---

AnyTech365 is a PC and Internet Help and Support company, specialised in providing high quality service to private consumers and small businesses.

AnyTech365 is founded by a team of Internet and security software entrepreneurs with multiple highly successful companies on our CVs. The cornerstone of all these companies has always been Retention, Compliance, Customer Satisfaction, and high level Service and Support.

These guiding principles and values have successfully been built into the DNA of AnyTech365, which today is among the leading European Internet Security, Help and Support companies. We excel in providing end users, small businesses and software vendors with the best service out there by having a team of friendly and certified IT-experts available 24 hours a day, 365 days a year.

We are based in Marbella, Spain, which is one of Europe's biggest and most popular holiday destinations. This location is carefully chosen as literally all nationalities and age groups are drawn to Costa del Sol’s sunny weather and fascinating lifestyle. Hence, we are proud to say that we cover any country and language with highly motivated and native speaking agents and IT experts ready to give end users a fantastic service!

For further information, please do not hesitate to contact us!

Complying with the Act 34/2002 of 11th June regarding Company Services for Information and Electronic Commerce, we would inform you that Anteco Systems trading as AnyTech365, domiciled at Anteco Systems, Edificio Los Pinos, Local 3, CN-340 KM-189, 29604, Marbella, Malaga, Spain, CIF: B-93311710, is the title owner of this website.

According to the provisions of the Spanish Organic Act 15/1999 regarding Personal Data Protection, in the event that an e-mail is sent to us to the address shown in the same, or that a data collection form is filled in, we would inform you that the personal data given to us will be registered in the file for which Anteco Systems trading as AnyTech365 is responsible. The purpose of the same is to deal with the enquiry, maintain a commercial relationship and to send by any means including by e-mail, or other equivalent electronic communication, publicity or promotional information regarding the products or services of the company.

You will be able to express refusal of your data being processed for publicity purposes and to exercise the rights of access, rectification, cancellation and opposition in accordance with that established in current legislation, by writing to the following address: Anteco Systems trading as AnyTech365, domiciled at Anteco Systems, Edificio Los Pinos, Local 3, CN-340 KM-189, 29604, Marbella, Malaga, Spain or to the e-mail address info@anytech365.com. Anteco Systems trading as AnyTech365 declares that it has adopted all the necessary and relevant security measures as established in the Spanish Royal Decree 1720/2007 of 21st December, by which the Regulatory Decree implementing the LOPD [Ley Orgánica de Protección de Datos - Spanish Personal Data Protection Act] was approved, and that it has established all technical methods within its means to avoid the loss, wrongful use, alteration, non-authorized access or theft of the data you may supply.

Anteco Systems trading as AnyTech365 declares that it has adopted all the necessary and relevant security measures as established in the Spanish Royal Decree 1720/2007 of 21st December, by which the Regulatory Decree implementing the LOPD [Ley Orgánica de Protección de Datos - Spanish Personal Data Protection Act] was approved, and that it has established all technical methods within its means to avoid the loss, wrongful use, alteration, non-authorized access or theft of the data you may supply.

All the contents of the website, and in particular trade names, business names, industrial designs, designs, texts, photographs, graphics, logos, icons, software and any other signs that may be used in industry and business, are protected by the industrial property and intellectual rights of Anteco Systems trading as AnyTech365. Their use and/or reproduction are therefore prohibited without the express consent of the company.

Anteco Systems trading as AnyTech365 will not be responsible for infringements of intellectual property or industrial rights of third parties originating from the inclusion in the website of trade marks, business names, industrial designs, patents, contents of the website in a conscientious, correct and legal manner and undertakes: a) Not to use the contents for objectives or purposes contrary to the law, to public morals and to normal customs or public order. b) Not to reproduce, copy, distribute, allow public access by whatever means of public communication, transform or modify the contents, unless the corresponding authorization from the title owner thereof has been given. c) Not to use the contents of the website to send publicity, communications for purposes of direct sales or for any other commercial purpose, unsolicited messages sent to a multitude of people regardless of its purpose, and to abstain from marketing or divulging such information in any way.

In the event of any kind of dispute, both parties will try to come to a friendly agreement. If this is not possible the Courts of Málaga will have jurisdiction to deal with the case and the parties will not have recourse to any other jurisdiction for the purposes of legal action.

USERS WHO DO NOT AGREE WITH THIS POLICY MUST NOT INTRODUCE ANY DATA THROUGH THIS WEB SITE OR ACCESS THE CONTENT OF THIS SITE.

European Law

Data protection

The right to protection of personal data is a fundamental right. It is different from, but closely linked to, the right to respect for private and family life. This distinction is notably made in the EU Charter of Fundamental Rights - which mentions the two rights separately, although next to each other in Articles 7 and 8.

Data protection is highly developed in the EU. The central piece of legislation is Directive 95/46/EC , which regulates the protection of individuals with regard to the processing of personal data and the free movement of such data. Implemented into national laws, the Directive applies to all EU Member States as well as to Iceland, Liechtenstein and Norway.

Regulation (EC) No 45/2001 lays down the same rights and obligations, but on the level of the EU institutions and bodies. It also establishes the EDPS as independent supervisory authority with the task of ensuring that the Regulation is complied with.

Privacy Policy

This legal text gives you details of how we collect and process your personal data through the use of our website www.anytech365.com, including any information that you can provide us through the site when you sign up for a service, register with us newsletter or provide your contact information through the form enabled for this purpose.

By providing us with the information, we inform you that our services are only directed to adults, so it guarantees that you are over 18 years of age when you send us the form.

1. Data controller.

Company name: Anteco Systems S.L. (ANYTECH365)

Corporate tax I.D.: B93311710

Registered Office: Road Nacional 340, km 189, Building Los Pinos núm. 3. Málaga, Marbella. ZIP code 29.660

Phone: 951390913

Email: info@anytech365.com

Registry data: Commercial Register Malaga, Volume 5248, Folio 1, Page MA-122108

Anteco Systems S.L. (ANYTECH365), is the controller of your data.

What data do we collect?

The General Data Protection Regulation, tells us that personal data is all information about an identified or identifiable natural person, that is, all the information capable of identifying a person. This would not include anonymous or percentage data.

