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by applicable law.

Therefore, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference "GDPR-https://vortia.eu/", specifying:

The User's first and last name, and a copy of their ID. In cases where representation is permitted, identification by the same means of the person representing the User, as well as the document proving the representation, will also be required. The photocopy of the ID may be replaced by any other legally valid means that proves identity.

Request with the specific reasons for the request or information to which access is sought.

Address for notification purposes.

Date and signature of the applicant.

Any document that proves the request.

This application and any other attached documents may be sent to the following address and/or email address:

Mailing Address: Delaware, 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex

Email: info@blueoceanmarketings.com

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Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to websites of third parties other than VORTIA, and therefore not operated by VORTIA. The owners of these websites have their own data protection policies, and they are, in each case, responsible for their own files and privacy practices.

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Complaints before the Supervisory Authority

If the User considers that there is a problem or a violation of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, particularly in the state where they have their habitual residence, place of work, or place of the alleged violation. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

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II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agree to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as accept the processing of their personal data so that the Data Controller can process it in the manner, during the time periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

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VORTIA reserves the right to modify its Privacy Policy, at its own discretion, or due to legislative, jurisprudential, or doctrinal changes from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy has been updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights.

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Who is responsible for the processing of your personal data?

The data controller is BLUE OCEAN MARKETING AND CONSULTING LLC, with Registration Number 32-0780146 and registered office at Delaware, 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA. (hereinafter, indistinctly, "VORTIA" or the "Entity"). For the proper management of your personal data, VORTIA has designated a Data Protection Officer. You can contact us with any questions you may have by contacting us at the following URL: https://vortia.eu/

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For what purposes is your personal data processed?

At VORTIA, we may process the personal data collected for the following purposes:

• 1. Contact: to manage the data of users who contact VORTIA through the contact form provided by the Entity. Your data will also be processed to manage any inquiries you may send us through the channels provided for this purpose on our website.

• 2. Registration in the customer area "https://vortia.eu/": to manage your registration in the "Account https://vortia.eu/" as well as any subsequent data that may be generated through this channel, for the purposes of general administration, maintenance, compliance, development, control, and management of the transactions you carry out through your Account https://vortia.eu/, as well as managing your relationship with the Entity.

• 3. Registration for activities and contests organized by VORTIA: Manage your registration and participation in the different activities or contests that VORTIA organizes for both its partners and anyone interested in participating.

• 4. Advertising for our own products and services: VORTIA may send you, via postal mail, email, SMS, and other electronic means of communication, both general and tailored to your needs, current and future advertising from the Entity itself, related to our own products.

• 5. Advertising for third-party products and services: Your data will be processed in this case for the purpose of sending you, via postal mail, email, SMS, and other electronic means of communication, current and future advertising, both general and tailored to your needs.

• 6. Profiling based on your purchases: Provided you authorize us, VORTIA will create profiles based on marketing studies and statistical and segmentation techniques and procedures that allow us to customize the offer of products tailored to your characteristics and needs, including the use of cookies. This acceptance will not imply automatic decision-making.

• 7. Other channels: We may also collect your data through other channels such as telephone, email, the VORTIA app, or social media. In this case, we will inform you of the purposes for which we will process your data and, where applicable, we will appropriately collect your consent through each of these channels.

• 8. Compliance with legal obligations: Compliance with legal obligations imposed on VORTIA in any respect, such as security or tax matters. This may entail, depending on the case and closely related to the aforementioned purpose, responding to judicial and/or administrative orders or requirements.

• 9. Conducting surveys and/or reviews of products and/or services. We will use your contact information to send you surveys that will allow us to know your opinion on the products purchased, as well as the service provided by VORTIA or other companies related to your purchase, such as shipping companies, Marketplace providers, etc.

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Purposes

To allow you to use the application's features and operate the service.

To allow you to use the application's features and operate the service.

To allow us to analyze traffic, sales, and the use of our features (statistical analysis).

To allow us to detect and analyze application anomalies and ensure their security.

To allow you to receive personalized messages.

To offer personalized advertising.

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Data Collected

Unique identifiers generated to retain your choices (e.g., cookie banner consent) or to identify your smartphone when using certain features (e.g., app clicks).

Your phone's characteristics and app version (e.g., smartphone language, time zone, app version, installation date).

Certain information from your VORTIA customer account to tailor your navigation within the app (e.g., product selection assistance).

Geolocation (subject to the associated permission granted by the system) (e.g., to view a product's availability in nearby stores).

Aggregate data about your use of the app (e.g., page views, clicks, duration of visit, etc.) to improve functionality.

Smartphone brand and model, IP address.

Browsing information (e.g., adding to cart, viewing a product sheet, last page visited). Customer account data, geolocation, advertising identifier.

Advertising identifier (subject to acceptance of advertising cookies and permission from the associated system).

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Legal Basis

Performance of contract (necessary for the app to function optimally).

Consent.

VORTIA's legitimate interest related to optimizing the app's operation / related to the provision of the service / related to the proper functioning of the app.

VORTIA's legitimate interest related to the security and proper administration of the app.

Consent.

Other purposes are related to the use of the website https://vortia.eu/, which you access through the app. Therefore, we invite you to consult the sections of this Policy for more information about these purposes.

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How can I express my choices about the use of my data in connection with the application?

As on the website, some operations that involve accessing information about your phone are necessary to implement the mobile app features you expect or to analyze the operation of our app and are not subject to your consent. For example, technical data that does not involve tracking outside the app, such as information regarding device type or app version, is collected to ensure the app is working properly (in-app push) and to resolve potential issues with the app (analysis and bug fixes).

