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Privacy policy

1. Data controller

The data controller of your personal data is Collins Laberge Asesores, S.L., with Tax ID (CIF) B
87045670 and registered office in Madrid (Spain), calle Príncipe de Vergara 120, esc. 1, 6-B. You
can also contact us by phone: (+34) 917 815 047 or by email: datos@claberge.es.

2. Data we process and how we obtain it

We collect and process data that you provide directly to us, such as when you:

✓ Fill out contact or subscription forms.

✓ Request information or quotes.

✓ Register to receive communications or participate in events.

The types of data we may process include:

✓ Identification data (name, company, position).

✓ Contact details (email, phone).

✓ Professional data related to business activity.

✓ Information related to your inquiries, requested services or subscriptions.

✓ IP address, cookies, and browsing data.

We do not collect or process specially sensitive data except in specific cases with your explicit
consent.

3. Purposes of processing

We process your data to:

✓ Manage and respond to your inquiries, requests, and communications.

✓ Formalize, provide, and invoice contracted services.

✓ Send you commercial or other information if you have given your consent.

✓ Manage subscriptions, events, newsletters, and informational communications.

✓ Fulfill legal and regulatory obligations.

4. Legal grounds for processing

The legal basis for processing your data is:

✓ Your explicit consent when collected for newsletters or commercial communications.

✓ The execution of a contract or pre-contractual measures.

✓ Compliance with legal obligations.

✓ The legitimate interest of the controller, provided it does not override your rights or
freedoms.

5. Data retention

We will retain your data for the time necessary to fulfill the described purposes and, thereafter, for the periods required by applicable regulations (tax, labor, etc.).

Once no longer needed, the data will be securely blocked or deleted.

6. Data disclosure to third parties

We will not transfer your data to third parties except:

✓ When required by law or a court order.

✓ When necessary for the provision of the service (e.g., technology providers, payment
entities).

✓ If you are part of entities within the same business group, always with protection
guarantees.

✓ If you give your consent for specific purposes.

In the event of international data transfers, appropriate legal mechanisms will be adopted (standard contractual clauses or other recognized instruments) to ensure an adequate level of protection under the GDPR.

7. Rights of data subjects

You have the right to:

✓ Access your data.

✓ Rectify it if inaccurate.

✓ Erase it when no longer needed.

✓ Object to its processing.

✓ Restrict its use.

✓ Data portability.

✓ Withdraw your consent at any time without affecting prior processing.

You can exercise your rights by sending a written request, along with a copy of your ID or equivalent document, to the postal or email address provided above.

You may also file a complaint with the Spanish Data Protection Agency (AEPD) if you believe your rights have been violated.

8. Data security

We apply appropriate technical and organizational measures to protect your data from loss, unauthorized access, alteration, or disclosure, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (General Data Protection Regulation – GDPR) and Spain’s Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights.

9. Use of Cookies and similar technologies

Our website uses first-party and third-party cookies to enable functionality, analyze site usage, and enhance user experience. Information about the use of cookies is described in our Cookies Policy, accessible on this website.

10. Updates to This Policy

We may update this Privacy Policy to reflect regulatory changes or modifications to our services. The current version will always be available on this website with the date of last update.

January 2026.