I. PRIVACY AND DATA PROTECTION POLICY

In accordance with current legislation, Nexta Living (hereinafter, also 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.

Laws incorporated 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 regulations:

• 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 the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulation implementing 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 data controller

The controller of personal data collected on Nexta Living is: NEXTA PROPERTIES, S.L., with Tax ID Number: B25918137, registered in the Commercial Registry of Santa Cruz de Tenerife with the following registration details: Volume 0, Page 9, Sheet 888, whose representative is: Tatiana Feijoo de Oliveira (hereinafter, the Data Controller). The contact details are as follows:

Address: Calle La Farola, 4, Local 5, 38390 – Santa Úrsula, Santa Cruz de Tenerife

Contact telephone: +34 604 851 794

Contact email: contact@nextaliving.com

Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Nexta Living through the forms on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between Nexta Living and the User or to maintain the relationship established through the forms that the User fills out, or to attend to a request or inquiry from the User. 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 applies, 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 shall be subject to the following principles set forth in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User's consent shall be required at all times with prior completely transparent information about the purposes for which personal data is collected.
• Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
• Principle of data minimization: personal data collected shall only be that which is strictly necessary in relation to the purposes for which it is processed.
• Principle of accuracy: personal data must be accurate and always kept up to date.
• Principle of storage limitation: personal data shall only be kept in a form that permits identification of the User for no longer than is necessary for the purposes of its processing.
• Principle of integrity and confidentiality: personal data shall be processed in a manner that ensures its security and confidentiality.
• Principle of accountability: the Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on Nexta Living are only identifying 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. Nexta Living undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their 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 affect the use of the Website.

On occasions when the User must or may 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 the completion of any of them is mandatory because they are essential for the correct execution of the operation carried out.

Purposes of the processing of personal data

Personal data is collected and managed by Nexta Living for 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 User fills out or to attend to a request or inquiry.

Likewise, the data may be used for commercial personalization, operational and statistical purposes, and activities related to the corporate purpose of Nexta Living, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and navigation of the Website.

At the time the 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 made of the information collected.

Retention periods for personal data

Personal data shall only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 24 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period for which the personal data will be stored or, when this 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 of 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 accordance with the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data 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 Nexta Living. In the case of a minor under 14 years of age, the consent of parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

Nexta Living undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order 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 transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since Nexta Living 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 personal data security occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means a breach of security leading 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 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, associates, and any person to whom it makes the information 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 the Protection of Personal Data and guarantee of digital rights, which may be exercised against the Data Controller:

• Right of access: This is the User's right to obtain confirmation as to whether or not Nexta Living is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Nexta Living has carried out or is carrying out, as well as, among other things, information available about the origin of such data and the recipients of communications made or planned.
• Right to 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 to erasure ("the right to be forgotten"): This is the User's right, provided that current legislation does not provide otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn consent to the 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 has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has 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 the available technology and the cost of its implementation, shall take reasonable steps to inform controllers who are processing the personal data of the data subject's request to erase any links to such personal data.
• Right to restriction of processing: This is the User's right to limit the processing of their personal data. The User has the right to obtain 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 the event that the processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit it to another controller. Whenever technically feasible, the Data Controller shall transmit the data directly to that other controller.
• Right to object: This is the User's right to have their personal data not processed or to have processing of their data by Nexta Living cease.
• Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "GDPR-www.nextaliving.com", specifying:

• Name, surname of the User and copy of ID card. In cases where representation is permitted, identification by the same means of the person representing the User will also be required, as well as the document accrediting the representation. The photocopy of the ID card may be replaced by any other legally valid means that proves identity.
• Request with the specific reasons for the application or information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request made.

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

Postal address: Calle La Farola, 4, Local 5, 38390 – Santa Úrsula, Santa Cruz de Tenerife

Email: contact@nextaliving.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Nexta Living, and which are therefore not operated by Nexta Living. The owners of such websites will have their own data protection policies, and they themselves are, 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 current regulations in the way their personal data is being processed, they shall have the right to effective judicial protection and to file 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 for the User to have read and agree to the conditions on the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller may proceed with it in the manner, during the periods and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

Nexta Living reserves the right to modify its Privacy 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 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 comply with 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 Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.