Other operations are carried out for marketing or advertising purposes (e.g., collecting advertising identifiers, localization for product recommendation purposes, etc.). In these cases, your consent is required.

To express your choices about the use of your personal data for marketing or advertising purposes, you can:

• Accept or decline permissions associated with certain features

• Accept or decline trackers from the VORTIA app and website in the banner that appears when you browse the app.

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Focus on Permissions

Access permissions are devices implemented by your mobile phone to allow you to choose the features accessible to mobile applications for security and privacy reasons. Below is the list of permissions used in the VORTIA app:

• Camera: Scan a barcode.

• Geolocation: View product availability at the nearest store, find the nearest store, use Pay&Go, activate the app's "store mode," receive notifications of events or offers from nearby stores.

• Microphone and voice recognition: Perform a voice search in the product catalog.

• Push notification: Receive VORTIA messages from the app (order confirmations, personalized commercial offers linked to your browsing).

• Advertising ID: Access your phone's advertising ID to share it with third parties for advertising purposes and track the performance of mobile advertising campaigns.

• Calendar: Allows you to add store events to your calendar.

These permissions are not required for using the VORTIA mobile app, but declining them may prevent you from using certain features or making optimal use of the app. They will be proposed to you in context when they are necessary for using a feature.

You can deactivate the various permissions at any time in your mobile phone's settings.

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Collection of personal data by your mobile phone's operating system.

Certain personal data, particularly the phone's advertising identifier, is generated and collected by the publishers of your mobile phone's operating system (OS). We invite you to read the privacy policies of the operating system publishers (iOS, Android, HarmonyOS, etc.) to learn how the operating system publishers use your personal data as data controllers and the settings available on your phone.

What data do we process and from what source is it obtained?

The data processed comes from:

• Data provided by you through the completion of the forms provided for this purpose.

• Data derived from the provision of the service: indirectly, derived from the provision of the service itself and the maintenance of this activity. This category includes website browsing data.

• Data obtained from marketing studies in which you have agreed to participate and have given consent for their use.

Depending on the service, the data processed may include the following types:

• Identification data (e.g., first name, last name, ID, postal address, email address, telephone number).

• Data on purchases you make.

• Commercial information (e.g., interest in certain products).

• Any type of personal data processed that may be required by the legislation applicable to VORTIA.

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What is the legal basis for processing your data?

The processing of your data related to "Contact", "Registration in the https://vortia.eu/ area", and any other communication channels available to you, is based on the maintenance of your request and, where applicable, for the provision of the contracted services. The sending of advertising for both our own and third-party products will be based on the express consent of the interested party to VORTIA, which has been duly requested. The legal basis for processing data related to compliance with legal obligations is the processing necessary for compliance with a legal obligation applicable to the data controller.

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To whom is your data communicated?

The personal data processed by VORTIA to achieve the purposes detailed above may be communicated to the following recipients depending on the legal basis for the communication. Pursuant to the foregoing, the following data communications are intended to ensure the proper development of the contractual and/or commercial relationship and comply with VORTIA's legal obligations:

• Public Agencies and Administrations.

• Financial institutions (for the management of collections and payments, as well as the fight against fraud).

• Companies belonging to the VORTIA Group.

• Courier and transport companies with which the VORTIA Group provides shipping services.

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How long will we retain your data?

Personal data will be retained for the time necessary to provide the service or as long as you do not withdraw your consent. Subsequently, the data will be deleted in accordance with data protection regulations, which implies blocking. It will be available only at the request of judges and courts, the Public Prosecutor's Office, or the competent Public Administrations during the statute of limitations for any actions that may arise, and, after this period, it will be completely deleted.

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What are your rights?

Any interested party has the right to obtain confirmation as to whether VORTIA is processing personal data that concerns them or not. Similarly, as provided for in the General Data Protection Regulation, you have the following rights:

• Access your data: You have the right to access your data to know what personal data we are processing that concerns you.

• Request rectification or deletion/cancellation of your data: Under certain circumstances, you have the right to rectify any personal data that you consider inaccurate and that concerns you, and that is being processed by VORTIA, or even to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

• Request restriction of the processing of your data: In certain circumstances, you will have the right to request that we restrict the processing of your data. In this case, we inform you that we will only retain it for the exercise or defense of legal claims, as provided for in the General Data Protection Regulation.

• Data portability: In certain circumstances, you will have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, machine-readable format, and to transmit it to another data controller.

• Object to the processing of your data: In certain circumstances and for reasons related to your particular situation, you will have the right to object to the processing of your data, in which case we will stop processing it unless there are compelling legitimate reasons or to exercise or defend potential legal claims.

Likewise, you have the right, at any time, to object to the sending of advertising by electronic means that we send you, both our own and those of third parties, and to withdraw any of your consent, without affecting the lawfulness of the processing based on the consent prior to its withdrawal. You may exercise the rights described above by means of a written request by postal mail addressed to BLUE OCEAN MARKETING AND CONSULTING LLC, at the postal address Delaware, 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA, indicating "Data Protection" in the subject line, or electronically through the following link: https://vortia.eu/ In both cases, some method of identification will be required to confirm that it is you who is exercising this right. Finally, we inform you that you can file a claim with the Spanish Agency for Data Protection and European Dispute Resolution, especially when you have not obtained satisfaction in the exercise of your rights. You can contact them through

their website:

https://ec.europa.eu/consumers/odr/main/index.cfm?event=main.home2.show&lng=EN

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