On our website we can process certain types of personal data, which may include:

• Identity data: name and surname
• Contact information: email and telephone
• Technical data: login data, Internet protocol addresses, browser type and version, configuration and location of the time zone, operating system, types and versions of browser plug-in, and any other technology on the devices that you use to access our website
• Marketing and communications data: preferences to receive marketing communications from our side and preferred means of communication

We do not collect any data related to special categories of personal data (those that reveal their ethnic or racial origin, political opinions, religious or philosophical convictions, union affiliation and information about their health, genetic or biometric data).

In case you are requested to collect personal data by law or according to the terms of contract between us and you refuse to provide them, we may not be able to make such a contract or provide the service, and you must notify us about this in advance.

2. How we collect your personal information?

The means we use to collect personal data are:

Through the form on our website, through our contact emails or by phone, when:

• You request information about our services
• You contract the provision of our services
• You request quotes

Through technology or automated interactions: on our site we can automatically collect technical data about your equipment, navigation actions and usage patterns. This data is collected through cookies or similar technologies. If you want to expand the information, you can consult our cookies policy

Through third parties:

• Google: analytical data or search data. Outside the European Union.
• Social Networks: (Facebook, Instagram, Twitter, Linkedin…) outside the European Union.

3. Purpose and legitimacy for the use of your data.

The most common uses of your personal data are:

- For the formalization of a contract between Anteco Systems S.L (ANYTECH365) and you.

- When you give your consent in the processing of your data

- When we need them to comply with a legal or regulatory obligation

- When necessary for our legitimate interest

The User may revoke the consent given at any time by sending an email to info@anytech365.com or consulting the section of exercise of rights below.

Below we attach a table in which you can consult the ways in which we will use your personal data and the legitimacy for its use, as well as knowing what kind of personal data we are going to deal with. We can process some personal data for some additional legal reason, so if you need details about it you can send an email to info@anytech365.com

Commercial communications:you will only receive communications if

- You requested information or made a contract with us for a product or service

- If you provided us with your information, accepting the box enabled in this respect on our form

- As long as you have not indicated your willingness to stop receiving such communications

We obtain your express consent before sending any communication, being able to request at any time that we stop sending you communications in the email info@anytech365.com

When you choose to stop receiving our communications, your personal data will remain stored as a result of the contract made by you to comply with legal requirements.

Purpose: We will only use your data for the purposes for which we collect it, unless we reasonably believe that we must use it for another reason, notifying you in advance so that you are informed of the legal reason for processing it and provided the purpose is compatible with the original purpose.

Conservation period:They will be kept for the time necessary to fulfill the purpose for which they were collected and to determine the possible responsibilities that may arise from said purpose and the treatment of the data. The provisions of the files and documentation regulations will apply.

Subscriber data by e-mail or form:From the moment the user subscribes until they unsubscribe.

4. Your Rights in Data Protection

How to exercise these rights? Users can send a communication to the registered office of Anteco Systems S.L. (ANYTECH365) or email address info@anytech365.com, including in both cases photocopy of your ID card or other similar identification document, to request the exercise of the following rights:

-Access to your personal data: you can ask Anteco Systems S.L. (ANYTECH365) if you it is using your personal data.

- To request rectification, if they were not correct, or to exercise the right to be forgotten with respect to them.

- To request the limitation of the treatment, in this case, they will only be conserved by Anteco Systems S.L. (ANYTECH365) for the exercise or defense of claims

- To oppose your treatment: Anteco Systems S.L. (ANYTECH365) will let you process the data in the way you indicate, except that for legitimate reasons or for the exercise or defense of possible claims, these should continue to be treated.

- To the portability of the data: in case you want your data to be processed by another firm, Anteco Systems S.L. (ANYTECH365), will facilitate the portability of your data to the new manager.

You can use the models placed at your disposal by the Information Commissioner's Office, to exercise your previous rights: Here

Claim before the Information Commissioner's Office: if you consider that there is a problem with the way in which Anteco Systems S.L. (ANYTECH365) is processing your data, you can direct your claims to the corresponding control authority, being in the UK, the competent for it: The Information Commissioner's Office.

We may have to request specific information to help us confirm your identity and guarantee your right to access your personal data (or exercise any of the other rights mentioned above). This is a security measure to ensure that personal information is not disclosed to any person who does not have the right to receive it.

All the requests are solved within the legal term indicated 1 month. However, it can take more than a month if your request is particularly complex, or if you have already performed a series of actions previously. In this case, we will notify you and keep you updated.

5. Transfer of personal data

It is possible that, in the performance of our work, we need the help of third parties, who will only process the data to provide the contracted service, and with whom we have the corresponding measures to guarantee their rights:

- Providers of services that provide systems administration and information technology services.

- Professional advisors that include lawyers, auditors and insurers that provide banking, legal, insurance and accounting consulting services.

All those in charge of treatment to whom we transfer your data will respect the security of your personal data and will treat them according to the GDPR. We only allow such managers to process your data for certain purposes and in accordance with our instructions. However you can ask us, in compliance with the transparency, a list of who are these companies that provide us services, you can do it to the email: info@anytech365.com

6. Data Security

We have implemented the appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized manner, modified or disclosed. In addition, we limit the access to your personal data to those employees, contractors and other third parties who have a commercial need to know such data. They will only process your personal data according to our instructions and will be subject to a duty of confidentiality.

We have implemented procedures to deal with any suspicion of violation of your personal data and will notify you and the Control Authority in case it occurs, as regulated in the GDPR in its articles 33 and 34, a security breach.

7. International transfers

Countries outside the European Economic Area (EEA) do not always offer the same levels of protection for their personal data, which is why European legislation has prohibited the transfer of personal data outside the EEA unless the transfer meets certain requirements.

Some of our external service providers are outside the European Economic Area (EEA), so the processing of your personal data will involve a transfer of data outside the EEA.

- Social networks: Anteco Systems S.L. (ANYTECH365) makes use of the social network Facebook, Instagram, Twitter, Linkedin…) in the U.S.A.

- For remote connections we work with TeamViewer, in the U.S.A.

If you need an extension with regard to the specific mechanism used by us when transferring your data outside the EEA, you can contact us through our email info@anytech365.com

Update: May 2018

AnyTech365 provides a 100% money back guarantee if, at any time during the first 30 days after purchasing the AnyTech365 products and services, you are not satisfied with the products or are unwilling to continue conducting business with AnyTech365.

The 30 day refund period begins from the immediate Date of Purchase. Please note that any License Keys provided will be deactivated upon completion of the refund process.

