PRIVACY POLICY

Confidentiality, professional secrecy, and security are paramount values of ACKERMANN LABS, which assumes the commitment to guarantee the privacy of the data subject. Therefore, following the principles of lawfulness, fairness, and transparency of Regulation (EU) 2016/679 General Data Protection Regulation ("GDPR") and Organic Law 3/2018, of December 5, on Protection of Personal Data and Guarantee of Digital Rights ("LOPDGDD"), we provide you with the following information to explain how we process the personal data you provide when interacting with us.

This policy applies to all users of the website, whether or not they are clients of Ackermann Labs (hereinafter, indistinguishably, "the user" or "the users") who are considered natural persons.

And by personal data, we refer to all information regarding an identified or identifiable natural person.

If you are already a client of Ackermann Labs, having signed a contract with us, you must also refer to the information contained therein regarding specific privacy terms.

We are the data controller of your personal data:

• Full entity name: Ackermann Labs International, S.L.
• Registered Office: C/Hermosilla 30, piso 4dcha, CP:28001 – Madrid
• Tax ID (CIF): B88298583
• Contact Phone/s: +34 91 781 52 50
• Contact Email (general): datos@ackermanninternational.com

In accordance with the "GDPR" and the "LOPDGDD", ACKERMANN LABS, having taken into account the nature, scope, and purposes of the processing, as well as the risk associated with the processing operations and following an internal analysis, has reached the conclusion that it has no legal obligation to appoint a data protection officer.

However, ACKERMANN LABS, to guarantee and demonstrate that the processing is carried out under the provisions of the "GDPR" and the "LOPDGDD", has established accountability protocols and tools such as impact assessments, reviews, etc. Likewise, it has a team in charge of ensuring compliance with the regulations on personal data protection, as well as informing and advising data subjects and cooperating with the supervisory authority.

You may exercise your rights, when appropriate, by directing a written communication to the registered office of ACKERMANN LABS or to the email address enabled for this purpose, datos@ackermanninternational.com.

Models, forms, and more information available regarding your rights on the website of the national supervisory authority, the Spanish Data Protection Agency (hereinafter, "AEPD") www.aepd.es

The processing of your data is necessary to give you access to the contents and/or functionalities of the platform or, in case you so require, to be able to send you the information or provide you with the services arranged through it.

In this regard, we maintain a firm commitment to process your personal data in a legitimate and coherent manner in accordance with the principles and legal obligations laid down by the current personal data protection regulations.

When you browse through our platform and, in particular, when you interact with us, you provide us with data directly, for example, when you complete any form or request arranged online pursuant to the processing purposes indicated in each case (newsletter, contact form, etc.).

The data you provide us is related to such forms or requests arranged through the platform and, in addition, may vary depending on the type of form or request in question.

Notwithstanding the foregoing, through the platform, and its various forms/requests, different categories of personal data may be collected, although we will always request those data that are adequate, pertinent, and limited to what is necessary regarding the cited processing purposes (principle of minimization of personal data):

• Identifying personal data (name and surnames).
• Personal contact data (telephone or personal mobile, email).
• Professional data: (company in which you work and role you occupy in said company).
• Data on personal characteristics (services that interest you, associated needs or doubts, etc.).

Likewise, you may configure your preferences regarding the use of cookies used on our Platform through the enabled configuration panel, as indicated in the cookie policy.

The personal data you provide us will be processed for the purpose stipulated in a particular manner in this privacy policy and, where appropriate, in the various data forms arranged therein.

In this sense, the data collection serves the following processing purposes:

• To enable you to browse our platform, thereby allowing you access to the information and contents arranged therein.
• To resolve your doubts in an agile and effective manner through the contact form, as well as complaints, comments, or concerns you may have regarding the information included on the web, the services provided through the web, the processing of your personal data, questions referring to the legal texts included on the web, as well as any other queries you may have that are not subject to the contracting conditions.
• To facilitate, if you so wish, your subscription to our blog/newsletter so that you can access additional content and information that may be of interest to you.
• To allow the uses associated with web cookies as described in our cookie policy.
• In the event that you have accepted the cookie policy, for the development of the purposes associated with the different types of cookies informed through it, in particular, those of an analytical type (browsing/user profile), to perform such analysis and statistics associated with web browsing in order to be able to improve our services and the quality in the provision thereof.

