I. PRIVACY POLICY AND DATA PROTECTION

In accordance with current legislation, Tenmar Agency (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Legislation included in this privacy policy

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

• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons concerning the processing of personal data and the free movement of such data (GDPR).
• Organic Law 3/2018, of December 5, on Personal Data Protection and the guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving 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 person responsible for the processing of personal data

The person responsible for processing personal data collected by Tenmar Agency is: BMDY2024 SL, with NIF: B19825306 (hereinafter, Data Controller). Their contact details are as follows:

Address: Calle El Callao 1 CALLAO SALVAJE 38678. 38678, Adeje (Santa Cruz De Tenerife). Spain

Contact phone number: +34 682 87 80 82

Contact email: Buenomtzyuso@gmail.com

Personal Data Records

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Tenmar Agency, through the forms provided on its pages, will be incorporated and processed in our file to facilitate, expedite, and fulfill the commitments established between Tenmar Agency and the User or the maintenance of the relationship established in the forms filled out by the User, or to respond to a request or query. Furthermore, in compliance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is kept specifying, according to their purposes, the processing activities carried out and 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 set out in Article 5 of the GDPR and Article 4 and following of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: The User's consent will be required at all times, following full transparency on the purposes for which personal data are collected.
• Purpose limitation principle: Personal data will be collected for specific, explicit, and legitimate purposes.
• Data minimization principle: The personal data collected will be only those strictly necessary concerning the purposes for which they are processed.
• Accuracy principle: Personal data must be accurate and always up-to-date.
• Storage limitation principle: Personal data will only be retained in a form that allows the identification of the User for the time necessary for the purposes of their processing.
• Integrity and confidentiality principle: Personal data will be processed in such a way as to ensure their security and confidentiality.
• Accountability principle: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by Tenmar Agency are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed by Tenmar Agency include both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

The processing of special categories of personal data will always require the explicit consent of the User for one or more specific purposes.

Legal basis for processing personal data

The legal basis for processing personal data is consent. Tenmar Agency undertakes to obtain the explicit and verifiable consent of the User for processing their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not affect 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 Website's content, they will be informed if the completion of any of these forms is mandatory due to being essential for the correct execution of the operation carried out.

Purposes of the processing of personal data

Personal data are collected and managed by Tenmar Agency to facilitate, expedite, and fulfill the commitments established between the Website and the User or to maintain the relationship established in the forms filled out by the latter, or to respond to a request or inquiry.

Likewise, the data may be used for commercial, customization, operational, and statistical purposes, and for activities related to the Website's corporate purpose, as well as for the extraction, storage of data, and marketing studies to adapt the content provided to the User, as well as improve the quality, operation, and navigation of the Website.

At the time personal data is obtained, the User will be informed of the specific purpose or purposes of the processing of personal data; that is, the use or uses that will be made of the information collected.

At the time personal data is obtained, the User will be informed of the specific purpose or purposes of the processing of personal data; that is, the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data will only be retained for the minimum necessary time for the purposes of their processing, and in any case, only for the following period: 6 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 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:

• Digital service providers necessary for the operation of the website (hosting, analytics, marketing, etc.).

If 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 of this third country or international organization to which data is intended to be transferred, as well as the existence or absence of a decision on adequacy by the Commission.

Personal data of minors

In compliance with the provisions of articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only individuals over the age of 14 may give their consent for the lawful processing of their personal data by Tenmar Agency. If a minor under 14 years of age wishes to give their personal data, parental or guardian consent will be required for the processing of their data.

Secrecy and security of personal data

Tenmar Agency undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, to ensure the security of personal data and to avoid 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 data is transmitted between the server and the User, and in feedback, fully encrypted or encrypted.

However, because Tenmar Agency cannot guarantee the absolute impregnability of the internet or the total absence of hackers or others fraudulently accessing personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. Following the provisions of Article 4 of the GDPR, a personal data breach is understood as a security breach that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated confidentially by the Data Controller, who undertakes to inform and ensure by 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 over Tenmar Agency and may, therefore, exercise the following rights recognized in the GDPR and the Organic Law on Data Protection:

• Right of access: The User has the right to obtain confirmation of whether or not Tenmar Agency is processing their personal data and, if so, to obtain information about their specific personal data and the processing Tenmar Agency has carried out or is carrying out, as well as, among other things, information available on the origin of such data and the recipients of the communications made or planned for such data.
• Right to rectification: The User has the right to have their personal data modified if it is inaccurate or incomplete, according to the purposes of the processing.
• Right to erasure (“right to be forgotten”): The User has the right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when such data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal ground for the processing; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; or the personal data must be erased in compliance with a legal obligation.
• Right to restriction of processing: The User has the right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when the accuracy of the personal data is contested by the User, for a period that allows the Data Controller to verify the accuracy of such data; the processing is unlawful, and the User opposes the erasure of the personal data and requests instead the restriction of its use; the Data Controller no longer needs the personal data for the purposes of the processing, but the User needs it to establish, exercise, or defend legal claims; and the User has objected to processing, pending the verification whether the legitimate grounds of the Data Controller override those of the User.
• Right to data portability: In cases where the processing is carried out by automated means, the User has 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 controller. Where technically feasible, the Data Controller will directly transmit the data to that other controller.
• Right to object: The User has the right to object to the processing of their personal data. Tenmar Agency will no longer process personal data unless there are compelling legitimate grounds for the processing or for the establishment, exercise, or defense of legal claims.
• Right not to be subject to automated decision-making: The User has the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning the User or significantly affects them in a similar way, unless it is necessary for entering into or performance of a contract between the User and Tenmar Agency, is permitted by Union or Member State law to which Tenmar Agency is subject, or is based on the User's explicit consent.

The User may exercise their rights through written communication addressed to the Data Controller with the subject "GDPR-[RIGHT NAME]," specifying:

• User's full name and a copy of their ID.
• The request with specific reasons for the request or information they wish to access.

Additionally, the User may file a complaint with the supervisory authority.

How to exercise your rights

The User may exercise their rights by sending a written communication to the Data Controller with the subject “GDPR-[RIGHT NAME],” specifying:

• The User’s full name and a copy of their ID. In cases where representation is allowed, it will also be necessary to provide the representation document as well as the representative’s ID.
• A request with the specific reasons for the request or information they wish to access.
• The User’s address for notification purposes, the date, and the User’s signature.
• Any supporting documents for the request being made.

This request and any attached documents may be sent to the following address and/or email address:

• Postal address: Tenmar Agency
• Email address: info@tenmaragency.com

Complaints to the supervisory authority

If the User believes that there is a problem or violation of current regulations in the way their personal data is being processed, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, particularly in the state where they have their habitual residence, place of work, or where the alleged violation took place. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.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 they accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the time, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Tenmar Agency reserves the right to modify its Privacy Policy according to its own criteria or due to a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Users will be notified of changes or updates to this Privacy Policy through a clear notice on the Website.

This Privacy Policy was updated on 2023-01-31 to adapt to Regulation (EU) 2016/679 of the European Parliament and the Council, of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR), and Organic Law 3/2018, of December 5, on Personal Data Protection and the guarantee of digital rights.