LEGAL ADVICE

GENERAL INFORMATION

In compliance with the obligation to provide information as stipulated in Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE) of 11 July, the following general information on this website is provided below:

The ownership of this website, www.eduardomassoud.com, (hereinafter Website) is held by: Eduardo Massoud, with NIF: 35103525M, and whose contact details are:

Address:
Urb. Coral Beach km 176, Marbella 29602, Spain Contact telephone: 952775000 Contact email: eduardomassoud@icloud.com

GENERAL TERMS AND CONDITIONS OF USE The subject matter of the terms and conditions: The Website
The purpose of these General Conditions of Use (hereinafter, Conditions) is to regulate access to and use of the Website. For the purposes of these Terms and Conditions, the Website shall be understood to mean: the external appearance of the screen interfaces, both static and dynamic, i.e. the navigation tree; and all the elements integrated both in the screen interfaces and in the navigation tree (hereinafter, Content) and all those online services or resources that may be offered to Users (hereinafter, Services).

Eduardo Massoud reserves the right to modify, at any time and without prior notice, the presentation and configuration of the Website and of the Contents and Services that may be incorporated therein. The User acknowledges and accepts that Eduardo Massoud may at any time interrupt, deactivate and/or cancel any of these elements incorporated in the Website or access thereto.

Access to the Website by the User is free and, as a general rule, is free of charge, without the User having to provide any consideration in order to enjoy it, except for the cost of connection through the telecommunications network supplied by the access provider contracted by the User.

The use of any of the Contents or Services of the Website may be made by prior subscription or registration of the User.

The User

Access, browsing and use of the Website confers the condition of User, and therefore, from the moment browsing the Website begins, the User accepts all the Conditions established herein, as well as any subsequent modifications, without prejudice to the application of the corresponding legal regulations that must be complied with as the case may be. Given the relevance of the above, the User is recommended to read them every time he/she visits the Website.

The Eduardo Massoud website provides a wide range of information, services and data. The User assumes responsibility for the correct use of the Website. This responsibility shall extend to:

Any use of the information, Content and/or Services and data offered by Eduardo Massoud that is contrary to the provisions of these Conditions, the Law, morality or public order, or which in any other way may infringe the rights of third parties or the operation of the Website itself.
The truthfulness and lawfulness of the information provided by the User on the forms provided by Eduardo Massoud for access to certain Contents or Services offered by the Website. In any event, the User shall immediately notify Eduardo Massoud of any event that may lead to the improper use of the information recorded on said forms, such as, but not limited to, theft, loss or unauthorised access to identifiers and/or passwords, in order to proceed to their immediate cancellation.

Mere access to this Website does not imply the establishment of any type of commercial relationship between Eduardo Massoud and the User.

In compliance with the legislation in force, this Eduardo Massoud website is intended for all persons, regardless of their age, who may access and/or browse the pages of the website.

ACCESS AND NAVIGATION ON THE WEBSITE: EXCLUSION OF WARRANTIES AND LIABILITY

Eduardo Massoud does not guarantee the continuity, availability and usefulness of the Website, or of the Contents or Services. Eduardo Massoud shall make every effort to ensure the proper functioning of the Website; however, it does not accept any liability or guarantee that access to this Website will not be uninterrupted or error- free.

Nor does Eduardo Massoud accept any liability or guarantee that the content or software that may be accessed through this Website is free from error or causes damage to the User's computer system (software and hardware). Under no circumstances shall Eduardo Massoud be liable for any loss, damage or harm of any kind arising from accessing, browsing and using the Website, including, but not

limited to, that caused to computer systems or that caused by the introduction of viruses.

Nor shall Eduardo Massoud be held liable for any damages that may be caused to users through improper use of this Website. In particular, it shall not be liable in any way whatsoever for any telecommunications failures, interruptions, faults or defects that may occur.

