IDENTIFICATION OF THE DATA CONTROLLER

The Data Controller of personal data is:

• Entity: ARCTIC SEA, S.L.
• Address: San Lorenzo Bidea, 10, 48100 Mungia, Bizkaia, Spain
• NIF: B-95776795
• Email: info@clcircular.com
• Phone: +34 627 72 23 89
• Website: https://www.clcircular.com

Hereinafter, “Arctic Sea,” the “Data Controller,” or the “Owner.”

This document (hereinafter, the “Privacy Policy”) informs about the data processing carried out by Arctic Sea regarding users (the “User/s”) who visit the website (hereinafter, the “Website”).

This Privacy Policy is divided into the following sections:

1. Principles applied in data processing.
2. Purposes for which we process data, categories of data, legal bases, and retention period.
3. Data recipients.
4. Rights.
5. Security.
6. Acceptance and consent.
7. Changes to the Privacy Policy.

1. PRINCIPLES APPLIED IN DATA PROCESSING

In the processing of personal data, the Owner will apply the following principles:

• Lawfulness, fairness, and transparency: The Owner will always require consent for the processing of personal data, which may be for one or more specific purposes about which the User will be informed in advance.
• Data minimization principle: Only the strictly necessary data for the required purpose(s) will be requested.
• Storage limitation principle: Personal data will be retained for the time strictly necessary for the purpose(s) of processing, informing the User of the retention period according to the purpose.
• Integrity and confidentiality principle: The security, confidentiality, and integrity of personal data will be guaranteed, preventing unauthorized access or misuse by third parties.

2. PURPOSES, CATEGORIES OF DATA, LEGAL BASES, AND RETENTION PERIOD

2.1. Data processing related to website management

Simply visiting this website and browsing its sections does not require the User to provide any personal data directly or register. However, cookies may be installed on the User’s device as stated in our Cookies Policy.

Purposes of processing:

• Ensure compliance with the Legal Notice and applicable law.
• Support and improve the services offered by this Website.
• Analyze user navigation through cookies (details in the Cookies Policy).
• Manage social networks, informing Users about Arctic Sea activities without sending individualized advertisements.

Categories of processed data:

• Non-identifiable data: IP address, geolocation, browsing habits.
• Personal data: name, surname, postal address, email, phone number, data provided in forms or attached documents.

Legal basis: Processing is based on the User’s consent when providing information through contact channels or accepting the Privacy Policy.

Retention period: Data will be retained as long as necessary for its purpose and until deletion is requested.

2.2. Use of Artificial Intelligence

Arctic Sea may use AI-based tools and technologies for:

• Data analysis.
• Document drafting and review.
• Audiovisual content production.
• Process automation.

AI usage will be subject to prior evaluation to ensure compliance with ethical, legal, and security requirements.

3. DATA RECIPIENTS

The web analytics service used is Google Analytics, provided by Google, Inc. You can review Google’s privacy policy at:

• https://policies.google.com/privacy?hl=en

4. RIGHTS

The User has the right to:

• Request access to their data.
• Request data portability.
• Request rectification or deletion of data.
• Request restriction of processing.
• Object to processing.

To exercise their rights, the User must send their request along with a copy of an official identification document to info@clcircular.com.

5. SECURITY

The Owner takes measures to prevent loss, misuse, unauthorized access, disclosure, or alteration of personal data. Data will not be transferred to third parties except when legally required or when a service contractually requires a data processor.

6. ACCEPTANCE AND CONSENT

The User declares to have been informed of the conditions on personal data protection and accepts the processing under the terms and purposes indicated in this Privacy Policy.

To contact the Owner, subscribe to a newsletter, or leave comments, acceptance of this Privacy Policy is required.

7. CHANGES TO THE PRIVACY POLICY

The Owner reserves the right to modify this Privacy Policy to adapt it to legal, jurisprudential, or industry practice updates. These policies will remain in effect until modified and duly published.