LEGAL POLICY

1. OWNERSHIP OF THE WEBSITE:

This domain https://www.auraam.com/ (hereinafter the “Website”) belongs to the commercial entity “AURA ASSET MANAGEMENT, S.L.”, a company of Spanish nationality, with registered office in Madrid, calle Almagro 3, 4º right, with C.I.F. number B‐87.056.123, registered in the Commercial  Register  of  Madrid,  in  volume  32.519,  sheet  111,  page  M‐585.319  (hereinafter  “Aura”).

2. CONDITIONS OF USE:

Access to and use of this Website implies the user’s acceptance of these General Conditions of Use (hereinafter, “General Conditions of Use”). Therefore, if the user does not agree with these General Conditions of Use, he or she must abstain from accessing the Website.

3. DISCLAIMER OF LIABILITY:

a. Exoneration of responsibility for the contents.

Aura does not guarantee the topicality, correctness, completeness or quality of the information provided. Aura will not be held responsible for material or immaterial damages derived from the use of the Website and/or the use or non‐use of the information provided in the Website being the exclusive responsibility of the person who accesses or uses them.

Aura expressly reserves the right to modify, supplement or delete publications temporarily or permanently. Aura has no obligation to control the use that the user makes of the Website, the services and the contents. Aura excludes any responsibility for damages of any nature that could be due to the use of the contents by the user.

Aura may, when it deems appropriate, make corrections, improvements or modifications to the information contained in the Website, services, or content without this giving rise to any right to any claim or compensation, or imply recognition of any liability.

b. Exoneration of responsibility for the contents facilitated by the users.

If any of the content, files, information, advertising, opinions, concepts and images hosted on the Website were contrary to law, morality, good faith and public order or contain any type of computer virus or similar software routine will be removed.

Aura is not responsible for the contents, files, information, advertising, opinions, concepts and images that do not depend on the Website, nor are managed by Aura.

Aura  will  not  assume  any  responsibility,  direct  or  indirect,  derived from the bad use of  the  Website or its contents by the user assuming, in any case, under his exclusive responsibility, the consequences, damages or actions that could be derived from his access or use of the Website or of the lodged contents, as well as of his reproduction or communication.

c. Exoneration of responsibility for the operation of the Website.

Aura provides its services and content on a continuous basis using all technical means at its disposal to perform such provision in a satisfactory manner. However, Aura does not guarantee the availability of the Website.

Aura  excludes  any  responsibility  for  damages  of  any  nature  that may be  due to  the  lack  of  availability or continuity of the operation of the Website. In any case, Aura will carry out all the necessary actions to re‐establish its services in case of technical failure.

Aura  cannot  control,  the  absence  of  virus  or  elements  in  the  contents,  that  can  produce  alterations in the Software or Hardware of the users that visit the Website, reason why it will not respond of the damages and prejudices of any nature that could be derived from the same ones.

d. Exoneration of responsibility for the contents housed in pages accessible from the Website.

Aura is not responsible for any of the contents, files, information, advertising, opinions, concepts and  images  that  are  emitted,  published  or  distributed  directly  or  indirectly  through  any  interconnected web that is accessed through the Website by means of links, or any of the services that are linked or related to this interconnected Website. Likewise, 

Aura  excludes  its  responsibility  for  the  services,  goods  or  products  that  may  be  acquired or contracted from third parties through access to the Aura Website, especially in those cases in which the purchase or contracting process is carried out directly on the web page of the third party and even though they appear distinctive or a “frame” with the graphic elements of the web page (branding).

Unless Aura has previously and expressly authorised it, a link, hyperlink, framing or similar link may not be inserted in the direction of the Website.

4. OBLIGATIONS OF USERS:

The user is obliged to make reasonable use of the Website and its contents, according to the possibilities and purposes for which it is intended.

In particular, the user undertakes to make diligent, appropriate and lawful use of the Website as well as of the contents and services, in accordance with: (i) the legislation applicable at all times; (ii) morality and generally accepted good customs, (iii) public order (iv) the provisions of these General Conditions of Use.