Dear Colleague:

AnyTech365 is the leading European IT support service for private consumers and businesses; a rapid-growth success story based on the huge demand for an easy and convenient way to get PC and Internet help in your language - from nativespeaking, friendly IT experts.

Since our inception, we have recognised that you, our employees and partners, are absolutely vital to our continued success. Our reputation for providing trustworthy technical support with an unrivalled customer experience is the direct result of both our continued collaboration and our individual efforts.

We are all responsible for maintaining and nurturing our reputation; our foundation of trust and respect. How we treat each other, how we treat our customers, and how we conduct business will determine if our reputation is that of trustworthy, experienced, and helpful professionals.

Each and every one of us in the AnyTech365 family must be personally accountable for acting with integrity every day - in compliance with ethical conduct as well as with laws and regulations.

As we continue to grow, the AnyTech365 Code of Conduct sets out our agreed standards which we see reflected in every single AnyTech365 interaction, business activity, workplace, and event. We are committed to acting honestly, ethically, and in complete compliance with not only the letter but also the spirit of the law. It is critical to our continued success, and the only way to operate.

With your help, I am confident that AnyTech365 will continue deserving our reputation for acting with integrity every day as we expand to support more people around the world.

Thank you for joining me in this effort!

Warm regards,

Janus R. Nielsen Founder and Chief Executive Officer, AnyTech365

The AnyTech365 Mission

To provide the most friendly, helpful and cost-effective remote technical support service in the world.

We strive towards achieving our mission by acting with integrity every day - in line with these core values:

Attitude

Our attitude to each other, to our work, and to our customers is vital to the successful completion of our mission. Having the right attitude is especially important when we support and resolve high-concern or stressful problems for a customer, and towards achieving our goals. We remain positive and professional with a “can-do” attitude in each and every AnyTech365 interaction.

Commitment

We are committed to the company and our mission, and to our customers. We strive to make a positive difference every single day. We are committed to always help and support each other; to give our complete effort to our duties; to always aim high and try to surpass our goals; to follow through every issue to resolution; and to remain professional and act with integrity at all times.

Team Work

Our strength lays in our diversity and in our collective knowledge, experience, and skills. We are always here for each other, ready to help – by supporting and encouraging each other; by sharing our ideas, time and knowledge; by listening carefully and speaking up thoughtfully; and by always working with integrity together to provide the best service to our customers.

Performance

We are a company with many employees and many customers, and as such we have a duty to ourselves and each other to always give 100% performance with 100% integrity. We work every day to ensure our individual performance supports the company, our mission, and our customers, and do everything we can to encourage and support the best performance in each other.

We believe with the right attitude and commitment to your work, to your colleagues and being a team player, and to the company and our mission - your performance and the future success of AnyTech365 will be outstanding.

About the Code of Conduct

We are all representatives of AnyTech35; as such, we are all empowered to make decisions and take action for ourselves that affect the company reputation.

Every AnyTech365 family member, throughout the course of his or her working day, is actively shaping how the world views our company and services. We must each take personal responsibility for the AnyTech365 mission and act ethically and with integrity at all times.

The AnyTech365 Code of Conduct details who we are, what we do, how we act, how we do business, and how we expect anyone involved with the company to act. The Code is your guide to ensure all daily work and interactions are in line with the highest legal and ethical standards.

If you are ever unsure of how to act in any situation, you have plenty of support available to you: Speak with your supervisor, manager, or personnel from HR or Compliance about any concerns you may have.

Please read the Code of Conduct carefully. If you have any questions, see the “Asking for Advice and Expressing Concerns” section of this booklet.

Contact hr@anytech365.com for more information.

Violations of the Code may result in disciplinary action up to and including termination of employment and legal action.

Asking for Advice and Expressing Concerns

AnyTech365 requires that all employees and partners operate in full compliance with the law and always conduct themselves ethically.

If you feel that the standards laid out in the Anytech365 Code of Conduct have not been adhered to, if you have any questions, or if you need further information or access to additional policies, it is your duty and responsibility to ask for guidance or voice your concerns by speaking with:

• Your direct supervisor or manager
• Any HR representative
• Eric Bertin, Chief Operations Director
• Georgi Medzhidiliev, Chief Compliance Officer

Your concerns will be taken seriously and all information provided will be treated as confidential and appropriately investigated.

Anti-Retaliation Policy

AnyTech365 strictly prohibits any victimisation of or retaliation against any employee who asks questions or expresses concerns about any potential violation of the Code of Conduct that he or she believes reasonably to have occurred.

Integrity in the Workplace

How we treat each other

Acting with integrity every day begins with how we treat each other - from the first interaction in the hiring process, through to daily life in the workplace, and beyond; we treat one another with respect, dignity, and courtesy at all times. All employees are entitled to work free from discrimination, bullying, and harassment.

AnyTech365 is an equal opportunities employer, and as such we recruit and promote staff based on job-related criteria only.

The guidelines here apply to all employees and partners, including C-level executives and officers; managers and supervisors; full-time, part-time, casual, temporary, or permanent staff; job candidates; student placements, apprentices, contractors, sub-contractors, and volunteers.

Discrimination

AnyTech365 is committed to providing a safe, respectful, and flexible work environment, free from all kinds of discrimination.

Harassment, bullying and discrimination take many forms, including:

• Unwelcome comments, gestures, or physical contact
• Displaying or circulation of offensive, derogatory, graphic or sexually explicit pictures or other materials, including via email, any other messaging service, or online
• Offensive or derogatory jokes or remarks (either explicit or implicit/by innuendo)

Discrimination is treating, or proposing to treat, someone unfavourably because of a personal or legally protected characteristic, such as:

• Any disability, disease or injury, including work-related injury
• Race, colour, descent, national origin, or ethnic background
• Age, whether young or old or because of age in general
• Physical attributes
• Biological gender
• Sexual orientation or gender identity
• Marital status, whether married, divorced, unmarried or in a samesex relationship
• Being pregnant or breastfeeding
• Religious beliefs
• Political opinion
• Social standing or origin
• Medical background

Sexual Harassment

Sexual harassment is considered to be “in the workplace” when it happens on company premises, at work-related events, between people sharing the same workplace, or between colleagues outside of work.

A single incident is enough to constitute sexual harassment - it doesn’t have to be repeated.

Any report of sexual harassment – no matter how large or small, or who is involved – requires an appropriate and confidential response and immediate investigation.