At any time, if you so wish, you may configure the use of analytical cookies, holding a right to revoke your consent regarding the purposes associated with these cookies.

We inform you that the revocation of your consent to the processing of your data regarding certain types of cookies such as session or technical ones may prevent you from browsing our platform (see cookie policy).

• Data of website users: if you wish to contact us to make an inquiry through the "Contact" form on the website.
• On the other hand, our website uses cookies that may collect personal data from you (for example, your IP address or your ID) to ensure browsing, see how many times you visit us, etc. If you want to know more about the cookies we use, you can consult our Cookie Policy.
• To adopt as many protection measures as are applicable in accordance with current regulations, including the possible anonymization of your personal data applying, for this purpose, the adequate techniques available to that effect.
• Consequently, in this area, anonymization and pseudonymization processing may also be carried out for the better protection of your personal data.
• To apply the pertinent security, technical, and/or organizational measures regarding your personal data with a focus on the risk existing at each moment, including the pseudonymization or encryption of personal data through our platform.

When the legitimate basis for the processing of your personal data is your consent, we remind you that you have the right to revoke it at any time easily and free of charge by writing to us.

In any case, and notwithstanding the foregoing, the user is also informed of the following:

• In accordance with current personal data protection regulations, in all that concerns the correct processing of personal information by Ackermann Labs, this entity may also retain the information for three years securely from its collection/capture (statute of limitations for infringements in this area).
• Regarding the retention time of cookies, the user is recommended to consult our cookie policy (temporality section).

Generally, when personal data are no longer necessary for the processing purposes for which they were collected, they will be blocked, remaining at the disposal only of the competent authorities for the possible determination of legal liabilities during the processing thereof, always in accordance with applicable regulations, and may not be used for other purposes distinct from these.

Once the corresponding legal terms have elapsed in case of blocking, your data will be erased as provided by applicable regulations, and may also, if applicable, be securely anonymized by Ackermann Labs (anonymized/non-personal data).

We endeavor to request or apply the minimum and essential data to carry out the personal data processing that we perform in full development of our corporate object and purposes. All this is in line with the principles contained in the applicable regulations.

However, the failure to provide your personal data could result in the impossibility of:

1. You being able to browse correctly through our website (disabling technical cookies);
2. Processing your specific request or petition (for example, due to the lack or insufficient completion of the corresponding form or request);
3. Accessing certain contents or services (for example, if you do not provide us with your data to receive our newsletter, you will not receive it, nor the information or contents associated with it).

In any case, the information and personal data you provide us, depending on each case, must be in any event:

• Sufficient, although adjusted, limited, and proportionate to the legitimate purposes of processing informed in each case, with maximum respect for the principles of purpose limitation and minimization of personal data.
• Accurate, up-to-date, and truthful, in order to be able to verify adequately the identity, capacity, and, where appropriate, representation, as well as to be able to adjust, in each case, the data processing carried out to your specific needs and your real situation.

All this in attention to the principle of accuracy of personal data.

Generally, we do not share your data with third parties, nor do we sell or offer it to them.

However, it is possible that certain third parties may access your personal information in the development of the services they may provide to Ackermann Labs. For example, in the case of third-party cookies applied on the platform (see cookie policy).

Likewise, as Ackermann Labs belongs to a corporate group, your data may be shared with the rest of the entities that make up said group.

Ackermann Labs has various data processors for the personal data under its control, allowing access to them, as trusted providers, and to the extent that is strictly necessary for the provision of the services contracted with them.

Such data processors operate under a service contract in the terms, with the conditions and guarantees contained in Article 28 of the GDPR, with Ackermann Labs performing the corresponding controls, inspections, and audits in this area to verify that such data processors strictly comply with the contracts signed for this purpose and the applicable regulations.

Ackermann Labs informs you that your data will be treated with the utmost care and confidentiality by all personnel involved in any of the processing phases.

We inform you that, generally, international transfers of your personal data are not foreseen, with the necessary measures and guarantees being adopted by Ackermann Labs in this area in accordance with current personal data protection regulations.

Notwithstanding the foregoing, in our cookie policy, you will find information regarding the use of Cookies by third parties that could perform international transfers of personal data.

