PRIVACY POLICY

Last updated: January 13, 2026

1. INTRODUCTION

At ASEPTIC PHARMA CONSULTING, S.L. (hereinafter, "TRI-CONSULTING") we are committed to protecting and maintaining the confidentiality of the personal data of our users, clients, and collaborators. This Privacy Policy describes how we collect, use, store, and protect your personal information in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), and Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).

2. DATA CONTROLLER

The controller of your personal data is:

3. PERSONAL DATA WE COLLECT

3.1. Data collected through the contact form

When you use our contact form, we collect the following data:

• Full name: To address you in a personalized way
• Email address: To respond to your inquiry
• Phone number: To contact you if necessary
• Message: The content of your inquiry

3.2. Data collected automatically

During your navigation of our website, we may automatically collect:

• Browsing data: IP address, browser type, pages visited, time spent
• Cookie data: As established in our Cookie Policy
• Analytics data: Anonymous statistical information about website usage (Google Analytics)

3.3. Data in commercial relationships

If you contract our services, we may additionally collect:

• Billing data (Tax ID, fiscal address)
• Banking data (for payment management)
• Professional data relevant to the provision of services
• Communications related to the contracted service

4. PURPOSE AND LEGAL BASIS OF PROCESSING

5. DATA RECIPIENTS

Your personal data will not be communicated to third parties, except in the following cases:

5.1. Service providers

We may share your data with service providers who help us operate our website and provide our services:

• Hosting services: Website data storage
• Email services: For sending communications
• Google Analytics: For statistical analysis of the website (anonymized data)
• Google reCAPTCHA: For spam protection in forms

All these providers have signed confidentiality and data processing agreements, acting as data processors according to Article 28 of the GDPR.

5.2. Legal obligations

We may communicate your data to public authorities when we are required by law, court order, or to protect our legal rights.

5.3. International transfers

Some of our service providers (such as Google) may be located outside the European Economic Area. In these cases, we ensure that appropriate safeguards exist through:

• European Commission adequacy decisions
• Standard contractual clauses approved by the European Commission
• Recognized certification mechanisms

6. DATA SUBJECT RIGHTS

As a holder of personal data, you have the following rights recognized by the GDPR:

6.1. Right of access (Art. 15 GDPR)

You may request information about whether we are processing personal data concerning you and, if so, obtain a copy of it.

6.2. Right to rectification (Art. 16 GDPR)

You may request the correction of inaccurate or incomplete personal data.

6.3. Right to erasure - "right to be forgotten" (Art. 17 GDPR)

You may request the deletion of your personal data when they are no longer necessary for the purposes for which they were collected, or when you withdraw your consent.

6.4. Right to restriction of processing (Art. 18 GDPR)

You may request that we suspend the processing of your data under certain circumstances.

6.5. Right to data portability (Art. 20 GDPR)

You may request to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and transmit it to another controller.

6.6. Right to object (Art. 21 GDPR)

You may object to the processing of your personal data when the legal basis is legitimate interest or they are processed for direct marketing purposes.

6.7. How to exercise your rights?

To exercise any of these rights, you may contact us by:

6.8. Right to lodge a complaint with the supervisory authority

If you consider that the processing of your personal data violates the regulations, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD):

7. SECURITY MEASURES

At TRI-CONSULTING we have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• SSL/TLS encryption: All communications through our website are encrypted
• Access control: Only authorized personnel have access to personal data
• Staff training: Our team is trained in data protection and confidentiality
• Backups: We perform periodic backups of data
• Security audits: We regularly review our security measures
• Password policy: Implementation of secure passwords
• System updates: We keep our systems and software updated

8. DATA RETENTION

We will retain your personal data only for as long as necessary to fulfill the purposes for which they were collected, including any retention period required by applicable law.

The criteria used to determine the retention period are:

• The duration of the contractual relationship
• Legal retention obligations (tax, commercial, etc.)
• The existence of claims or litigation
• Guidelines from data protection authorities

9. MINORS

Our services are aimed at businesses and professionals. We do not knowingly collect personal data from children under 14 years of age. If you become aware that a child has provided us with personal data without parental consent, please contact us so we can delete such information.

10. SOCIAL NETWORKS

TRI-CONSULTING may be present on social networks. The processing of data carried out on social networks will be governed by the privacy policies of each social network:

• LinkedIn: LinkedIn Privacy Policy

11. THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for the privacy policies of these websites. We recommend that you read the privacy policies of each website you visit.

12. UPDATES TO THE PRIVACY POLICY

TRI-CONSULTING reserves the right to modify this Privacy Policy to adapt it to legislative developments, case law, or changes in our business practices.

Any modification will be published on this page with sufficient notice. In case of substantial changes, we will notify users through a prominent notice on our website or by email when possible.

13. CONTACT

For any matter related to the processing of your personal data or to exercise your rights, you can contact us at:

14. APPLICABLE LAW

This Privacy Policy is governed by current Spanish legislation on the protection of personal data:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)
• Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD)
• Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE)

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