/ DATA PRIVACY POLICY 

Company name: FIDES ELECTRÓNICA, S.L

Registered Office: 2222

Tax Identification Code: AV. CERDANYOLA, 98 – EDIF. COLLSEROLA, ESC.A

PLANTA 2 08173 SANT CUGAT DEL VALLÈS (BARCELONA)

Trade Register of Barcelona, Volume 42028, Sheet 8, Sheet Number B-399715

E-mail: fidesing@fidesing.com

Website: www.fides-electronica.com

According to the established in the Organic Law 15/1999, of Personal Data Protection (LOPD for its Spanish acronym), its development regulation, and the LSSICE 34/2002, of 11th july, on the Society of Information and Electronic Commerce, FIDES ELECTRÓNICA, S.L in obedience to what the LOPD articles 5 and 6 dispose, informs all users which may provide their personal data, that they will be added to an automatic file which is found duly registered at the Data Protection Spanish Agency.  

The users expressly accept, willingly and unequivocal, that their personal data will be treated by FIDES ELECTRÓNICA, S.L to perform the next purposes:

1.Delivery of advertising commercial communications via e-mail, fax, SMS, MMS, social communities or any other electronic or physical means, present or future, which make possible the commercial communications. Said commercial communications will be about products or services offered by FIDES ELECTRÓNICA, S.L, as well as by the collaborators or partners with whom a commercial promotion agreement for their clients has been established. In this case, the third parties will never have access to the personal data. In any case, the commercial communications will be made by FIDES ELECTRÓNICA, S.L and will be about its products and services, related to FIDES ELECTRÓNICA, S.L’s business sector.

2.Make statistical studies.

3.Process orders, requests or any other kind of petitions, which may be made by the user via any contact form put at the user’s disposition by FIDES ELECTRÓNICA, S.L.

4.The sending of the Newsletter to those users which have subscribed.

FIDES ELECTRÓNICA, S.L informs and expressly guarantees the users that their personal data will not be transferred in any case to third companies, and that in case a data transfer were to be made, the express, informed and unequivocal consent from the title holders would be previously requested.

Through the fulfilling and sending of the pertinent forms in this website, the User accepts and authorizes their personal data to be object of automatic treatment by FIDES ELECTRÓNICA, S.L. In case you add third people’s personal data to the website forms, you must obtain, previous to adding them, their consent and inform them of the points contained in the previous paragraphs.

 All the requested data through FIDES ELECTRÓNICA, S.L are mandatory, since they are necessary for the optimal services provided to the user. In case not all data is to be obtained, FIDES ELECTRÓNICA, S.L does not guarantee that the provided information and services will be completely adjusted to your needs.

FIDES ELECTRÓNICA, S.L guarantees the user the exercise of their rights of access, rectification, cancellation, information and opposition, in the disposed terms of the current legislation. Therefore, and according to the established in the Organic Law 15/1999, of Personal Data Protection (LOPD), you can exercise your rights addressing an express request, attached to a copy of your ID card via the next means:

1.E-Mail: fidesing@fidesing.com

2.Post Mail: AV. CERDANYOLA, 98 – EDIF. COLLSEROLA, ESC.A PLANTA 2 08173 SANT CUGAT DEL VALLÈS (BARCELONA)

3.Likewise, the user can unsubscribe from any of the given subscription services sending an e-mail to: fidesing@fidesing.com

In the same way, FIDES ELECTRÓNICA, S.L has adopted all the technical and organization measures needed to guarantee the security and integrity of the personal data that are treated, as well as to avoid loss, alteration and/or access from non-authorized third parties to them.

SECURITY

FIDES ELECTRÓNICA, S.L uses information security techniques, generally accepted in the business, such as firewalls, access control procedures and cryptographic mechanisms, all that with the purpose of avoiding the non-authorized data access. To accomplish these purposes, the user/client accepts that the providing party obtains data for the corresponding acknowledgment of the access controls.

