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At Rubio Verde Ltd. (“Rubio Verde”, “we, us”), we place a high value on the privacy and security ofpersonal data. We handle personal data for (1) our own objectives and (2) by following thedirections of our customers who utilize Rubio Verde's service (“Service”), where they upload andmaintain certain information. In this latter scenario, we meticulously follow our customers' instructions and do not use the data for any purposes other than delivering our Services.

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In this Privacy Policy, we outline how we process personal data for the following data subjects for our purposes:

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• our customers, their end users and representatives,
• website users,
• potential customers,
• our counterparties and their representatives.

This policy pertains to information collected within the Service, on our website, or on other websites managed by Rubio Verde where the Privacy Policy is displayed (the “Site”), within our Web apps, and from other sources.

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If you have any inquiries or suggestions regarding our privacy practices, please email us at ingo.lange@coaching-central.com. Additionally, send us an email if you would like to request data accessor deletion, or to exercise your rights as a data subject.

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1. Methods of Personal Data Collection

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The type of personal data we gather is primarily influenced by your interactions with Rubio Verde,which generally fall into these categories:

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• When you utilize Rubio Verde Service. Whenever you use Rubio Verde Service, we retain allthe content you share, including details about you as either a customer or a user of the Service. This data is collected directly from you when entered or from linked integrations like Facebook, Instagram, etc. We also gather data from you and your representatives when requests are made for signing a DPA or other documents. Additionally, we may acquire information from third parties, such as receiving confirmation from a payment service provider regarding the success of your payment.
• When you email or message us. Upon receipt of your emails or chat messages, we may store the message content, attachments, and your contact information.
• When you fill out forms on the Site or join our events. By completing forms on the Site (like for contact, subscription, demo requests, event registration), we collect your contact information and any details you provide in the form. If we co-host events with partners, we may also receive data from our partners.
• When accessing the Site. Using the Site results in the collection of specific information as elaborated below, which can, either alone or combined with other data, be seen as personal data (e.g., cookies).

2. Types of Personal Data We Process

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We gather and handle the following personal data:

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• Customer account details. To establish or update your account and deliver the Service, we collect from you and third-party integrations (e.g. Facebook, Instagram) information about you, as a customer or end-user of the Service. This includes id, name, email, status, linked pages and accounts, products in use, location, etc.
• Financial information. For processing your payments for the Service subscription, your credit card details (last four digits of the card number), account details and payment information are needed.
• Contact details and business data. We obtain information about our customers and potential customers for the purpose of cooperation and communication. This encompasses full name, title, company, email or other contact details as required.
• Requests, messages and submitted forms details. We receive and process your messages, support requests, emails and any information you share with us via online forms or social media accounts. This includes the content of such communications along with your contact details if any.
• Usage data, logs and other technical data. When you interact with the Service, metadata and log files are automatically collected. This data may cover the Internet Protocol (IP) address, your browser type and settings, the date and time when the Service was used, information about browser configuration plugins, language preferences, the pages or features browsed, time spent on those pages or features, the frequency of pages and functions use, and the links clicked on or used. If accessing the Service from your phone, this could also include the type of device, operating system, device settings and device identifiers.
• Website cookies and similar technologies. Cookie technology is employed on the Site.
• Customer Content. By using our Service, you might import into our system personal data you've gathered from your users, customers, prospective customers, social media, and messaging platform contacts (collectively referred to as “Subscribers”) or other individuals. We process this data solely on your behalf as our customer. We do not have a directrelationship with your Subscribers or any person other than you, requiring you to ensure youhave the appropriate permission and legal basis for us to collect and process informationabout these individuals.

We request that you refrain from sending or disclosing to us any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religionor other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) through the Service or by any other means.

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3. Purpose of Using Personal Data

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We gather and handle your personal data for the reasons outlined below:

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• To manage the Service: We utilize data to establish the agreement with you as a customer and to manage, maintain, and administer your account within the Service. This includes communicating with you about your account (such as sending announcements, technical notices, updates, security alerts, and support and administrative messages) and addressing any Service-related inquiries, questions, or feedback. We also leverage your data to fulfill our billing responsibilities.
• To deliver the Service, we process Customer Content information on your behalf as a client.
• To communicate and keep you informed about the Service. If you inquire for information, sign up for the Service, complete a form or feedback on a Site, or take part in our surveys, promotions, or events, we may send you Rubio Verde-related marketing messages if allowed by law. In all communications, we will offer you the option to opt-out.
• To organize events and communicate with you. We employ your personal data, as provided during event registration, to send event reminders, related communications, and information about Rubio Verde services. Additionally, we might solicit your feedback. Each communication always includes the option to opt-out.
• To adhere to legal requirements. We make use of your personal data as needed to comply with relevant laws, including sanctions, accounting and tax obligations, legal processes, or audits, and to respond to subpoenas or binding requests from governmental authorities. Before disclosing any information to an authority upon request, we carefully verify the validity of such a request.
• To negotiate, form, and execute agreements. We must collect and process information about our counterparties and their representatives to negotiate, establish, and perform legally binding agreements and collaborate with them.
• For compliance and safety. We employ your personal data as we deem necessary or appropriate to (a) enforce the terms and conditions governing the Service; (b) protect our rights, privacy, safety, or property, and/or that of you or others; and (c) guard against, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activities.