Sexual harassment can include:

• Comments about a person’s private life or the way they look
• Sexually suggestive comments or jokes
• Intrusive questions or statements about a person’s private life
• Insults or taunts of a sexual nature
• Repeated unwanted requests to go out
• Requests for sexual intercourse, intimacy, or acts
• Sexually suggestive behaviour, such as leering or staring
• Unwanted physical contact
• Sending sexually explicit emails, SMS, MMS, or other messages
• Displaying offensive screensavers, photos, calendars or objects
• Inappropriate advances on social networking sites
• Accessing sexually explicit internet sites
• Behaviour that may also be considered to be an offence under criminal law, such as physical assault, indecent exposure, sexual assault, stalking or obscene communications.

AnyTech365 strongly encourages any staff member who believes they have been discriminated against, bullied, sexually harassed, or victimised to take immediate action by contacting the supervisor, manager or HR representative with whom they feel most comfortable speaking with.

How our supervisors treat team-members

From our team-leaders all the way up to our C-level officers and executives at AnyTech365, we understand that the words, actions, attitude, and approach of anyone in a supervisory position must be aligned with the Code of Conduct at all times in order to preserve and grow the positive, professional culture of integrity that we demand.

As a Supervisor, Team-Leader, Manager, Director, C-level officer or executive, you must:

• Ensure that your team know and understand their responsibilities under the Code and other Company policies
• Model the Code at all times, especially during appraisals, team meetings, and any required disciplinary actions - we cannot reinforce the importance of ethics and compliance with the Code to our employees if we ourselves are not compliant, ethical, and acting with integrity
• Conduct in private any meeting necessary to deliver constructive criticism, feedback, disciplinary action, or in any situation with the potential to escalate or potentially embarrass any partner
• Ensure employees feel comfortable raising concerns without fear of retaliation – treat any concerns seriously and with confidentiality
• Consider conduct in relation to the Code and other Company policies when evaluating any employee
• Never encourage or direct employees to achieve business results at the expense of ethical conduct or compliance with the Code or the law
• Always be vigilant and act to stop any violations of the Code
• Take any question or concern related to the Code seriously and act upon it accordingly, and in the quickest possible time - listen carefully and give the employee and the matter your complete attention

Failure to act professionally, even in times of high stress or increased workload, is a failure in your role as a supervisor and can lead to disciplinary action, relief from the position, or termination of employment.

How we treat our customers

Our customers deserve exceptional service delivered with integrity. The AnyTech365 mission is to be the friendliest, most helpful and professional technical support provider available - how we treat customers is pivotal to our continued success.

The core of who we are is simple: we are people helping people, and as such, customer service and satisfaction are top priorities for us. We must consistently act ethically, be professional and polite, and fulfil the needs of each customer in every single interaction.

Specifically, you must:

• Treat every customer with dignity, respect, and courtesy
• Always act with integrity and in line with the Code
• Always present AnyTech365’s (and affiliates’) products and services in an honest and forthright manner to customers and potential customers
• Never offer, promise, or provide any product or service to a customer which does not fulfil a specific need
• Never engage in unfair, deceptive, or misleading practices
• Never harass or discriminate against our customers or potential customers in any way

Alcohol, Drugs, and Substance Abuse

AnyTech365 has strict standards regarding alcohol, illegal drugs, and substance abuse. AnyTech365 takes these rules very seriously. It is essential that you understand and follow them carefully.

The following policy applies to all AnyTech365 employees and partners of all levels, and will be strictly enforced:

• Employees are not permitted to use or possess any alcoholic beverages on company property, except where alcohol is specifically permitted at an AnyTech365 social event
• You also may not use or possess illegal drugs or controlled substances on AnyTech365 premises or while you are engaged in any job-related activity
• You may not report for work while under the influence of alcohol, drugs, or controlled substances
• Any employee or partner who can be reasonably deemed as unfit for work due to alcohol, illegal drugs, or substance abuse will be sent home immediately
• All matters concerning alcohol, drugs, or substance abuse will be treated with the utmost confidentiality
• AnyTech365 will report to the Police immediately any person in possession of or attempting to supply illegal drugs on company premises

In addition, if you are taking any kind of pharmaceutical drug or medication, prescribed or otherwise, you must:

• Ensure that you are familiar with the potential side-effects listed in the informational insert supplied with the medication
• Advise your line manager of any potential side-effects of any medication that you are taking that may affect your work performance, or the health and safety of yourself, your colleagues, company property, or any other individuals or property

AnyTech365 is committed to supporting any employee or partner who comes forward to ask for help with substance abuse. If you admit to your supervisor that you have a problem with any kind of substance abuse, AnyTech365 will work to help you with finding appropriate treatment. All such matters will be treated with the utmost confidentiality.

Integrity in Business

Legal and Regulatory Compliance

AnyTech365 is 100% committed to acting with integrity in business every day: we operate in full compliance with all applicable laws, regulations, and rules.

You are required to comply with the Code and all applicable laws, regulations, and rules when performing your duties for the company.

If you have reason to believe that there is a discrepancy between the Code of Conduct and any applicable law, regulation, or rule, or unsure or concerned about the legality of your own conduct, or the conduct of any other AnyTech365 employee or partner, speak with your supervisor or manager immediately.

Marketing and Sales Practices

The success of AnyTech365 is based on the merits of our products and services – we sell and market truthfully and accurately. This must be apparent at all times in any communications with customers or potential customers. We must be able to prove any claims we make about our products or services. We sell the truthful quality of our products and services; we do not misrepresent ourselves, disparage our competitors, or use our technical knowledge (or our customers’ lack thereof) to sell products or services based on fear or negativity of any kind.

You must not in any way suggest, imply, claim, or state, neither directly nor indirectly, that the company is recommended by, associated with, partners with, working for, endorsed by, or is itself Microsoft, Apple, or any other recognised and trusted IT companies.

If you are personally one of our Support Technicians who are genuinely Microsoft Certified, you may mention, if and where appropriate, that fact about yourself. You must not suggest, state, or claim that certification or association is with AnyTech365 directly, or that AnyTech365 itself is Certified in that way.

Competition Law

AnyTech365 promotes and supports open competition in a free market; it is not only fair and ethical, but it is also in our best interests to do so. All

AnyTech365 business decisions must be made independently, free from any supplier or competitor arrangements or understandings that restrict competition.