INDUSTRIAL AND INTELLECTUAL PROPERTY

This web is owned by FIDES ELECTRÓNICA, S.L The intellectual property rights and the rights of exploitation and reproduction of this web, of its pages, screens, the Information they contain, their appearance and design, and the hyperlinks established from it to other web pages of any subsidiary and/or company dominated by FIDES ELECTRÓNICA, S.L, are of the exclusive property of the same, unless other thing is expressly specified. Any denomination, design and/or logotype, and any product or service offered and reflected in this web page, are brands duly registered by FIDES ELECTRÓNICA, S.L, by its subsidiaries and/or dominated companies or by third parties. Any undue use of the same by people other than their legitimate owner and without the express and unequivocal consent by that owner can be denounced and pursued by all the legal means existing in the Spanish and/or European Community legal system.

The intellectual property rights and brands of third parties are conveniently highlighted and must be respected by everyone gaining access to this page; FIDES ELECTRÓNICA, S.L is not liable for the use that the user may carry out to that regard; the user is solely liable.

You can only download the contents, copy or print any page from this web for a personal and private use. It is forbidden to reproduce, transmit, modify or delete the information, content or warnings from this web without the prior written consent of FIDES ELECTRÓNICA, S.L.

The contents provided by FIDES ELECTRÓNICA, S.L are subject to the rights of intellectual and industrial property and are of the exclusive ownership of FIDES ELECTRÓNICA, S.L or the individuals or legal entities we inform about. With the purchase of a product or service, FIDES ELECTRÓNICA, S.L does not grant the purchaser any right of alteration, exploitation, reproduction, distribution or public communication of the same; FIDES ELECTRÓNICA, S.L reserves all these rights. The assignment of the mentioned rights will require the prior written consent by the holder of the same, so that the client may not put those contents at the disposal of third parties.

The intellectual property extends, apart from the content included in FIDES ELECTRÓNICA, S.L, to its graphs, logotypes, designs, images and source codes used for its programming.

FIDES ELECTRÓNICA, S.L has obtained the information and materials included in the web from sources considered as reliable and, although reasonable measures have been adopted to ensure that the contained information is correct, FIDES ELECTRÓNICA, S.L cannot guarantee that in all moments and circumstances that information is exact, complete, updated and, consequently, you cannot trust it as if it were so. FIDES ELECTRÓNICA, S.L expressly declines any liability for mistakes or omissions in the information contained in the pages of this web.

FIDES ELECTRÓNICA, S.L reserves the power to modify, suspend, cancel or restrict the content of the web, the links or the information obtained through it, with no need for a prior warning. It in no case assumes any liability as a consequence of the incorrect use of the web by the user, both of the information and of the services contained in it.

In no case shall FIDES ELECTRÓNICA, S.L its branch offices and/or work centres, directors and/or attorneys, employees and, in general, the authorised staff be liable for any type of damage, losses, claims or expenses of any type, if they are the result, directly and indirectly, of both the use and/or diffusion of the web or the information acquired or accessed by or through it, or of its computer viruses, of operation failures or of interruptions in the service or transmission, or of failures in the line when using the web, both by direct connection and by links or other means, constituting for all legal purposes a warning to any user that these possibilities and events can take place.

FIDES ELECTRÓNICA, S.L is not liable for the webs that are not its own, to which you can access by links, or for any content put at the disposal of third parties. Any use of a link or access to a web that is not its own, will be performed voluntarily and at the exclusive risk of the user. FIDES ELECTRÓNICA, S.L does not recommend or guarantee any of the information obtained through a link, and is not liable for any loss, claim or damage arising from the use or bad use of a link, or from the information obtained through it, including other links or webs, for the interruption in the service or the access, or for the attempt to use a link or to use it badly, both when connecting to the web of FIDES ELECTRÓNICA, S.L and when gaining access to the information of other webs from the same.

GOVERNING LAW AND JURISDICTION

The applicable law in case of dispute or conflict of the interpretation of the terms that define this legal warning, as well as any other question related with the services in this website will be the Spanish Law.

QUALITY AND ENVIRONMENT POLICY

The General Management of FIDES ELECTRONICA SL, specifies the Quality and Environment Policy of the company through the following declaration and signature; this statement is accessible to all employees by posting on the company’s bulletin boards and available to external stakeholders through this publication.