You can consult the privacy information of the third parties that serve cookies on this web through our Cookie Policy.

Any person can exercise their rights by directing a written communication to the email address datos@ackermanninternational.com with the Ref. "Exercise Rights" accompanying, if necessary to prove your identification, a copy of your national identity document or equivalent identification document (passport, N.I.E…).

Specifically, interested persons have the following rights:

• Right of information (Articles 12 to 14 of the GDPR): Right to be provided by Ackermann Labs with appropriate information, both at the time your personal data is collected (whether obtained from you or through a third party), and at any subsequent time.
• Right of access: Right to obtain from Ackermann Labs confirmation of whether or not your personal data are being processed, and basic information regarding such processing, as well as to obtain a copy of the personal data subject to processing.
• Right of rectification: Right to obtain without undue delay from Ackermann Labs the rectification of your personal data.
• Right of erasure ("the right to be forgotten"): Right to obtain without undue delay from Ackermann Labs the erasure of your personal data.
• Right to restriction of processing: Right to obtain from Ackermann Labs the restriction of the processing of your data when: You contest the accuracy of your personal data; the processing is unlawful and you oppose their erasure; Ackermann Labs no longer needs the personal data but you need them for claims; or you have objected to processing pursuant to Art. 21.1 GDPR.
• Right to data portability.
• Right not to be subject to a decision based solely on automated processing (including profiling).
• Right to object.
• Right to withdraw consent given: You shall have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing performed by Ackermann Labs based on your consent prior to its withdrawal.

Data subjects shall also have the right to effective judicial remedy and to lodge a complaint with the supervisory authority, in this case, the Spanish Data Protection Agency (Agencia Española de Protección de Datos), if they consider that the processing of personal data concerning them infringes the Regulation.

However, we recommend that before filing any complaint or claim with the AEPD, you contact us in order to analyze the specific situation applicable, and try, where appropriate, to seek an effective and amicable solution.

Apart from the foregoing, if you wish, you can also find information about how to file a complaint on the AEPD website www.aepd.es.

Additionally, if you have any questions or doubts or require more information, please do not hesitate to contact us at the email address: datos@ackermanninternational.com

Taking into account the nature, scope, context, and the indicated purposes of the processing, as well as the risks of varying likelihood and severity for your rights and freedoms, Ackermann Labs applies (and will apply) appropriate technical and organizational measures to ensure the due security and protection of your personal data attending to criteria of privacy by design and by default, as well as applying a concurrent risk-focused system that will be reviewed and updated by Ackermann Labs when necessary.

The use of the Hyper-Text Transfer Protocol (HTTPS) on our platform is a reinforced guarantee for the security of your personal data.

Articles on this website may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in exactly the same way as if the visitor had visited the other website.

Ackermann Labs reserves the right to modify this policy, to adapt it to future legislative, doctrinal, or jurisprudential developments that may apply, or for technical, operational, commercial, corporate, and business reasons, informing you reasonably in advance of the changes that occur when possible.

In any case, it is recommended that, every time you access this platform, you read this policy in detail, since any modification will be published through it.

Likewise, Ackermann Labs may inform you personally and in advance of the projected changes in this policy, prior to its entry into force, whenever this is technically and reasonably possible.

In case of any question or suggestion you would like to send us regarding this policy, please do not hesitate to contact us through the email address: datos@ackermanninternational.com or through the "Contact us" section found on the platform.

Generally, any controversy and conflict will be submitted preferentially by the parties to the knowledge of the same for the purposes of seeking an amicable solution and by mutual agreement using, for these purposes, the channel and email arranged in the third [section] of this policy.

In the event that this is not possible, attending to the criteria contained in the GDPR for the determination of the competence of the lead or main authority regarding the knowledge of any conflict, controversy, or claim regarding this privacy policy, at least, via administrative channels, it is informed that such authority shall be the Spanish Data Protection Agency (AEPD), having to attend, in any case, to the provisions of Article 56 of the GDPR.

Regarding the right to effective judicial remedy against the Client in these cases, the provisions of Article 79.2 of the GDPR shall also apply, being able to exercise the corresponding action before the Judges and Tribunals of the City of Madrid to the extent that the responsible entity is a company based in Spain.

The current applicable Spanish and European regulations in this area shall be attended to.