POLICY ON INFORMATION PRIVACY AND THE USE OF COMPUTER TOOLS

1. OBJECT AND SCOPE OF APPLICATION

This policy applies to all of the companies listed below which are part of the SGEL Group (hereinafter SGEL).

• Sociedad General Española de Librería, S.A. (SGEL)
• Sociedad de Inversión y Gestión de Mercancías y Articulos, S.A. (SIGMA)
• Zona Europea de Negocios de Distribución Internacional y Servicios S.L. (ZENDIS)
• TOPCODI SLU.
• FREACTION SLU
• Distribuciones Graña 2007 S.L.
• AELIA Retail España S.A.
• DistriRueda 2011 SLU

At SGEL, we consider INFORMATION to be one of our most important assets. Therefore, we have implemented the technical and organisational security measures needed to protect information against potential threats and vulnerabilities in order to prevent the loss, destruction, misuse, alteration, unauthorised access or theft of information processed by the Company.

At SGEL we believe we have a fundamental obligation to guarantee the rights of all persons to their privacy and the protection of their personal data and to that end we have assumed a formal commitment to protect those rights and to document the way in which private information is collected, processed and shared.  At the same time, the Company is also bound by certain obligations imposed by the laws in force on this subject as well as obligations relative to the intellectual property rights of the owners of the software and other products protected by intellectual property rights which we use in our business operations.

This Policy on Information Privacy and the Use of Computer Tools represents a commitment to protect the confidentiality of all information stored, collected, processed or disclosed by the Company and compliance with the laws in force on personal data protection and intellectual property or any others associated with the use and processing of information and electronic communications.  The law describes certain measures intended to ensure the effectiveness of the aforementioned commitment, notwithstanding others that may be adopted.

The Company will oversee compliance with this policy and any violation of the policy will be considered a transgression of contractual good faith.

2.- CONFIDENTIALITY AND INTEGRITY OF INFORMATION

The company considers that all information stored in its systems and corporate network is confidential and since it specifically considers all of the information handled by the company to be its property, it is particularly sensitive to the obligation to demand that each and every user who handles such data, applications, computer tools or any other information asset owned by SGEL comply with the duty of secrecy, proper use and confidentiality.

Unless specifically authorised, copying, disclosing or transferring confidential information to third parties or to company employees and users who are not authorised to access such information is prohibited by SGEL.

All information handled by SGEL in the course of its business operations is considered confidential information, including particularly sensitive information such as SGEL's industrial or commercial secretes and other information which may include but is not limited to the following:

• Commercial purchase and sale conditions.
• Information related to procedures for servicing our clients, publishers and suppliers.
• Information processed by SGEL that is considered personal data under Spanish law.
• Databases of customers, users, subscribers and employees; marketing and sales plans and any other materials that are part of the company's industrial or commercial strategy.
• Information relative to partnership plans, agreements or the acquisition of other companies in the same or other sectors.  Information on the development of new lines of business and the related negotiations.
• Procedures, methodologies, source codes, calculations and other documentation associated with business processes.

In order to preserve the integrity of the confidential information processed and managed by SGEL, technical and organisational measures will be established to guarantee compliance with the laws in force and prevent incorrect, abusive, illegal or harmful practices that may result in the loss, disclosure, unauthorised use, transformation or destruction of SGEL's information assets.

3.- CONFIDENTIALITY AND DUTY OF SECRECY

The confidential information managed by SGEL includes the processing of personal data. The processing of these data involves a series of obligations for the company and for the employees of the company who have access to the data in the performance of their functions, pursuant to Spanish law.

The right to the protection of one's personal data is recognised as a fundamental right in our legal system which is regulated in Organic Law 15/1999 of 13 December on the Protection of Personal Data (LOPD) and the regulation which developed it, approved by Royal Decree 1720/2007 of 21 December (RLOPD).   SGEL is constantly making adjustments and adapting to the technical and legal requirements of these laws. 

Article 10 of LOPD stipulates that anyone who participates in any stage of the process involving the processing of personal data is bound by the obligation of professional secrecy in respect thereof.