PRIVACY AND DATA PROTECTION POLICY

In compliance with the provisions of current legislation, Eduardo Massoud undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to current Spanish and European legislation on the protection of personal data on the Internet. Specifically, it respects the following rules:

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 the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
Royal Decree 1720/2007, of 21 December, approving the Regulation implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).
Identity of the controller processing the personal data

The person responsible for the processing of personal data collected in Eduardo Massoud is: Eduardo Massoud, NIF: 35103525M (hereinafter also Data Controller). His contact details are as follows:

Address:
Urb. Coral Beach km 176, Marbella 29602, Spain Contact telephone: 952775000 Contact email: eduardomassoud@icloud.com

Register of Personal Data

In compliance with the provisions of the RGPD and the LOPD-GDD, we inform you that the personal data collected by Eduardo Massoud through the forms provided on its pages will be incorporated and processed in our files in order to facilitate, expedite and fulfil the commitments established between Eduardo Massoud and the User or the maintenance of the relationship established in the forms filled in by the User, or to

respond to a request or query from the User. Likewise, in accordance with the provisions of the RGPD and the LOPD-GDD, unless the exception provided for in article 30.5 of the RGPD applies, a register of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the RGPD.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR:

Principle of lawfulness, fairness and transparency: the consent of the User shall be required at all times after full and transparent information on the purposes for which the personal data are collected.
Purpose limitation principle: personal data will be collected for specified, explicit and legitimate purposes.
Principle of data minimisation: the personal data collected will be only that which is strictly necessary for the purposes for which it is processed.
Principle of accuracy: personal data must be accurate and always up to date.
Principle of limitation of the storage period: personal data will only be kept in a form that allows the identification of the User for the time necessary for the purposes of their processing.
Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures their security and confidentiality.
Proactive accountability principle: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Eduardo Massoud are solely identification data. Under no circumstances 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. Eduardo Massoud undertakes to obtain the express and verifiable consent of the User to the processing of his/her personal data for one or more specific purposes.

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

On those occasions when the User must or may provide his/her data through forms to make enquiries, request information or for reasons related to the content of the Website, he/she will be informed in the event that the completion of any of them is compulsory due to the fact that they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data are used

The personal data is collected and managed by Eduardo Massoud in order to facilitate, speed up and fulfil the commitments established between the Website and the User or to maintain the relationship established in the forms filled in by the latter or to attend to a request or query.

Likewise, the data may be used for commercial, personalisation, operational and statistical purposes, and for activities inherent to Eduardo Massoud's corporate purpose, as well as for the extraction and storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and browsing of the Website.

At the time the personal data is collected, the User will be informed about the specific purpose(s) of the processing for which the personal data will be used, i.e. the use(s) to which the collected information will be put.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 12 months, or until the User requests their deletion.

At the time personal data is obtained, the User will be informed of the period for which the personal data will be retained or, where this is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data is collected, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

In accordance with the provisions of articles 8 of the RGPD and 13 of the RDLOPD, only persons over 14 years of age may give their consent to the processing of their personal data in a lawful manner by Eduardo Massoud. In the case of a minor under 14 years of age, the consent of the parents or guardians shall be required for the processing, and the processing shall only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Eduardo Massoud undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, so as to ensure the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.

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

However, because Eduardo Massoud cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of security of personal data occurs that is likely to entail a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a breach of security of personal data means any breach of security resulting in the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, partners, and any other person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User has over Eduardo Massoud and may, therefore, exercise the following rights recognised in the RGPD against the Data Controller:

Right of access: This is the User's right to obtain confirmation as to whether or not Eduardo Massoud is processing his/her personal data and, if so, to obtain information on his/her specific personal data and on the processing that Eduardo Massoud has carried out or is carrying out, as well as, inter alia, the information available on the origin of such data and the recipients of the communications made or planned for such data.
Right of rectification: This is the User's right to have his/her personal data amended if it proves to be inaccurate or, having regard to the purposes of the processing, incomplete.
Right of erasure ("the right to be forgotten"): This is the right of the User, unless otherwise provided by law, to obtain the erasure of his or her personal data when the personal data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his or her consent to the processing and the processing has no other lawful basis; the User objects to the processing and there is no other legitimate reason to continue the processing; the personal data have been processed unlawfully; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a person under 14 years of age. In addition to erasure, the Controller shall, taking into account available technology and the cost of its implementation, take reasonable steps to inform controllers who are processing the personal data of the data subject's request for erasure of any link to those personal data.
Right to restriction of processing: This is the User's right to restrict the processing of his or her personal data. The User has the right to obtain the limitation of processing when he/she contests the accuracy of his/her personal data; the processing is unlawful; the Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.

