PRIVACY POLICY

In compliance with the provisions of current legislation, Eduardo Massoud (hereinafter also the Website) 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, with NIF: 35103525M (hereinafter, Data Controller). His contact details are as follows:

Address:
Urb. Coral Beach km 176, Marbella 29602, Spain Contact telephone: 952775000 Contact email: eduardo@coralestates.es

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 RGPD and in article 4 and following of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

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 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 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 purposes of personalisation, operational and statistical purposes, and for activities inherent to the corporate purpose of Eduardo Massoud, 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 compliance with the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, only persons over the age of 14 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 given their consent.

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 against the Data Controller the following rights recognised in the RGPD and in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights:

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 said data and the recipients of the communications made or planned for said 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).

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 they may use 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 their visit to the Website in order to recognise them as a User, and to personalise their 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.

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.

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 and Cookies 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. Use of the Website implies acceptance of its Privacy and Cookies Policy.

Eduardo Massoud reserves the right to modify its Privacy and Cookies 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 and Cookies Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to keep abreast of the latest changes or updates.

This Privacy and Cookies Policy was updated on 19 December 2022 to adapt to 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 (RGPD) and to Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.