When involved in AnyTech365 business, all employees and partners must:

• Not discuss internal pricing, practices, or business / marketing strategies with competitors
• Always present AnyTech365 services and products in a manner consistent with the Code
• Not induce a third party to breach an existing agreement
• Never attempt to exclude present or potential competitors or to control market prices, or conduct yourself in a manner which could be perceived as such

Competitive Intelligence Gathering

Understanding of our competitors is essential for us to provide the best service to and value for our customers, and to ensure our continued success. When we act with integrity and follow the Code to obtain it ethically, such information is an extremely useful asset.

Employees are encouraged to collect, share and use information about our competitors only in a legal and ethical manner. We respect the non-public information of others, just as we do our own.

It is acceptable to collect competitive intelligence through publicly available information or ethical inquiries. For example, you may gather and use information about our competitors from public sources, such as:

• Published pricing and product features on their official websites
• News, trade journal articles, and publications about them

Conflicts of Interest

Each employee and partner of AnyTech365 must take steps to avoid conflicts of interest and the appearance of conflicts of interest. A conflict of interest, or the appearance of one, can arise when your personal interests or activities interfere with the duties performed at or owed to AnyTech365.

The appearance of a conflict of interest can potentially cause conflict or concern, or integrity to be questioned – even in the most ethically-minded and well-respected individuals could be unconsciously influenced by a conflict of interest.

Any actual or potential conflict of interest must be immediately brought to the attention of your direct supervisor or manager.

Some examples of situations where a conflict of interest could potentially arise:

• Working for or operating a business, including a consultancy firm, that does or wishes to do business with AnyTech365 or that competes with AnyTech365 (for example, working for a competitor’s technical support company)
• Making a significant direct investment in any such business (either by you directly, or by a member of your immediate family)v
• Acting on behalf of any party other than AnyTech365 in any transaction involving AnyTech365 (for example, attempting to sell products or services to AnyTech365, or helping someone to)
• Getting personally involved in any interactions in which AnyTech365 has an interest

In any potential conflict of interest situation, ask yourself:

• Could my personal interests interfere with those of AnyTech365?
• Might it appear that way to others, either inside or outside of the company?

If you are unsure or would like guidance, please speak with your supervisor or manager.

Company Assets

We strive to create and maintain the ideal working environment to enable you to fulfil your duties in the most efficient and productive way. We all have a responsibility to protect company assets and use all assets in the manner intended.

All company assets are provided for use in your role and duties and for the benefit of AnyTech365. You must not use any company assets for your own personal benefit, or for the benefit of any other party other than AnyTech365.

AnyTech365 are committed to supporting a healthy and appropriate worklife balance, and as such, personal phone calls, emails, or messaging during company time or using company assets are acceptable within reason. Frequent or excessive personal communications or activities are strictly prohibited.

You may not use company assets:

• To engage in any personal activities during work hours which interfere with or prevent you from fulfilling the duties of your role
• To benefit yourself or any third-party (see “Conflicts of Interest” section in this booklet for more information)
• For any illegal or unethical activities, or other activities not compliant with the Code (for example gambling, creation or dissemination of pornographic or other offensive or disturbing materials)

Privacy

AnyTech365 respects the right to privacy of all employees, partners, and customers. We must handle personal data responsibly and in compliance with all applicable privacy laws, regulations, and rules. Employees who handle the personal data of others must:

• Act in accordance with applicable national, EU, and international law
• Act in accordance with any relevant contractual obligations
• Collect, use and process such information only for legitimate business purposes
• Limit access to the information to those who have a legitimate business purpose for seeing the information
• Take care to prevent unauthorized disclosure

Integrity of Information and Intellectual Property

Confidential Information

While fulfilling your duties at AnyTech365, you will naturally gain some nonpublic knowledge that is the property of AnyTech365. We trust and expect that all employees and partners maintain the confidentiality of this valuable information.

Confidential information includes things such as contracts, supplier or partner information, business strategy, marketing plans, management changes, existing and future product launches, Personally Identifiable Information (PII) of employees or partners, scripts, internal technical or operational details, financial data, and product costs.

It is prohibited to disclose AnyTech365 information to anyone outside of AnyTech365; it must only be used for company purposes. Within the company, confidential information must also only be accessible to employees and partners whose specific duties require access to said information. If you leave AnyTech365, you must return all company property, materials, and any copies.

Confidential materials must:

• Be maintained and stored securely at all times
• Not be left visible to non-authorised individuals
• Be plainly marked as confidential
• Not be sent to unattended printers or fax machines
• Not be discussed where non-authorised individuals might hear

Fairness and equality are important to AnyTech365 – we must also act with integrity with regards to the confidential information and materials of others and respect their confidentiality at all times.

Here are some basic guidelines:

• You must not bring any materials with you to AnyTech365 from any previous employer
• You must not make use of or receive the confidential information of others
• You must not attempt to obtain confidential information from another company’s present or former employees, partners, or suppliers.
• Do not engage in espionage; be ethical, transparent, and compliant with the law when obtaining information about competitors or the marketplace

Intellectual Property

Any work product you create or develop, either totally or partially, through use of company information or resources, as part of your duties, or on company time – is the sole property of AnyTech365. This includes ideas, improvements, software programs, artwork, inventions, discoveries, and works of authorship.

Any such work product that is a result of your work efforts must be disclosed to AnyTech365 in writing, and you must cooperate with AnyTech365 in order to secure the correct legal protection of the product for the company.

When contracting any work from a third party, you are required to secure the appropriate written agreement or release before any such work begins to ensure that AnyTech365 receives the legal benefit of and protection for any work.

Be sure to follow any and all applicable rules regarding the use of the work product of others. For example, you must only use software for which we have a valid license and must only use that software in accordance with the license terms for that software. Written materials, artwork, photographs, images, and music may be subject to copyright protection and should be used only if and when permitted. Note that some copyrighted material does not clearly display the copyright symbol – be sure to confirm legal right to use anything before you use it.

Company Records

You must manage information in such a way that supports business needs while ensuring efficiency, security, and full compliance with any applicable laws, regulations, or rules. This policy applies to records maintained in all forms at AnyTech365, including both electronic and paper.

