WEB SITE PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Granfield Estate S.L. (hereinafter, also referred to as the Website) commits to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it adheres to the following laws:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).

Royal Decree 1720/2007, of 21 December, approving the Regulation developing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).

Law 34/2002, of 11 July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data

The controller of the personal data collected by Granfield Estate S.L. is: GRANFIELD ESTATE S.L., with Tax ID: B01967785 and registered in: Mercantile Registry of ALACANT/ALICANTE with the following registry information: Sheet A-171588 Volume 4326 Folio 83, whose representative is: Olga Urbas (hereinafter, Data Controller). Their contact details are as follows:

Address:

• Av. Bélgica 1, C.C. Parquemar, 03188, La Mata, Alicante
• Contact phone: +(34) 865 44 3333
• Contact email: info@granfield-estate.com

Data Protection Officer (DPO)

The Data Protection Officer (DPO) is in charge of ensuring compliance with the data protection regulations to which Granfield Estate S.L. is subject. The User can contact the appointed DPO using the following contact details: info@granfield-estate.com.

Registration of Personal Data

In compliance with the provisions of the GDPR and LOPD-GDD, we inform you that the personal data collected by Granfield Estate S.L., through forms spread on its pages, will be incorporated and processed in our files in order to facilitate, expedite and fulfill the commitments established between Granfield Estate S.L. and the User or the maintenance of the relationship established in the forms that he or she fills out, or to attend to a request or query from the same. Likewise, in accordance with the provisions of the GDPR and LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles contained in Article 5 of the GDPR and Article 4 and subsequent of Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights:

Principle of legality, loyalty and transparency: the consent of the User will be required at all times following completely transparent information on the purposes for which the personal data are collected.

Principle of limitation of purpose: personal data will be collected for specific, explicit, and legitimate purposes.

Principle of data minimization: the personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.

Principle of accuracy: personal data must be accurate and always up-to-date.

Principle of limitation of retention period: personal data will only be maintained in such a way as to allow the identification of the User for the time necessary for the purposes of their processing.

Principle of integrity and confidentiality: personal data will be treated in a way that guarantees their security and confidentiality.

Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed in Granfield Estate S.L. are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal Basis for the Processing of Personal Data

The legal basis for the processing of personal data is consent. Granfield Estate S.L. commits to obtaining the express and verifiable consent from the User for the processing of their personal data for one or several specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed in the event that the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the Processing for Which the Personal Data Are Intended

Personal data are collected and managed by Granfield Estate S.L. in order to facilitate, expedite, and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend to a request or query.

Additionally, the data may be used for a commercial purpose of customization, operational and statistical activities, and activities pertaining to the corporate purpose of Granfield Estate S.L., as well as for the extraction, data storage and marketing studies to adapt the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be destined; that is, the use or uses that will be given to the information collected.

Retention Periods for Personal Data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following term: 2 years, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

Recipients of Personal Data

The personal data of the User will be shared with the following recipients or categories of recipients:

• Granfield Estate S.L. Tax ID (CIF): B01967785
• Av. Belgium 1, C.C. Parquemar, 03188, La Mata, Torrevieja, Alicante

In case the Data Controller intends to transfer personal data to a third country or international organization, at the time the personal data is obtained, the User will be informed about the third country or international organization to which it is intended to transfer the data, as well as the existence or absence of an adequacy decision by the Commission.

Personal Data of Minors

In compliance with the provisions set forth in Articles 8 of the GDPR and 7 of the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only those over 14 years of age may give their consent for the lawful processing of their personal data by Granfield Estate S.L. If it concerns a minor under 14 years of age, the consent of the parents or guardians is required for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and Security of Personal Data

Granfield Estate S.L. commits to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent its accidental or unlawful destruction, loss or alteration, personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, because Granfield Estate S.L. cannot guarantee the impregnability of the internet nor the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to communicating to the User without undue delay when a breach of the security of personal data occurs that is likely to entail a high risk to the rights and freedoms of individuals. Following the provisions of Article 4 of the GDPR, a personal data security breach is any breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring by legal or contractual obligation that such confidentiality is respected by its employees, associates, and anyone to whom it makes the information accessible.

Rights Derived from the Processing of Personal Data

The User has the following rights recognized by the GDPR and the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, over Granfield Estate S.L. and may, therefore, exercise the following rights in front of the Data Controller:

Right of access: It is the User's right to obtain confirmation on whether Granfield Estate S.L. is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Granfield Estate S.L. has carried out or is carrying out, as well as, among other things, the available information on the origin of those data and the recipients of the communications made or planned.

Right to rectification: It is the User's right to have their personal data corrected if it is inaccurate or, considering the purposes of the processing, incomplete.

