Privacy Policy

CONTROLLER

1. Identity

• Company: MZL REAL ESTATE S.L.

• Tax ID: B75421990

• Address: Valentuñana, 2, 7ºdcha, 29601, Marbella, Málaga

• Phone: 952770592

• Email: info@streetandpartners.com

• Data Protection Officer contact details: Not available.

PURPOSES

2. Extended Description of the Purpose(s) of Data Processing:

We will process your data for administrative, accounting, and fiscal management, as well as for advertising and commercial prospecting.

Contractual Purposes:

• To contract, maintain, and monitor the performance of service agreements you have with us.

• To comply with the legal obligations derived from our activity.

Purposes Based on Legitimate Interest:

• To carry out commercial actions to offer and/or recommend consulting services that may be of interest to you.

• To share your data with group companies if you contract their services through THE OWNER, in which case only the necessary data for the contract will be communicated.

• To process and/or communicate your data to third parties (Public Administrations) to prevent, investigate, and/or detect fraud.

You may object to any of the aforementioned data processing activities based on legitimate interest by contacting the address provided above and explaining your reason for objection.

Purposes Requiring Your Consent:

• To communicate your personal data to group companies for commercial activities.

Refusing to authorize the data processing for this purpose will not affect the maintenance or performance of your contractual relationship with THE OWNER.

DATA RETENTION

3. Retention Periods or Criteria:

The personal data provided will be retained while the relationship with the entity is maintained and the deletion of the data is not requested by the data subject. The data will be stored in accordance with the legal timeframes established for tax and accounting matters, taking the latest communication as a reference.

DECISIONS

4. Automated Decisions, Profiling, and Applied Logic:

The company will not make automated decisions, create profiles, or apply logic to your data.

LEGAL BASIS

5. Legal Basis for Contract Execution:

Since the processing is necessary for the performance of a commercial contract in which you are a party, it is stated that the type of contract is the aforementioned commercial contract or pre-contractual relationship.

As the communication of personal data is a legal or contractual requirement necessary for the subscription of the mentioned contract, the data subject is informed that they are obliged to provide personal data. Failure to do so may result in the requested service not being provided.

RECIPIENTS

6. During the processing period, THE OWNER will carry out the following legal data transfers:

• Management with financial institutions and organizations or persons directly related to the controller.

7a. Occasionally, part of the collected information (email) will be shared with ADG Media Group for strategic collaborations.

7b. Optionally, temporary transfers will be made to IT service companies (data processors) outside the EU, in compliance with Privacy Shield. The entity hires its virtual infrastructure according to a cloud computing model through a provider protected under the EU-US Privacy Shield agreement. (More information available at: www.privacyshield.gov).

RIGHTS

8. The data subject may exercise the following rights:

• Right to access their personal data.

• Right to rectification or deletion of their data.

• Right to restrict the processing of their data.

• Right to object to the processing of their data.

• Right to data portability.

• Right to withdraw consent at any time.

Any person has the right to obtain confirmation on whether their personal data is being processed. Interested parties have the right to access their personal data and request the rectification of inaccurate data or request the deletion of their data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, data subjects may request the restriction of the processing of their data, in which case it will only be retained for the exercise or defense of claims. In specific cases and for reasons related to their particular situation, data subjects may object to the processing of their data. In this case, the entity will cease processing the data unless there are compelling legitimate grounds or for the exercise or defense of possible claims.

If you have given your consent for a specific purpose, you have the right to withdraw it at any time without affecting the lawfulness of the processing based on your prior consent.

You can use the forms provided by the company or send a letter to the following address:

• Email: info@streetandpartners.com

If you believe your rights concerning personal data protection have been violated, especially if you have not received satisfaction in exercising your rights, you may file a complaint with the relevant Data Protection Authority through their website: www.aepd.es.

In compliance with Article 21 of Law 34/2002 on Information Society Services and Electronic Commerce, if you no longer wish to receive information about our services, you may unsubscribe by sending an email to the entity, indicating “Unsubscribe” in the subject line.

SOURCE OF DATA

The personal data we process is provided directly by you or your legal representative.

The categories of processed data include:

• Specially protected data

• Identification data

• Personal characteristics

• Social circumstances

• Academic and professional data

• Employment details

• Commercial information

• Financial data

• Transaction details

Specially protected data is processed.

COOKIE POLICY

Information on Responsibility:

This section includes the legal information about the entity responsible for processing cookies collected on the website, in this case, the property of THE OWNER.

