PRIVACY POLICY

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, Gambito Golf Club Calatayud (hereinafter, also Website) commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the collected data.

Laws incorporated in this privacy policy

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

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 December 5, on Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

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

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

Identity of the controller of personal data processing

The controller of the personal data collected in Gambito Golf Club Calatayud is: GALERA GOLF, SL, provided with NIF/CIF: B65931693 and registered in: Barcelona Mercantile Registry with the following registration data: Volume 43554, Folio 172, Sheet B 432127, whose representative is: Jorge Piera Vivó (hereinafter, Data Controller).

Their contact details are as follows:

Address: C/ Mallorca, 230, Pral 1ª – 08008 Barcelona Contact phone: 934876934

Contact email: comunicacion@galeragroup.com

Personal Data Register

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Gambito Golf Club Calatayud, through the forms extended on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Gambito Golf and the User or the maintenance of the relationship established in the forms that he/she fills out, or to attend to a request or query from the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR is applicable, a record of processing activities is maintained that specifies, according to its 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 collected in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights:

Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times following completely transparent information about the purposes for which personal data is collected.

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

Principle of data minimization: the personal data collected will be only 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 storage limitation: personal data will only be maintained in a way that allows 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 its 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 Gambito Golf Club Calatayud 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. Gambito Golf commits to obtaining the User’s express and verifiable consent 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. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions where 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 if completing any of them is mandatory because they are essential for the correct execution of the operation carried out.

Purposes of processing for which personal data are intended

Personal data is collected and managed by Gambito Golf with the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the

relationship established in the forms that the latter fills out or to address a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operations and statistics, and activities specific to Gambito Golf’s corporate purpose, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User, as well as improve the quality, functionality, and navigation of the Website.

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

Personal data retention periods

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

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

Recipients of personal data

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

In the event that 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 the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with the provisions of Article 8 of the GDPR and Article 7 of 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 Gambito Golf. If it concerns a minor under 14 years of age, parental or guardian consent will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Gambito Golf Club Calatayud commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the collected data, 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 unauthorized communication 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 data transmission between the server and the User, and in feedback, is fully encrypted.

However, since Gambito Golf Club Calatayud 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 personal data breach occurs that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data breach is understood as any breach of security that causes the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication or access to such data.

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

Rights derived from the processing of personal data

The User has the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, which they can exercise against Gambito Golf as the Data Controller:

Right of access: This is the User’s right to obtain confirmation of whether Gambito Golf is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Gambito Golf has carried out or is carrying out, as well as, among other things, the available information on the origin of said data and the recipients of communications made or planned for the same.

Right of rectification: This is the User’s right to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.

Right of erasure (‘right to be forgotten’): It is the User’s right, unless current legislation establishes otherwise, to obtain the erasure of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent for processing and there is no other legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be erased to comply with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14 years of age. In addition to erasing the data, the Data Controller, taking into account available technology and the cost of its application, must adopt reasonable measures to inform the controllers who are processing the personal data of the data subject’s request to erase any link to that 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 needs it to make claims; and when the User has objected to the processing.

Right to data portability: In case the processing is carried out by automated means, the User shall have 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. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.

Right to object: It is the User’s right to prevent the processing of their personal data or to cease the processing of the same by Gambito Golf.

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 individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference ‘GDPR-https://www.gambitogolfclubcalatayid.com/’, specifying:

Name, surname of the User and copy of ID. In cases where representation is allowed, it will also be necessary to identify by the same means the person representing the User, as well as the document proving the representation. The photocopy of the ID may be replaced by any other means valid in law that proves identity.

Request with the specific reasons for the request or information to which access is desired. Address for notifications.

Date and signature of the applicant.

Any document that supports the request being made.

This request and any other attached document may be sent to the following address and/or email: Postal address: C/ Mallorca, 230, Pral 1ª – 08008 Barcelona

Email: comunicacion@galeragroup.com

Links to Third-Party Websites

The Website may include hyperlinks or links that allow access to third-party web pages different from Gambito Golf Club Calatayud, and which are therefore not operated by Gambito Golf Club Calatayud. The owners of these websites will 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 violation of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State where 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 (https://www.aepd.es/).

II. 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 accepts the processing of their personal data for the Data Controller to proceed with it in the manner, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

Gambito Golf reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change from the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated 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 (GDPR) and to the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.