Right to erasure ("right to be forgotten"): It is the User's right, as long as current legislation does not establish otherwise, to have their personal data erased when it is no longer necessary for the purposes for which it was collected or processed; if the User has withdrawn their consent to processing and there is no other legal basis for the processing; if the User objects to the processing and there is no other legitimate reason to continue with it; if the personal data has been unlawfully processed; if the personal data must be erased to comply with a legal obligation; or if the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years old. In addition to deleting the data, the Data Controller, taking into account available technology and the cost of its application, must take reasonable steps to inform those responsible for processing the personal data of the data subject's request for the erasure of any links to those personal data.

Right to restriction of processing: It is the User's right to limit the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data but the User requires it for the establishment, exercise or defense of legal claims; and when the User has objected to processing.

Right to data portability: In the event that processing is carried out by automated means, the User has the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Where technically feasible, the Data Controller will directly transmit the data to the other controller.

Right to object: It is the User's right not to have their personal data processed or to have the processing thereof ceased by Granfield Estate S.L.

Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individual decision based solely on automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by sending a written communication to the Data Controller with the reference "GDPR-granfield-estate.com", specifying:

• The User's name, surname and copy of their ID. In cases where representation is accepted, it will also be necessary to identify the person representing the User by the same means, as well as the document accrediting the representation. The photocopy of the ID can be substituted by any other legally valid means that proves identity.
• Request with the specific reasons for the request or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that proves the request made.

This request and any other attached documents may be sent to the following address and/or email:

Postal address:

• Av. Bélgica 1, C.C. Parquemar, 03188, La Mata, Alicante
• Email: info@granfield-estate.com

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party websites other than Granfield Estate S.L., and therefore are not operated by Granfield Estate S.L. The owners of such websites will have their own data protection policies, and they will be responsible, in each case, for their own files and their own privacy practices.

Complaints to the Supervisory Authority

In case the User considers that there is a problem or infringement of the current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. COOKIE POLICY

Access to this Website may involve the use of cookies. Cookies are small amounts of information stored in the browser used by each User—on the various devices they may use to browse—so that the server remembers certain information that later and only the server that implemented it will read. Cookies facilitate navigation, make it more user-friendly, and do not harm the browsing device.

Cookies are automatic procedures for collecting information related to the preferences determined by the User during their visit to the Website in order to recognize them as a User, and personalize their experience and the use of the Website, and can also, for example, help identify and resolve errors.

The information collected through cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website, and the sites visited just before and after it. However, no cookie allows it to contact the User's telephone number or any other personal contact means. No cookie can extract information from the User's hard drive or steal personal information. The only way for the User's private information to be part of the Cookie file is for the user to personally provide that information to the server.

Cookies that allow identifying a person are considered personal data. Therefore, the previously described Privacy Policy will apply to them. In this regard, the use of them will require the User's consent. This consent will be communicated, based on a genuine choice, offered through an affirmative and positive decision, before the initial processing, removable, and documented.

Own Cookies

These are those cookies that are sent to the User's computer or device and managed exclusively by Granfield Estate S.L. for the better functioning of the Website. The information collected is used to improve the quality of the Website and its Content and the User's experience. These cookies allow recognizing the User as a recurring visitor to the Website and adapt the content to offer contents that fit their preferences.

The entity(ies) in charge of supplying cookies may transfer this information to third parties, provided that the law requires it or a third party processes this information for such entities.

Social Network Cookies

Granfield Estate S.L. incorporates social network plugins, which allow access to them from the Website. For this reason, social network cookies can be stored in the User's browser. The owners of such social networks have their own data protection and cookie policies, and they are themselves, in each case, responsible for their own files and their own privacy practices. The User should refer to them to find out about such cookies and, where appropriate, the processing of their personal data. Only for informational purposes, the links where these privacy and/or cookie policies can be consulted are indicated below:

• - Facebook: https://www.facebook.com/policies/cookies/
• - Twitter: https://twitter.com/es/privacy
• - Instagram: https://help.instagram.com/1896641480634370?ref=ig
• - YouTube: https://policies.google.com/privacy?hl=es-419&gl=mx
• - Google+: https://policies.google.com/technologies/cookies?hl=es
• - Pinterest: https://policy.pinterest.com/es/privacy-policy
• - LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies

Disabling, Rejecting, and Deleting Cookies

The User may disable, reject, and delete cookies—totally or partially—installed on their device through the configuration of their browser (among which are, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures to reject and delete cookies may differ from one Internet browser to another. Consequently, the User must go to the instructions provided by the Internet browser they are using. In the event that they reject the use of cookies—totally or partially—they may continue to use the Website, although they may have limited use of some of the features of the same.

III. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions on the protection of personal data contained in this Privacy and Cookie Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the time frames, and for the purposes indicated. The use of the Website will imply acceptance of the Privacy and Cookie Policy of the same.

Granfield Estate S.L. reserves the right to modify its Privacy and Cookie Policy, according to its own criteria, or motivated by a legislative, case law, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookie Policy will be explicitly notified to the User.

This Privacy and Cookie Policy was updated on November 3, 2023, to conform to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.