4. Distribution of Personal Data

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We do not sell your personal information to outside parties for business or promotional reasons. Your data is shared as outlined in this Privacy Policy or when we have your explicit approval for sharing.

We disclose personal data to third parties in the following situations:

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• Service Providers. We hire external companies and individuals to assist with certain activities,such as payment processing services. We also rely on third-party software for datamanagement (e.g., CRM systems, email platforms, cloud storage, etc.). You can view allprocessors and sub-processors at http://followflash.com/legal/list-service-provider. These third parties are allowed to use your personal data solely to perform these tasks for lawfulbusiness purposes, in line with the terms we have with these service providers, and for noother reasons.
• Professional Advisors. We may provide your personal data to professional advisors like lawyers, bankers, auditors, and insurers when needed in the delivery of their professional services to us.
• Third-party Applications and Integrations. For delivering the Service, we exchange data with integrations and applications linked by clients (Facebook, Instagram, Stripe, PayPal, etc.).
• Business Transfers. As our business evolves, we may sell or purchase businesses or assets. In the scenario of a corporate sale, merger, reorganization, dissolution, or similar event, personal data might be included in the transferred assets. You acknowledge and agree that any successor to or purchaser of Rubio Verde (or its assets) will retain the right to use your personal data and other information as per this Privacy Policy. Additionally, Follow Flash may disclose aggregated personal data to describe our Service to potential buyers or business partners.
• Compliance with Laws and Law Enforcement. Rubio Verde may provide information about you to governmental or law enforcement officials or private entities as required by law. We may reveal and use such data as we find necessary or appropriate to (a) comply with relevant laws and legal requests, like responding to subpoenas or requests from authorities; (b) enforce our Service's terms and conditions; (d) safeguard our rights, privacy, safety, or property, along with yours or others; and (e) protect against, investigate, and prevent fraudulent, harmful, unauthorized, unethical, or illegal actions.
• Use of Data and AI/ML Training. We affirm that any data accessed or fetched via Google Workspace APIs is not used to develop, improve, or train generalized artificial intelligence (AI) or machine learning (ML) models. We strictly use this data to provide the requested functionality to our users and in accordance with Google's API Services User Data Policy, including the Limited Use requirements.
• Corporate Affiliates. We might share personal data with our corporate affiliates. See the list at http://followflash.com/legal/list-service-providers.

5. Your Data Protection Rights & Choices

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Your rights include the following: If you wish to access your personal data that is collected by Rubio Verde, you can contact us at any time.

• You are also able to reach out to us to update, correct, or remove information in your account. For further details, visit http://followflash.com/legal/delete-account.
• If you are residing in the European Economic Area (“EEA”), the UK, or Switzerland, you have the right to object to the processing of your personal data, request limitation on the processing of your personal data, or request data portability where technically feasible.
• Similarly, if you are located in the EEA, the UK, or Switzerland, and we have collected and processed your personal data based on your consent, you have the option to withdraw your consent at any time. Withdrawing your consent will not affect the legality of any processing carried out prior to your withdrawal, nor will it impact processing based on other lawful grounds.
• You hold the right to file a complaint with a data protection authority regarding our handling of your personal data. Information on data protection authorities in the EEA, Switzerland, and certain non-European countries (such as the U.S. and Canada) is accessible at https://admin.google.com/rapt=AEjHL4NNE5k0Ydvl19MNbo2BqJtCdQaLsQbIl17Wmzve_MvacR6Pke_yWgqrshj_wJTysyRpeEbB4_kTAn9FdzJIhws5wxJS4ZuBA-g9SKvf-SsDlHVvXWw.

You can submit your request by emailing ingo.lange@coaching-central.com. We commit to responding to all requests in line with applicable data protection laws. Access to Data Controlled by our Customers. We do not have direct relationships with the Subscribers of our customers, i.e., the individuals whose personal data is stored by our customers through the Service. Individuals seeking to access, or correct, amend, or delete personal data processed by our customers should direct their requests to the customer directly.

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6. Duration of Personal Data Retention

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We will store and handle personal data until you end the Agreement with us as specified under the Terms of Service.
Additionally, some data might be retained for a period mandated by law or for the time needed to resolve disputes, prevent misuse, and uphold our agreements.

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7. International Data Transfers

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Your personal data could be stored and processed in any nation where we operate facilities or where we employ service providers. By accepting the terms of this Privacy Policy, you acknowledge and agree to (1) the transfer and processing of personal data on servers situated outside your country of residence and (2) our collection and use of your personal data as outlined here and in compliance with the data protection laws of the countries where we operate facilities or engage service providers, which might differ and potentially offer less protection than those in your own country.