• Records must always be prepared accurately and reliably, and stored properly in accordance with company policy
• All required transactions and events must be accurately and fairly recorded
• AnyTech365 strictly prohibits any unrecorded company funds, assets, or other types of “off the books” accounts, regardless of any perceived reason for such accounts
• It is forbidden to knowingly destroy or discard any information that is subject to a legal hold

Integrity in the Community

Social Media and Online Communities

The majority of our business is conducted online, and as such, our online communities are of vital importance for our reputation, for our continued service to customers, and for our successes as a company.

For the purpose of this policy, we define “social media” as any social networking sites, blogs, wikis, microblogs, message boards, chat rooms, electronic newsletters, online forums, and any other sites and services that permit users to share information or materials with others in a contemporaneous manner.

The social media policy applies equally to the business use of social media on behalf of AnyTech365 conducted by authorised personnel, to personal use of social media by any employee or partner in reference to AnyTech365, or in relation to any AnyTech365 websites or accounts.

You must:

• Always act with integrity and follow the Code when using social media in reference to or on behalf of AnyTech365
• Never publish, post, or release in any form any non-public or confidential information
• Immediately notify your line manager in the event that AnyTech365 receives media attention or legal questions via social media, without responding directly
• Be aware of the effect your actions may have on your own, as well as AnyTech365’s, reputation
• Never post material that is either inappropriate or harmful to AnyTech365, our employees, or our customers
• Disengage politely from any dialogue that threatens to become antagonistic while using social media (involving AnyTech365, our partners, customers, or any employee) and seek the advice of your manager
• Ensure you have the appropriate permissions before referring to or posting images of current or former employees, partners, vendors or suppliers
• Ensure you obtain appropriate permission to use a third party’s copyrights, copyrighted material, trademarks, service marks or other intellectual property
• Never neglect your duties and responsibilities to use social media
• Never use social media for any personal blogging or content sharing using company assets, and never during working hours
• If authorised and related to your duties, only use social media for the benefit of the company, in line with our mission and the Code

Subject to applicable law, an after‐hours online activity that violates the AnyTech365 Code of Conduct or any other company policy may lead to disciplinary action up to and including dismissal

Personal Activities

AnyTech365 encourage employees and partners to be involved in their communities and understand the importance of balance between work, personal, and family lives. However, you must not impose your personal opinions or beliefs on others, or represent your personal views as those of AnyTech365.

While you are entitled to keep your personal activities outside of the workplace confidential, you must always keep in mind that you are a representative of AnyTech365. Your behaviour can positively or negatively affect our reputation and ability to complete our mission.

Political Activities

AnyTech365 strictly prohibits any political activities while on company time, premises, or using company resources. Do not promote any political views or beliefs by any means, including distribution or posting notices or other materials around AnyTech365 premises or online. Outside of the workplace, you must not suggest or indicate that AnyTech365 supports your views, or that you speak on behalf of the company.

Public Relations

Acting with integrity is the correct way to do business, and all public relations situations allow us to present our integrity and professionalism. It is vital that all information regarding the company must be accurate, consistent, and complete, and propagated in accordance with the Code and all other AnyTech365 policies.

If someone asks you for information or comment (for example, a journalist or potential investor), immediately notify your line manager about the request. Do not attempt to answer these questions yourself –the appropriate person will supply the requested information directly to the inquirer in line with correct procedures.

Administration of the Code

The responsibility for administering the Code rests with Janus Nielsen (Chief Executive Officer), with oversight by Juan Salazar (General Manager), George Medzhidiliev (Chief Compliance Officer), and the management team.

Decision Making

The management team will make all decisions regarding any perceived or actual Code violations and any necessary disciplinary action. Decisions which fall into certain categories may be delegated to others as necessary.

Disciplinary Action

If an employee or partner is found to be in violation of the Code, full notation of the details and circumstances, the final decision, and a copy of any letter of reprimand will be placed in employee’s permanent record.

Immediate Termination Offences

While any violation of the Code should be avoided, and many infractions can involve termination of employment, the following actions of misconduct will result in immediate termination of employment, and prosecution to the full extent of the law where applicable:

• Claiming that AnyTech365 is recommended by, associated with, partners with, is endorsed by, or is itself Microsoft, Apple or any other well-known IT company in order to mislead the consumer and gain selling advantage
• Theft or unlawful access of customer payment card/bank details
• Theft of unlawful access of Personally Identifiable Information (PII) from company records

Acknowledgement

All new and existing employees and contracted staff must by personally signed declaration acknowledge their receipt of, and agreement to abide by, the AnyTech365 Code of Conduct.

Failure to read the Code or sign the acknowledgement form does not disqualify an employee or partner from compliance with the Code.

1. WHAT ARE COOKIES?

Anteco Systems S.L. (ANYTECH365) is responsible for the website www.anytech365.com, and uses cookies and/or other files of similar functionality (hereinafter "Cookies").

Cookies are small data files that are sent to the user's computer, mobile phone or other access device when you visit a web page and that allow you to obtain information related to your browsing or a code that allows you to uniquely identify the user.

2. TYPE OF COOKIES AND PURPOSES OF USE

The website www.anytech365.com uses session cookies and/or persistent cookies that, in turn, can be your own and/or third party cookies.

Session Cookies are cookies designed to collect and store data while the user accesses a web page. They are usually used to store information that only interests to keep for the provision of the service requested by the user in a single occasion.

Persistent cookies are a type of cookies in which the data is still stored in the terminal and which can be accessed and processed during a period defined by the person responsible for the cookie, which can range from a few minutes to several years.

Own cookies: Those created or managed by the person in charge of the website Anteco Systems S.L. (ANYTECH365). The website www.anytech365.com, uses own cookies with the following purposes:

• Techniques: allow the user to navigate the use of different options or services that exist in it, for example, control traffic and data communication, identify the session, access restricted access parts, use security elements during navigation, store contents.
• Personalization: they allow the user to access the service with some predefined general characteristics based on a series of criteria in the user's terminal, such as remembering video playback preferences.

Third party cookies: Those administrated by service providers outside Anteco Systems S.L. (ANYTECH365).

Below are given the third parties who can configure and access Cookies of their team, as well as the purposes for which the information they store:

3. DEACTIVATION OR ELIMINATION OF COOKIES

Most web browsers allow you to manage, at any time, the user's preferences regarding the use of Cookies. The user can adjust their browser to reject Cookies or remove certain cookies at their discretion

For the configuration of Cookies the user can access:

• Google Chrome
• Mozilla Firefox
• Internet Explorer
• Microsoft Edge
• Safari
• Opera 19

The user can revoke their consent to the use of Cookies in their browser through the above indications or through the installation of a rejection system ("opt-out") in their web browser.

