PRIVACY POLICY

1. WHO IS THE DATA CONTROLLER?

Entity Name: CLECE, S.A.

Tax Identification Number (CIF): A80364243

Registered Address: Calle de Quintanavides, 19, Block 4 – Floors 1 and 2, 28050 Madrid, Spain

Telephone: +34 91 745 91 00

Data Protection Officer (DPO) Email: rgpd-clece@clece.es

2. WHAT IS THE PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

Through this website, we collect personal data via the contact form for the following purposes:

Handling information requests and communication:

1. • To collect and manage inquiries related to our services.

1. • To provide information about services based on the selected geographical area.

1. • To assist in addressing received inquiries.

The legal basis for this processing is the performance of a contract or pre-contractual measures under Article 6(1)(b) of the General Data Protection Regulation (GDPR), which is deemed granted when you submit the form with your data.

Managing suggestions, complaints, and comments:

1. • To process complaints, suggestions, or comments submitted through the relevant section.

1. • To respond to requests related to the quality of the services provided.

The legal basis for this processing is the fulfillment of contractual or pre-contractual obligations under Article 6(1)(b) of the GDPR, which is considered granted when you submit the form with your data.

If you contact us through other channels (e.g., email), we will process your data to address your request and respond through the contact method you provide. The legal basis for this processing is your explicit consent, which is considered granted upon receiving your request via email.

3. WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?

Depending on your use of our website, we may process the following categories of personal data:

1. • Identification and contact details: Name, surname, email address, and telephone number.

1. • Location data: Geographical area selection.

1. • Browsing data: IP address and website usage patterns (For more information, please refer to our Cookie Policy).

1. • Other data: Additional information provided by the user in the “Comments” field of the form.

Please do not submit sensitive personal data or third-party information without their explicit consent through the web form or via any email addresses provided on this website.

4. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

Personal data will be retained for the following periods:

1. • Handling inquiries and requests: Until the inquiry is resolved, and for a maximum of 12 months.

1. • Suggestions and complaints: For as long as necessary to resolve the matter and for up to 5 years after its processing (statutory limitation period for potential civil actions).

1. • Browsing data: As determined by cookie settings (For more information, refer to our Cookie Policy).

5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We do not disclose your personal data to third parties outside the CLECE Group unless required by legal obligation or necessary for service provision through contracted service providers, such as:

1. • Technology providers: Web hosting and maintenance platforms.

1. • Authorities and public agencies: When required by law.

For services involving providers outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place to protect personal data.

Additionally, our company is present on social networks (Facebook, Twitter, YouTube, LinkedIn). When interacting with our profiles, we recommend reviewing their privacy policies.

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement appropriate technical and organizational measures to ensure the security of your personal data, preventing unauthorized access, loss, or alteration.

7. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

You have the right to:

1. • Access: Obtain confirmation of whether we are processing your personal data and access to such data.

1. • Rectification: Request the correction of inaccurate or incomplete data.

1. • Erasure (Right to be Forgotten): Request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected.

1. • Restriction of Processing: Request the restriction of the processing of your data under certain conditions.

1. • Objection: Object to the processing of your data for specific purposes.

1. • Data Portability: Receive your data in a structured, commonly used, and machine-readable format or request the transfer to another controller.

To exercise these rights, please send an email to rgpd-clece@clece.es with the subject line “Exercise of Data Protection Rights”.

If you believe your rights have not been properly addressed, you may file a complaint with the Spanish Data Protection Agency (AEPD) (C/ Jorge Juan, 6, 28001 Madrid or www.aepd.es).

8. UPDATES TO THIS PRIVACY POLICY

The company may update this privacy policy to reflect changes in regulations or its data processing practices. We recommend reviewing it periodically.