Pursuant to this article, all employees who, in the performance of their functions, have access to the personal data for which SGEL is responsible, are obligated to keep all such information confidential and to refrain from disclosing any or all of it, directly or indirectly, or making it available to third parties, on any medium containing such information, obligations which remain in effect even after the end of the relationship with SGEL.

A breach of these obligations can have serious consequences for the Company, including, among others, the levying of fines as provided for in the LOPD. Moreover, breaches may result in the criminal liability classified in Title X of Book II of the Penal Code. SGEL reserves the right to take the pertinent civil and/or criminal actions against the employees responsible for breaching these obligations in each case.

In compliance with the terms of article 89.2 RLOPD, by means of this Policy on Information Privacy and the Use of Computer Tools, the employee is hereby informed of all of the rules and obligations affecting the performance of his/her functions and the potential consequences of a breach of those obligations.

4.- SECURITY MEASURES ADOPTED

This Policy on the Information Privacy and the Use of Computer Tools, equipment, applications, Internet and email which is provided by SGEL to all employees and service providers for the performance of their labour and mercantile obligations, requires the adoption of certain measures intended to preserve the confidentiality of the information, prevent misuse, avoid damages that could affect the company's assets and prevent violations of the laws in force, including the current law regulating the protection of personal data or the intellectual property laws in relation to the use of software involving acts of piracy such as making illegal copies of proprietary software or other products protected by intellectual property laws used by the Company under license.

The following rules regulating the responsible use of computers, applications, email and Internet are designed to facilitate communications and to optimise the use of electronic transmissions and are therefore intended to prevent errors and malpractice in the use of this technology.

I.- General rules of use for personal computers and peripherals, use of applications and access to the company's information.

1- SGEL's information resources, including networks and connections, must not be used for purposes other than the intended purposes which are those related to the performance of the user's functions for the company in compliance with his/her job responsibilities.

2- In order to impede the unauthorised access to confidential information or the unauthorised use of terminals, the user must adopt appropriate measures to prevent third party access to these terminals by adequately protecting access codes and locking the workstation when the user steps away.

3- The user assumes the obligation to keep the personalised passwords assigned to him/her secret and is responsible for safeguarding them and updating them periodically.  All passwords and access codes provided are considered personal, non-transferable and secret and therefore the user is responsible for any type of network access using them.  If there is reason to suspect that the confidentiality of the passwords may have been compromised, the company's Systems Department must be informed immediately.

4- Regarding the use of printers and copiers, all users must practice diligence regarding the confidentiality of the different reports that are printed or copied and assume responsibility for their protection while in use.

5- Users may not connect any communication equipment to any of SGEL's information resources that makes it possible to connect to the corporate network and likewise may not connect to the SGEL network using any means other than those defined and administered by the company's Systems Department.

6- In order to preserve the confidentiality of the information, SGEL expressly prohibits the use of computer programmes other than those authorised and provided by the company's Systems Department.  Consequently, the user is personally responsible for any damages caused by the use of programmes other than those mentioned above and particularly in those cases where unlicensed programmes are used.

7- At the same time, copying, communicating or transmitting the information processed by the company and contained in its applications, equipment, systems or files, automated or otherwise, accessed by users in the performance of their functions is strictly prohibited by SGEL, except for the normal use for which such information is intended.  It is important to note the duty of secrecy and confidentiality incumbent upon all personnel who process personal information according to the law.  Therefore, actions on the systems that compromise their stability or the information stored therein should be avoided and any failures detected should be reported to Systems Department management.

8- For security reasons and also considering the occupancy of the lines, all file downloads should be work-related. However, and given the legally-protected intellectual property rights, SGEL declines any liability for the violation of these rights as a consequence of the unlawful downloading and use of any product in the company's computers not supplied by the company.  To this end, and by virtue of the commitment undertaken, SGEL regularly manages and updates the list of applications used under license in each computer, area and department.

II. - Conditions of Use of Internet and email.

1- The company provides its employees with the tools and applications needed to access the Internet and send emails and expects that its employees will use these tools responsibly and not abuse them.

2- Email accounts are personal and non-transferable and may not be used by unauthorised third parties.  The actions carried out from a user's account are the responsibility of that user.  For security and control reasons, SGEL records the electronic connections from corporate accounts noting the address, date and time of the communication carried out, preserving the personal privacy and fundamental rights of each user at all times.