Right to data portability: Where processing is carried out by automated means, the User shall have the right to receive from the Controller his or her personal data in a structured, commonly used and machine-readable format and to transmit it to another controller. Where technically feasible, the Controller shall transmit the data directly to such other controller.
Right of opposition: This is the User's right not to have his or her personal data processed or to have the processing of such data by Eduardo Massoud cease.
Right not to be subject to a decision based solely on automated processing, including profiling: This is the right of the User not to be subject to an individualised decision based solely on automated processing of his or her personal data, including profiling, unless otherwise provided for by law.

Therefore, the User may exercise his/her rights by means of a written communication addressed to the Data Controller with the reference "RGPD- www.eduardomassoud.com", specifying:
Name, surname(s) of the User and copy of ID card. In cases where representation is permitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be substituted by any other legally valid means that accredits identity.
Request with specific reasons for the request or information to be accessed.
Address for the purpose of notifications.
Date and signature of the applicant.
Any document supporting the request you are making.
This application and any accompanying documents may be sent to the following address and/or e-mail address:

Postal address:
Urb. Coral Beach km 176, Marbella 29602, Spain E-mail: eduardomassoud@icloud.com

Links to third party websites

The Website may include hyperlinks or links that allow access to websites of third parties other than Eduardo Massoud, and which are therefore not operated by Eduardo Massoud. The owners of such websites shall have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of the regulations in force in the way in which his/her personal data is being processed, he/she shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State in which he/she has his/her 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).

Acceptance and changes to this privacy policy

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that he/she accepts the processing of his/her personal data so that the Data Controller can proceed in the manner, during the periods and for the purposes indicated. The use of the Website implies acceptance of the Privacy Policy of the same.

Eduardo Massoud reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy shall be explicitly notified to the User.

This Privacy Policy was updated on 19 December 2022 to adapt it to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of 5 December 2018 on the Protection of Personal Data and the guarantee of digital rights (LOPD).

COOKIE POLICY

Access to this Website may involve the use of cookies. Cookies are small amounts of information that are stored in the browser used by each User - in the different devices that may be used to browse - so that the server remembers certain information that will subsequently be read only by the server that implemented it. Cookies make browsing easier, more user-friendly and do not damage the browsing device.

Cookies are automatic procedures for collecting information relating to the preferences determined by the User during his/her visit to the Website in order to recognise him/her as a User, and to personalise his/her experience and use of the Website, and may also, for example, help to 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 just after the Website. However, no cookie allows the cookie to contact the User's telephone number or any other means of personal contact. 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 give that information to the server.

Cookies that allow a person to be identified are considered personal data. Therefore, the aforementioned Privacy Policy shall apply to them. In this regard, the use of cookies requires the consent of the User. This consent will be communicated, on the basis of a genuine choice, offered by means of an affirmative and positive decision, prior to the initial processing, removable and documented.

Own cookies

These are cookies that are sent to the User's computer or device and managed exclusively by Eduardo Massoud for the better functioning of the Website. The information collected is used to improve the quality of the Website and its Content and your experience as a User. These cookies make it possible to recognise the User as a recurring visitor to the Website and to adapt the content to offer him or her content that suits his or her preferences.

Third party cookies

These are cookies used and managed by external entities that provide Eduardo Massoud with services requested by the latter in order to improve the Website and the user's experience when browsing the Website. The main purposes for which third-party cookies are used are to obtain access statistics and to analyse browsing information, i.e. how the User interacts with the Website.

The information obtained refers, for example, to the number of pages visited, the language, the place where the IP address from which the User accesses, the number of Users who access, the frequency and recurrence of visits, the time of visit, the browser used, the operator or type of device from which the visit is made. This information is used to improve the Website, and to detect new needs in order to offer Users optimum quality Content and/or service. In any case, the information is collected anonymously and reports on website trends are drawn up without identifying individual users.

You can obtain more information about cookies, privacy information, or consult the description of the type of cookies used, their main characteristics, expiry period, etc. at the following link(s):

Google Analytics
https://developers.google.com/analytics/; Optimizely: https://help.optimizely.com/

The entity(ies) responsible for the provision of cookies may transfer this information to third parties, where required by law or where a third party processes this information for these entities.