In the case of Google Analytics Cookies, the opt-out can be done through the this link.

The user must bear in mind that some features of the contents of the Website www.anytech365.com are only available if the installation of cookies in your browser is allowed. If you decide not to accept or block certain Cookies (depending on their purpose), this may affect, in whole or in part, the normal operation of the Website or prevent access to some services of the same.

4. UPDATES AND CHANGES IN THE COOKIES POLICY

Anteco Systems S.L. (ANYTECH365) can modify this Cookies Policy based on new legislative or regulatory requirements, or with the purpose of adapting this policy to the instructions issued by The Information Commissioner's Office.

If you want more information about what use we make of Cookies, you can send us an e-mail to info@anytech365.com

1. Legal information and acceptance

In compliance with article 10 of Law 34/2002, of 11h of July, on Services of the Information Society and Electronic Commerce, the identification data of the company are presented below. The present Internet portal is put at the service of users by the entity, whose identifying data are

Company name: Anteco Systems S.L. (ANYTECH365)
Corporate tax I.D.: B93311710
Registered Office: Road Nacional 340, km 189, Building Los Pinos núm. 3. Málaga, Marbella. ZIP code 29.660
Phone: 951390913
E-mail: info@anytech365.com
Registry data: Commercial Register Malaga, Volume 5248, Folio 1, Page MA-122108

Anteco Systems S.L. (ANYTECH365) is an entity adhering to Online Confidence, thereby guaranteeing the maximum transparency, security and confidence in navigation throughout its Website. Anteco Systems S.L. (ANYTECH365) complies with all the standards included in the Online Trust Code of Ethics. You can view the seal and membership of Anteco Systems S.L. (ANYTECH365) by visiting Confianza Online.

This legal notice includes the general conditions governing the access to and use of this website, hereinafter "the website". The use of the website implies the express and full acceptance of these general conditions in the version published at the moment in which the user accesses it, without prejudice to the particular conditions that may apply to some of the specific services of the website.

Access to the website is free except for the cost of the connection through the telecommunications network provided by the access provider contracted by the users. Certain services are exclusive for our clients and their access is restricted.

The use of the Portal attributes the condition of user of the Portal (hereinafter, the 'User') and implies the acceptance of all the conditions included in this Legal Notice. The provision of the Portal service has a limited duration at the moment in which the User is connected to the Portal or to any of the services that are provided through it. Therefore, the User must carefully read this Legal Notice in each of the occasions in which may intend to use the Portal, since the same and its conditions of use contained in this Legal Notice may be modified.

Some Portal services accessible for Internet users or exclusive to clients of Anteco Systems S.L. (ANYTECH365), may be subject to particular conditions, regulations and instructions that, where appropriate, replace, complete and / or modify this Legal Notice and that must be accepted by the User before starting the provision of the corresponding service.

 

2. Intellectual and industrial property

This website and its contents are protected by current legislation on intellectual property.

Anteco Systems S.L. (ANYTECH365) is the owner or licensee of all intellectual and industrial property rights of its website, as well as the elements contained in it. Therefore, the reproduction, distribution, public communication and transformation of all or part of the contents of this website, for commercial purposes, in any support and by any technical means, without the authorization of Terms and Conditions, is expressly prohibited.

The brands, trade names or distinctive signs are the property of Anteco Systems S.L. (ANYTECH365) or third parties, without it being understood that access to the Portal attributes any right over the aforementioned trademarks, trade names and / or distinctive signs.

All products and services on these pages that are NOT owned by Anteco Systems S.L. (ANYTECH365) are registered trademarks of their respective owners and are recognized as such by our company. They only appear on the Anteco Systems S.L. (ANYTECH365) for the purposes of promotion and information. These owners can request the modification or elimination of the information that belongs to them.

 

3. Terms of use of the portal

3.1 General

The User is obliged to make correct use of the Portal in accordance with the Law and this Legal Notice. The User will respond to Anteco Systems S.L. (ANYTECH365) or against third parties, of any damages that may be caused as a result of breach of this obligation.

It is expressly forbidden to use the Portal for harmful purposes to goods or interests of Anteco Systems S.L. (ANYTECH365) or of third parties or that in any other way overload, damage or disable the networks, servers and other computer equipment (hardware) or computer products and applications (software) of Anteco Systems S.L. (ANYTECH365) or of third parties.

 

3.2 Contents

The User agrees to use the Contents in accordance with the Law and this Legal Notice, as well as with the other conditions, regulations and instructions that may be applicable in accordance with the provisions of clause 1.

With a merely enunciative character, the User in accordance with current legislation must refrain from:

• Reproducing, copying, distributing, making available, publicly communicating, transforming or modifying the Contents except in cases authorized by law or expressly consented by Anteco Systems S.L. (ANYTECH365) or by who holds the ownership of the exploitation rights in its case.
• Reproduce or copy for private use the Content that may be considered as Software or Database in accordance with current legislation on intellectual property, as well as its public communication or the one made available to third parties when these acts necessarily imply reproduction by part of the User or a third party.
• Extract and / or reuse all or a substantial part of the Contents of the Portal

3.3 Introduction of links to the Portal

The Internet user who wants to introduce links from their own web pages to the Portal must comply with the conditions that are detailed below and the ignorance of them are not avoiding the responsibilities derived from the Law:

The link will only link to the home page or main page of the Portal but will not be able to reproduce it in any way (online links, copy of the texts, graphics, etc).

In any case, it shall be prohibited, in accordance with the applicable legislation and in force at any time, to establish frames of any kind that involve the Portal or allow the display of the Contents through Internet addresses other than those of the Portal and, in Any case, when viewed together with contents outside the Portal so that: (I) produce, or may produce, error, confusion or deception in users about the true origin of the service or Content; (II) suppose an act of comparison or unfair imitation; (III) serves to take advantage of the reputation of the brand and prestige of Anteco Systems S.L. (ANYTECH365); or (IV) in any other way is prohibited by current legislation.

Any type of false, inaccurate or incorrect statement about Anteco Systems SL (ANYTECH365), its partners, employees, clients or about the quality of the services it provides will not be made from the page that introduces the link.