III. Rules relative to the use of professional contact data

1- In those cases where it is necessary to gather and manage contact information for clients and suppliers, such information may only be professional in nature and must be limited to the full name of the contact person, the function performed or position held in the company and the professional contact information (postal or email address, telephone and fax number).

2- SGEL is not liable for data relative to contact persons other than those indicated.  If an employee gathers or processes any additional data, he/she does so at his/her own exclusive risk.

3- The contact information for clients and suppliers may not be used for any purpose other than maintaining the commercial relations between the contact persons and SGEL.

4- These rules apply to any agenda or database of contacts prepared by SGEL personnel, whether in hard copy or electronic format.

LEGAL NOTICE

Ownership of the website

As established in the Law on Information Society Services and E-Trade, you are hereby informed that this portal is managed by the SGEL GROUP, a business group dedicated primarily to marketing communication and entertainment products and services whose parent company is Sociedad General Española de Librería, Diarios, Revistas y Publicaciones,  S.A., with tax ID number A28015527, registered offices at Avda. Valdelaparra nº 29, Pol. Ind, 28108 Alcobendas, Madrid (Spain) and email address [INSERT].

Registration information: Madrid Business Register: Volume 966, Folio 192, Section 3, Page 9161, Entry 1 et seq.

GRUPO SGEL is composed of the following companies: Sociedad General Española de Librería, Diarios, Revistas y Publicaciones, S.A. (SGEL) with tax ID A28015527, Distribuciones Graña 2007 S.L. with tax ID B84955962, Distrirueda 2011 SLU with tax ID B86321452, AELIA Retail España, S.A. with tax ID CIF A84911379, Sociedad de Inversión y Gestión de Mercancías y Artículos, S.A. (SIGMA) with tax ID A79831327, Zona Europea de Negocios de Distribución Internacional y Servicios S.L. (ZENDIS) with tax ID B82979774 and TOPCODI, SLU with tax ID B85586212, all with registered offices at Avda. Valdelaparra nº 29, Pol. Ind, 28108 Alcobendas, Madrid (Spain).

Liability Limit

1- GRUPO SGEL is only liable for the damages sustained by the user as a consequence of using this website (hereinafter, the Portal) when the damages can be ascribed to a culpable act on the part of the company.

2- The user acknowledges and accepts that he/she uses the Portal and the services offered on the Portal at his/her entire risk and responsibility.

3- GRUPO SGEL declines any liability for damages caused by events that may include but are not limited to the following (i) inferences, omissions, interruptions, computer viruses, malfunctions and/or disconnections of the electronic systems or the computer equipment and devices of the users for reasons unrelated to GRUPO SGEL which impede or delay the provision of the service or the ability to browse the system; (ii) delays or inability to use the site due to deficiencies or overloads of Internet or other electronic systems; (iii) events caused by third parties through illegal interference beyond the Portal's control not ascribable to GRUPO SGEL; (iv) impossibility of rendering the service or providing access for reasons not attributable to GRUPO SGEL and caused by the user, third parties or events of force majeure.

4- As a rule, GRUPO SGEL does not control how the Portal is used by users.

Intellectual property rights

1- All of the contents displayed on the Portal, especially designs, text, graphics, logos, icons, buttons, software, trade names, trademarks, industrial drawings or any other signs for industrial or commercial use are subject to intellectual and industrial property rights held by GRUPO SGEL or third parties who have authorised their inclusion on the Portal.

2- Under no circumstances shall it be understood that a license of any kind is granted or that the aforementioned rights are partially or totally waived, transferred or assigned, or that any right or expectation of a right is granted, particularly the right to alter, exploit, reproduce, distribute or publicly communicate the contents without the express prior consent of GRUPO SGEL or other owners.

3- No link to the Portal may be established from any other website without the express prior consent of GRUPO SGEL.

All rights to the information contained on each and every one of the pages of this website are reserved. 

Portal modifications and updates

GRUPO SGEL reserves the right to modify or eliminate part of the contents of the website, images or information contained therein or to change the configuration in order to improve its appearance or accessibility.

LAST UPDATE  June 2012

© SGEL S.A., 2012 All rights reserved.