The user undertakes to use the contents diligently, correctly and lawfully. It is strictly prohibited and, therefore, its consequences will be the sole responsibility of the user, access or use of the Website and its content for illegal or unauthorized purposes. In particular, by way of illustration only and not as a limitation, they abstain from:

(a) Use the Website in a manner, for purposes or effects contrary to the law, morality and generally accepted good customs or public order.

(b) Reproduce  or  copy,  distribute,  allow  public  access  through  any  form  of public communication, transform or modify any aspect of the Website.

(c) Perform any act that may be considered a violation of any intellectual or industrial property rights belonging to Aura or third parties.

(d) Use  the  information  of  any  kind  obtained  through  the  Website  to  send advertising, communications for direct sales purposes or any other kind of commercial purpose, unsolicited messages addressed to a plurality of people regardless of their purpose, as well as to market or disseminate in any way such information.

(e) Not to use false identities, nor to supplant the identity of others in the use of the Website or in the use of any of the services of the Website.

Aura  will  not  assume  any  responsibility,  direct  or  indirect,  derived from the bad use of  the  Website or its contents on the part of the user assuming, in any case, under his exclusive responsibility, the consequences, damages or actions that could be derived from his access or use of the Website or of the lodged contents, as well as of his reproduction or communication.

Aura reserves the right to cancel or restrict access to the Website to certain users, in the event of observing any conduct that in the opinion of Aura are contrary to these General Conditions of Use, the Law, the rules established by Aura or its collaborators or may disturb the proper functioning, image, credibility and/or prestige of Aura or its collaborators.

5. INTELLECTUAL AND INDUSTRIAL PROPERTY.

Aura, as the author of the collective work of which the Website consists, is the owner of all industrial and intellectual property rights over it.

Any form of reproduction, distribution, public communication, modification and, in general, any act of exploitation of all or part of the contents (images, texts, design, indexes, forms, etc.) that make up the Website, as well as the databases and software necessary for the visualization or operation of the same that does not have the express prior written permission of Aura.

The user may not, in any case, exploit or use commercially, directly or indirectly, in whole or in part, any of the contents (images, texts, designs, indexes, forms, etc.) that make up the Website without the prior written permission of Aura.

All the contents, without exclusion and in a not limited way, that form part of this Website, that is to say, information, articles, data, texts, logos, icons, images, design and image of the Web Site (external appearance or  “look and feel”),  video  files, audio  files,  databases,  computer  applications, are the property of Aura or are exploited under license of third party holders of the intellectual and/or industrial property rights of the mentioned contents. These are protected by intellectual and industrial property laws in force.

All  trademarks  and  logos  of  Aura  referred  to  on  the  Website  are trademarks  or registered  trademarks of Aura.

6. DATA PROTECTION:

Aura, in accordance with the provisions of Organic Law 15/1999, its implementing regulations and the recent EU Regulation 2016/679 of the European Parliament and Council of 27 April 2016 (LOPD) and its implementing regulations, guarantees the security and confidentiality of personal data  provided  by  the  user  through  the  Website,  as  well  as  any  other  means  (computer,  telephone…). Aura is particularly sensitive to the protection of personal data of users of its services (hereinafter, the “Data Protection Policy”).

Aura informs the users of the Website, of the uses to which the personal data collected and provided to Aura are submitted, in order to decide, freely and voluntarily, if they wish to provide the requested information.

Aura  reserves  the  right  to  modify  this  Data  Protection  Policy  in  order  to  adapt  it  to  new  legislation, jurisprudential criteria, industry practices, or interests of the entity. Any modification in it will be announced with due notice, so that users have perfect knowledge of its content.