Social media cookies

Eduardo Massoud incorporates social network plugins, which allow access to social networks from the Website. For this reason, social network cookies may be stored in the User's browser. The owners of these social networks have their own data protection and cookie policies, being themselves, in each case, responsible for their own files and their own privacy practices. The User should refer to them for information about these cookies and, where appropriate, the processing of their personal data. For information purposes only, the links where these privacy and/or cookie policies may 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 can disable, reject and delete cookies - in whole or in part - installed on their device by configuring their browser (including, for example, Chrome, Firefox, Safari, Explorer). In this regard, the procedures for rejecting and deleting cookies may differ from one Internet browser to another. Consequently, the User must follow the instructions provided by the Internet browser that he/she is using. In the event that you reject the use of cookies - totally or partially - you may continue to use the Website, although the use of some of its features may be limited.

Changes to the Cookie Policy

It is possible that the Cookies Policy of the Website may change or be updated, therefore it is recommended that the User reviews this policy each time he/she accesses the Website in order to be properly informed about how and for what purpose we use cookies.

LIAISON POLICY

Users are informed that the Eduardo Massoud Website places or may place at the disposal of Users means of linking (such as, among others, links, banners, buttons), directories and search engines that enable Users to access websites belonging to and/or managed by third parties.

The installation of these links, directories and search engines on the Website is intended to make it easier for Users to search for and access information available on the Internet, and may not be considered a suggestion, recommendation or invitation to visit them.

Eduardo Massoud does not itself or through third parties offer or market the products and/or services available on such linked sites.

Likewise, it does not guarantee the technical availability, accuracy, veracity, validity or legality of sites outside its property that can be accessed through the links.

Eduardo Massoud shall not under any circumstances review or control the content of other websites, nor does it approve, examine or endorse the products and services, content, files and any other material existing on the aforementioned linked sites.

Eduardo Massoud accepts no liability for any damages that may arise from the access, use, quality or legality of the contents, communications, opinions, products

and services of websites not managed by Eduardo Massoud and which are linked to this Website.

The User or third party who makes a hyperlink from a web page of another, different, website to the Eduardo Massoud Website must be aware that:

The reproduction - in whole or in part - of any of the Contents and/or Services of the Website is not permitted without the express authorisation of Eduardo Massoud.

Nor may any false, inaccurate or incorrect statement be made about the Eduardo Massoud Website, or about the Contents and/or Services of the same.

With the exception of the hyperlink, the website on which the hyperlink is established shall not contain any element of this website that is protected as intellectual property by Spanish law, unless expressly authorised by Eduardo Massoud.

The establishment of the hyperlink shall not imply the existence of a relationship between Eduardo Massoud and the owner of the website from which it is made, nor the knowledge and acceptance by Eduardo Massoud of the contents, services and/or activities offered on said website, and vice versa.

INTELLECTUAL AND INDUSTRIAL PROPERTY

Eduardo Massoud, by itself or as assignee, is the owner of all intellectual and industrial property rights of the Website, as well as of the elements contained therein (including but not limited to images, sound, audio, video, software or texts, trademarks or logos, colour combinations, structure and design, selection of materials used, computer programs necessary for its operation, access and use, etc.). They are, therefore, works protected as intellectual property by the Spanish legal system, being applicable to them both the Spanish and Community regulations in this field, as well as the international treaties relating to the matter and signed by Spain.

All rights reserved. By virtue of the provisions of the Intellectual Property Law, the reproduction, distribution and public communication, including making available, of all or part of the contents of this website, for commercial purposes, on any medium and by any technical means, without the authorisation of Eduardo Massoud, is expressly prohibited.

The User undertakes to respect the intellectual and industrial property rights of Eduardo Massoud. You may view the elements of the Website or even print, copy and store them on the hard drive of your computer or on any other physical medium provided that this is exclusively for your personal use. The User, however, may not remove, alter or manipulate any protection device or security system installed on the Website.

In the event that the User or third party considers that any of the Contents of the Website involves a violation of the rights of protection of intellectual property, he/she must immediately notify Eduardo Massoud through the contact details in the

GENERAL INFORMATION section of this Legal Notice and General Conditions of Use.

LEGAL ACTIONS, APPLICABLE LAW AND JURISDICTION

Eduardo Massoud reserves the right to bring any civil or criminal action it deems necessary for improper use of the Website and its Contents, or for breach of these Conditions.

The relationship between the User and Eduardo Massoud shall be governed by the regulations in force and applicable in Spanish territory. Should any dispute arise in relation to the interpretation and/or application of these Conditions, the parties shall submit their disputes to the ordinary jurisdiction, submitting themselves to the judges and courts that correspond in accordance with the law.

Last updated: 19 December 2022