In no case, will be expressed on the page where the link is located in which Anteco Systems S.L. (ANYTECH365) has given its consent for the insertion of the link or that otherwise sponsors, collaborates, verifies or supervises the services of the sender.

It is forbidden the use of any word mark, graphic or mixed mark or any other distinctive sign of Anteco Systems S.L. (ANYTECH365) within the sender's page, except in the cases permitted by law or expressly authorized by ANTECO SYSTEMS, SL and provided that, in these cases, a direct link to the Portal is permitted in the manner established in this clause.

The page that establishes the link must faithfully comply with the law and can not in any case dispose of or link to its own content or that of third parties that: (I) are illegal, harmful or contrary to morality and good customs (pornographic, violent, racists, etc.); (II) induce or may induce in the User the false conception that Anteco Systems S.L. (ANYTECH365) subscribes, endorses, adheres or in any way supports the ideas, statements or expressions, legal or illegal, of the sender; (III) are inappropriate or not pertinent to the activity of Anteco Systems S.L. (ANYTECH365) in attention to the place, content and subject of the web page of the sender.

4. Exclusion of responsibility

4.1 About the information

Access to the Portal does not imply an obligation on the part of Anteco Systems S.L. (ANYTECH365) to verify the veracity, accuracy, adequacy, suitability, completeness and timeliness of the information provided through it. The contents of this page are of a general nature and do not constitute, in any way, the provision of a legal advice service or of any kind, reason why such information is insufficient for the personal or business decisions made by the User.

Anteco Systems S.L. (ANYTECH365) is not responsible for the decisions taken from the information provided in the Portal or the damages and losses caused in the User or third parties with reason for actions that have as sole foundation the information obtained in the Portal.

 

4.2 About the quality of the service

Access to the Portal does not imply an obligation on the part of Anteco Systems S.L. (ANYTECH365) to control the absence of viruses, worms or any other harmful computer element. It corresponds to the User, in any case, the availability of adequate tools for the detection and disinfection of harmful computer programs.

Anteco Systems S.L. (ANYTECH365) is not responsible for the damages produced in the computer equipment of the Users or third parties during the provision of the Portal service.

 

4.3 About the availability of the Service

Access to the Portal requires services and supplies from third parties, including transportation through telecommunications networks whose reliability, quality, continuity and functioning does not correspond to Anteco Systems S.L. (ANYTECH365). Therefore, the services provided through the Portal may be suspended, canceled or inaccessible, prior or simultaneous to the provision of the Portal service.

Anteco Systems S.L. (ANYTECH365) is not responsible for any damages or losses of any kind caused to the User that result in failures or disconnections in the telecommunications networks that produce the suspension, cancellation or interruption of the Portal service during the provision of the same or with previous character.

 

4.4 About the contents and services linked through the Portal

The access service to the Portal includes technical link devices, directories and even search tools that allow the User to access other Internet pages and portals (hereinafter, 'Linked Sites'). In these cases, Anteco Systems S.L. (ANYTECH365) acts as a provider of intermediation services in accordance with article 17 of Law 34/2002, of 12of July, on Services of the Information Society and Electronic Commerce and will only be responsible for the contents and services provided on the Linked Sites to the extent that you have effective knowledge of the unlawfulness and have not deactivated the link with due diligence. In the event that the User considers that there is a Linked Site with illicit or inappropriate content, he/she may inform Anteco Systems S.L. (ANYTECH365) in accordance with the procedure and the effects established in clause 6, without this communication entailing the obligation to withdraw the corresponding link.

In any case, the existence of Linked Sites must presuppose the existence of agreements with the managers or owners thereof, or the recommendation, promotion or Identification of Anteco Systems S.L. (ANYTECH365) with the manifestations, contents or services provided.

Anteco Systems S.L. (ANYTECH365) does not know the contents and services of the Linked Sites and therefore is not responsible for the damages caused by the illegality, quality, failure to update, unavailability, error and uselessness of the contents and/or services of the Linked Sites or by Any other damage that is not directly attributable to Anteco Systems SL (ANYTECH365).

 

5. Data Protection

You can consult our policy of Data Protection to know the use we make of your personal data.

 

6. Communication of illicit and inappropriate activities

In the event that the User or any other Internet user were aware that the Linked Sites refer to pages whose contents or services are illegal, harmful, degrading, violent or contrary to morality, they may contact Anteco Systems S.L. (ANYTECH365) indicating the following extremes:

• Personal data of the caller: name, address, telephone number and email address;
• Description of the facts that reveal the illicit or inadequate nature of the Linked Site;
• In the case of violation of rights, such as intellectual and industrial property, the personal data of the owner of the infringed right when he is a person other than the communicating party.
• He must also provide the title that proves the legitimacy of the rights holder and, where appropriate, the representation to act on behalf of the owner when it is a person other than the communicating party;
• Express declaration that the information contained in the claim is accurate.

The reception by Anteco Systems S.L. (ANYTECH365) of the communication provided in this clause will not imply, according to the provisions of Services of the Information Society and Electronic Commerce Law, the effective knowledge of the activities and/or contents indicated by the communicator.

He must also provide the title that proves the legitimacy of the owner of the rights and, where appropriate, the representation to act on behalf of the owner when the person is different from the communicating party; Express statement that the information contained in the claim is accurate.

 

7. Notifications

All notices and communications made by the parties will be valid in accordance with the means admitted by Law. Those related to this Portal will be considered effective, for all purposes, if they are made through the Portal itself.

 

8. Modifications

Anteco Systems S.L. (ANYTECH365) reserves the right to make any changes it deems appropriate on its website without prior notice, and may change, delete or add both the contents and services provided through it and the way in which they appear presented.

On the other hand, these terms and conditions may change at any time. The modifications will take effect from the moment of their publication.

 

9. Legislation

These general conditions are ruled by the Spanish Law. The parties submit, at their option, for the resolution of conflicts and renouncing any other jurisdiction, to the courts and tribunals of the user's domicile. Likewise, as an entity adhering to Online Confidence and in the terms of its Code of Ethics, in case of disputes related to online contracting and advertising, data protection and protection of minors, the user may resort to the system of extrajudicial resolution of Trust disputes. Online: www.confianzaonline.es

Resolution of online litigation in accordance with Art. 14.1 of Regulation (EU) 524/2013: The European Commission provides an online dispute resolution platform, which is available at the following link: https://ec.europa.eu/consumers/odr/.