Ever since the company was first established, FIDES ELECTRONICA SL has always presented its services in the electronics market, in the development, manufacture and sale of electronic circuits, based on the principal argument of its professionalism and the quality of its products and services.

The objective of our company’s quality and environment policy is to consolidate this situation, in all cases improving our service and paying attention to meeting the requirements of our customers and complying with current legislation and regulations.

In choosing FIDES ELECTRONICA SL, our customers can rest assured that they will receive a reliable response, from the first contact to the completion of the process.

To offer this reliability, the company considers that the following aspects are of the greatest importance:

  1. Address the needs of stakeholders (internal and external)
  2. Consolidation of our market presence as a supplier of electronic controls.
  3. Introduction of the appropriate technical resources to increase our service capacity.
  4. Increasing the knowledge of our staff, in order to maintain and extend our competitiveness.
  5. Optimization of the costs in each of our processes, to increase our profitability and efficacy.
  6. Reduction of occupational risks and improvement of working conditions to achieve an excellent work environment.
  7. Reduction in the impact of our processes on the environment and the prevention of environmental pollution and acting on significant environmental aspects.
  8. Ongoing analysis of the processes and management system, in reference to indicators, and the application of concepts and tools based on continuous improvement, establishing quality and environmental objectives and improving the performance of both the organization and the environment.

The Quality System has been developed under my supervision and has my full support. All the details of the policies, procedures and practical aspects are set out in a simple and dynamic way in the Quality and Environment Manual, the Procedures Manual and the work instructions.

Although the coordination and execution of the necessary Quality and Environment management actions have been assigned to the responsible person, the ultimate responsibility for achieving it rests with me. For this reason, I guarantee the necessary human, technical and economic resources to achieve them.

CONFLICT MINERALS POLICY

Sustainability in its three dimensions (environmental, social, and economic) is of the highest importance for Fides Electronica. Sustainable conduct forms the basis of our business decisions and dealings with our stakeholders.

Along with governments, NGOs, the investment community, and many other companies worldwide, we are concerned about human rights violations including forced labor, human trafficking and child labor occurring anywhere in the world, as well as the role that armed conflicts play in causing extreme violence across the Democratic Republic of the Congo and its adjoining countries (“the DRC region”).

In 2010, the U.S. Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), pursuant to which the U.S. Securities and Exchange Commission (the “SEC”) issued rules requiring certain reporting companies to make disclosures under specific circumstances concerning the use of “Conflict Minerals” – defined in the
Act as tantalum, tin, tungsten (and the ores from which they originate) and gold. Conflict Minerals are used in the manufacture of a variety of commercial products.

We have rolled out a uniform and enterprise-wide process to determine the use, source and origin of Conflict Minerals in our supply chain. We work closely with our direct suppliers to support us in carrying out these steps. Where necessary, we work with suppliers in order to remediate risks and perform additional due diligence so that we

can continue to source responsibly, building on established management processes.

Because of our support for human rights and our concern that funds from purchases of materials used in our supply chain may be exploited for illegal purposes, we are taking systematic steps to understand whether any Conflict Minerals in our products are financing the conflict and violence in the DRC region. 

SUPPLIER EVALUATION POLICY-CRITERIA

Appreciated Supplier,

Our Quality Management System establishes the need to evaluate and select the suppliers based on their ability to comply with established commercial commitments. Consequently, we inform you that your performance will be evaluated based on the orders received, taking into account the following criteria:

  • Technicians: compliance with the delivery deadline, incidents and technical capacity.
  • Commercial and economic: price in relation to the competition and payment terms.
  • Business: trajectory as a supplier, ease of understanding and billing volume.
  • ISO 9001 Certification
  • ISO 14001 Certification

An analysis of the anomalies that may occur will be carried out and, if the incident requires it, the Non-Conformity will be communicated for correction. These Non-Conformities will lead to a negative assessment by our Quality and Purchasing Departments. In case of repeated Non-Conformities, or a deficient annual qualification, FIDES ELECTRÓNICA, SL will contact the supplier to request possible actions to correct the problems detected, being able to reach the de-homologation of the supplier.