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8. Information Regarding Children

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We recognize the importance of providing additional protection for children on the internet. We recommend that parents and guardians spend time online with their children to supervise, engage with, and/or oversee and guide their online activities. The Site and/or the Service are not designed for individuals under the age of 18, and Follow Flash does not intentionally gather or request personal data from those under 18.

If you are under 18, you should not try to register for the Service or send us any personal information, such as your name, address, phone number, or email address. If we discover that we have collected personal data from an individual under 18 without parental consent verification, we will promptly remove that data. If you are a parent or legal guardian of a child under 18 and suspect that we may have collected information from or about that child, please get in touch with us. We do not sell any Personal Data of our customers, including those aged between 13 and 18.

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9. Security

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Protecting Your Information

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We take reasonable and suitable measures to safeguard personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, considering the risks involved in processing and the nature of the personal data. Despite our efforts to store personal data gathered on and through the Site and/or the Service securely in an operating environment that is not accessible to the public, we cannot assure the security of personal data during its transmission or while stored in our systems. Furthermore, while we strive to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent unauthorized third parties, like hackers, from illegally accessing personal data. We make no promises or representations that personal data about you will be secure from loss, misuse, or changes by third parties. The credit card processing provider we engage with uses security measures to protect your information both during and after the transaction is complete. If you have any questions about the security of your personal data, please reach out to us via email at ingo.lange@coaching-central.com.

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Notice of Security Breach

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If a security breach results in an unauthorized entry into our system, significantly affecting you or your Subscribers, we will inform you as quickly as possible and subsequently report the actions we took in response.

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10. Legal Ground for Processing Your Personal Data (EEA Visitors/Customers Only)

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If you are situated in the EEA or the UK, our rationale for collecting and utilizing the personal data outlined above will depend on the purpose of processing and the relevant personal data:

We handle data to fulfill a contract with you regarding the use of the Service (Art. 6(1)(b) of the GDPR or UK GDPR);

We also process data based on our legitimate interests (Art. 6(1)(f) of the GDPR or UK GDPR) in the following scenarios:

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• to communicate with you and keep you informed about our Service;
• to comply with legal obligations we face;
• to organize events and interact with you;
• to negotiate, finalize, and execute agreements;
• for compliance and safeguarding.

We process certain types of cookie files with your consent (Art. 6(1)(a) of the GDPR or UK GDPR). More details can be found in the Cookie Statement. If we request you to provide personal data to fulfill a legal obligation or to enter into a contract with you, this will be communicated clearly at the appropriate time. We will inform you whether providing your personal data is mandatory or optional (as well as the potential outcomes if you choose not to provide your data). Similarly, when we collect and use your personal information based on our justified business interests, we will clearly communicate at the relevant time what those interests are. While you are not required to give us your personal data, if it is necessary for entering and executing a contract with you, and you choose not to provide it, we may be unable to execute the contract we have or are endeavoring to enter with you. If you have inquiries or require additional information regarding the legal grounds on which we gather and use your personal data, you can reach us by email at Ingo.lange@coaching-central.com.

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11. Legal Basis for Processing Your Personal Data (EEA Visitors/Customers Only)

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If you are a person located in the EEA or the UK, our legal basis for collecting and using the personal data described above will depend on the purpose of processing and personal data concerned:

• We process data to perform a contract with you on the use of the Service (Art. 6(1)(b) of the GDPR or UK GDPR);
• We also process data based on our legitimate interest (Art. 6(1)(f) of the GDPR or UK GDPR) in the following cases:
  • to communicate with you and inform you about our Service;
  • to comply with the law we are subject to;
  • to conduct events and communicate with you;
  • to negotiate, enter, and perform agreements;
  • for compliance and safety.
• We process some types of cookie files based on your consent (Art. 6(1)(a) of the GDPR or UK GDPR). See more details in Cookie Statement.

If we ask you to provide personal data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Similarly, if we collect and use your personal data in reliance on our legitimate business interests, we will make clear to you at the relevant time what those legitimate business interests are. You are not obliged to provide your personal data to us. However, if we need personal data in order to enter and perform the contract with you and you do not provide this data, we may not be able to perform the contract we have or are trying to enter into with you. If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, you may contact us by email at ingo.lange@coaching-central.com.

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12. Modifications to Our Privacy Policy

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From time to time, we might need to amend this Privacy Policy to accommodate legal, technical, or business advancements. When we make updates to our Privacy Policy, we will ensure you are appropriately notified prior to its implementation, in line with the significance of the changes made. We will seek your consent for any substantial changes to the Privacy Policy if required by the data protection laws applicable to us.

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You can determine the last update to this Privacy Policy by looking at the “Effective date” noted at the top. The revised Privacy Policy will be applicable to all existing and prior users of the website, superseding any previous notices that conflict with it.

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13. How to Reach Us

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Should you need further information or have any inquiries regarding our privacy policy, please feel free to reach out via email at ingo.lange@coaching-central.com.