6.1. RESPONSIBLE: The person responsible for processing personal data is the company “AURA ASSET MANAGEMENT, S.L.”, a company of Spanish nationality, with registered office  in  Madrid,  calle  Almagro  3,  4º  right,  with  C.I.F.  number  B‐87.056.123,  whose  contact details are: emmanuel@auraam.com / +34617836456

6.2. PURPOSE OF THE PROCESSING OF THE DATA: The data facilitated by the user will be  treated  with  the  purpose  of  managing  and  attending  to  requests  of  information,  doubts, complaints, congratulations or suggestions to any services or activities or acts provided by Aura.

Aura undertakes to keep secret with respect to them, guaranteeing the duty to keep them,  taking  all  necessary  measures  to  prevent  their  alteration,  loss,  treatment  or  unauthorized access, of in accordance with the legal obligations of the party responsible for processing your personal data.

6.3.  CONSERVATION  OF  DATA:  The  personal  data  provided  will  be  kept  for  the  corresponding period to comply with legal obligations, if any, or for as long as a judge or court may require them.  Data based on consent will be retained  as long as the user  refuses consent or opposes processing.

6.4. LEGITIMACY OF VBARE FOR DATA PROCESSING: Aura is entitled to the processing of personal data provided by users on the basis of the consent given by the data subject for one or more specific purposes, as stated in Article 6.1. a) of the General Regulation on the Protection of Personal Data.

n case the user provides personal data to Aura as a consequence of the use of telephone voicemail, the fact of having provided personal data imply the consent and knowledge by the user to the processing of their personal data.

In  the  event  that  the  user  provides  personal  data  to  Aura  as  a  result  of  the  use  of  telephone voicemail, the fact of having provided personal data, implies the consent and knowledge by the user to the processing of their personal data.

6.5. ACCURACY OF  DATA AND VERACITY  OF DATA: The  user  will  be  responsible  for  providing truthful and lawful information. In order that the data in the files, computer and/or paper, always correspond to reality, Aura will try to keep them updated. To this end, the user must communicate the change or update of data to Aura.

6.6. ASSIGNMENT OF DATA: Aura will not transfer the data to third parties, unless there is a legal obligation.

6.7. CHECKING OF DATA: The user will have the right at any time to be informed by Aura whether their data is being processed correctly, as well as to lodge a complaint with the Spanish Data Protection Agency in case of disagreement with the treatment carried out by Aura.

6.8.  RIGHTS  OF  USERS:  The  user  may  at  any  time  exercise  their  rights  to:  i)  request  access to their personal data, ii) rectification of their personal data iii) deletion and forgetting of their personal data, iv) limitation of the processing of their personal data, v) oppose the processing of  their  personal data  and  vi)  request  the  portability  of personal data.

To this end, the user must send a written request to Aura, to its registered office at Calle Almagro number 3, 4º floor right of Madrid through emmanuel@auraam.com / +34617836456. Aura must resolve the request made by the user within a maximum period of ONE (1) MONTH from receipt of the request, which may be extended to TWO (2) MONTHS taking into account the complexity of the request or the number of requests received.

7. CHANGES AND MODIFICATIONS TO THE GENERAL CONDITIONS OF USE AND THE WEBSITE:

Aura reserves the right to unilaterally modify, at any time, the present General Conditions of Use for legal reasons, for technical reasons or due to changes in the provision of the service or in the access to the contents or to the Website, as well as to make modifications that could derive from applicable codes of conduct or, in its case, by strategic corporate decisions notifying the Users through the Website.

Likewise, Aura may change, suspend or eliminate any aspect of the Website, such as access to certain  functions,  databases  or  contents  of  the  Website,  when  it  deems  it  appropriate  and  without prior notice. Aura may also restrict access to all or certain parts of the Site by notifying users through the Website.

Aura shall be exempt from any liability arising from the actions described in this clause, provided that it publishes the modifications on the Website.

8. APPLICABLE LAW AND JURISDICTION

The use of the Website shall be governed by Spanish law. Any controversy arising in connection with its use will be subject to the non‐exclusive jurisdiction of the Spanish courts and tribunals.