I. PERSONAL DATA PROTECTION POLICY

19-02-2024

TECHNO PRO HISPANIA SL (hereinafter, the “Company”) is an organization in which personal data processing activities are carried out, which gives it significant responsibility in the design and organization of procedures aligned with legal compliance in this matter.

In the exercise of these responsibilities and in order to establish the general principles that must govern the processing of personal data in the Company, this Personal Data Protection Policy is approved, which is notified to its employees and made available to all its interest groups.

1. Purpose

The Personal Data Protection Policy is a proactive responsibility measure that aims to ensure compliance with the applicable legislation in this area and, in relation to this, respect for the right to honour and privacy in the processing of personal data of all persons who interact with the Company.

Pursuant to the provisions of this Personal Data Protection Policy, the principles governing the processing of data in the organization are established and, consequently, the procedures and organizational and security measures that the persons affected by this Policy undertake to implement within their area of responsibility.

To this end, ADEPLUS CONSULTORES, SLU, with address at Av. del Parque Científico y Tecnológico BADAJOZ, BADAJOZ and email [email], together with the Management, will assign responsibilities to the personnel involved in data processing operations.

2. Scope of application

This Personal Data Protection Policy will apply to the Company, its directors, managers and employees, as well as to all persons who have a relationship with it, expressly including service providers with access to data (hereinafter, “Data Processors”).

3. Principles of processing personal data

As a general principle, the Company will scrupulously comply with the legislation on the protection of personal data and will be able to demonstrate this (principle of "proactive responsibility"), paying special attention to those treatments that may pose a greater risk to the rights of those affected (principle of "risk approach").

In relation to the above, TECHNO PRO HISPANIA SL will ensure compliance with the following principles:

• Legality, loyalty, transparency and limitation of purpose: Data processing must always be communicated to the affected party through clauses and other procedures; and it will only be considered legitimate if there is consent for the data processing or if there is another valid legitimation.

• Data minimization: The data processed must be adequate, relevant and limited to what is necessary in relation to the purposes of the processing.

• Accuracy: The data must be accurate and, where necessary, up-to-date. The necessary measures will be taken to delete or rectify inaccurate personal data without delay.

• Limitation of the conservation period: The data will be kept in a way that allows the identification of the interested parties for no longer than necessary for the purposes of the processing.

• Integrity and confidentiality: The data will be processed in a manner that guarantees adequate security, through the application of appropriate technical or organizational measures.

• Data transfers: Purchasing or obtaining personal data from illegitimate sources or in cases where such data has been collected or transferred in violation of the law is prohibited.

• Hiring suppliers with access to data: Only suppliers that offer sufficient guarantees to apply appropriate technical and security measures in data processing will be contracted.

• International data transfers: Any data processing involving a transfer outside the European Economic Area must comply with applicable legal requirements.

• Rights of those affected: The Company will facilitate the exercise of the rights of access, rectification, deletion, limitation of processing, opposition and portability, establishing internal procedures for this purpose.

4. Employee Commitment

Employees are informed of this Policy and declare that they are aware that personal information is an asset of the Company. In this regard, they undertake the following:

• Carry out the data protection awareness training that the Company makes available to you.

• Apply security measures at user level that correspond to their job position, without prejudice to the responsibilities in their design and implementation that may be attributed to them based on their role within TECHNO PRO HISPANIA SL

• Use the established formats for the exercise of rights by those affected and inform the Company immediately so that the response can be effective.

• Inform the Company, as soon as it becomes aware, of deviations from this Policy, in particular regarding “personal data security breaches”, using the format established for this purpose.

5. Control and evaluation

An annual verification, evaluation and assessment will be carried out, or whenever there are significant changes in data processing, of the effectiveness of the technical and organisational measures to ensure the security of the processing.