In compliance with Law 34/2002 on Information Society Services and Electronic Commerce (LSSI), along with the General Data Protection Regulation (GDPR) and Organic Law 3/2018 on Data Protection (new LOPD), we inform you that this website uses cookies or similar technologies to store and retrieve information when you browse.

This Cookie Policy is an integral part of the Legal Notice and the Privacy Policy of the website info@streetandpartners.com (hereinafter, the “Website”). By accessing and browsing the Website or using its services, you agree to the terms and conditions outlined in the Terms of Use and Privacy Policy.

What are cookies?

A cookie is a file downloaded to your device (computer, smartphone, or tablet) when you access a website, allowing the owner of the page to store or retrieve specific information about multiple variables, such as the number of visits by the user, identifying registered users, ensuring the user’s session during browsing, and enabling secure transactions.

Cookies provide information about user browsing habits and, as such, may affect privacy. We want to provide you with all necessary information regarding the types of cookies used on our website to allow you full control over their use and protection of your privacy.

Types of Cookies

• Own Cookies: Sent from our own devices or domains to your terminal.

• Third-Party Cookies: Sent from third-party collaborators.

Based on the Duration:

• Session Cookies: Stored until the user ends their browsing session.

• Persistent Cookies: Remain stored for a set time for later access.

Based on Purpose:

• Technical Cookies: Necessary for website functionality and service provision.

• Customization Cookies: Allow access with pre-defined settings (language, browser type, etc.).

• Analytical Cookies: Used for monitoring and analyzing user behavior to improve website performance.

• Advertising Cookies: Manage advertising spaces efficiently based on edited content or ad frequency.

How to Manage Cookies:

You can manage cookies through browser settings. Here are links for cookie settings in the most common browsers:

• Explorer, Firefox, Chrome, Safari.

If cookies are blocked, some website functionalities and content may be affected. Users can give or revoke their consent at any time through the configuration panel.

Please Note:

If the installation of all cookies on the website is blocked, some functionalities and content may be affected.

Who Uses the Cookies?

The information collected through cookies on the website may be used both by THE OWNER and by third parties providing services to it.

The information from the cookies used on the Website is processed by THE OWNER as well as by third parties providing services. These third parties include:

• Google

• LinkedIn

• Microsoft

• Meta (Meta Products)

• Pinterest

For additional information about third-party cookies used, you can visit the following links:

Data Retention Period for Cookie-Generated Data

The data generated by the use of accepted cookies will no longer be available in our systems after twelve (12) months. You will need to reconfigure your cookie preferences after this period.

Updates and Changes to the Cookie Policy

THE OWNER may modify the Cookie Policy in whole or in part by publishing any changes in the same format or through any type of communication directed to users, in response to legislative or regulatory requirements, or to adapt the policy to the instructions of the Spanish Data Protection Agency. We recommend that you periodically review its contents.

INTERNAL INFORMATION SYSTEM (S.I.I.)

The Internal Information System is the mechanism provided by THE OWNER to allow informants to report violations or infringements occurring or that have occurred within a professional or workplace context.

Violations or Infringements Reportable through the S.I.I.:

Reports may relate to violations or breaches in the following areas:

• European Union law regarding public contracts, financial services, anti-money laundering, and counter-terrorism financing, product safety and compliance, environmental protection, nuclear safety, food and feed safety, consumer protection, and network security.

• Criminal law violations.

• Administrative law for serious or very serious offenses.

• Anti-Money Laundering and Counter-Terrorism Financing regulations.

• Internal regulations of THE OWNER.

• Labor law violations related to workplace safety, health, harassment, and equality.

• Data protection breaches.

Who Can Use THE OWNER’s Internal Information System:

The system is available to public employees, employees under contract, freelancers, shareholders, board members, executives (including non-executive members), volunteers, interns, trainees, former employees, candidates, and any individual working under contractors, subcontractors, or other third parties related to THE OWNER in a professional capacity.

These individuals will be considered Informants when they use the Internal Information System.

Guarantees of THE OWNER’s Internal Information System:

• Accessibility: Reports can be made in different ways, including anonymously or by providing identification, at the informant’s discretion.

• Confidentiality and Data Protection: Confidentiality is maintained at all times.

• Effectiveness: All communications received will be treated so that the organization is the first to be informed of them.

• Objectivity and Impartiality: All communications will be handled objectively and impartially, regardless of who reports or is reported.

• Presumption of Innocence: The presumption of innocence, the right to defense, and the right to honor of the parties involved are guaranteed.

• No Retaliation: THE OWNER prohibits and guarantees that no retaliation will be taken against informants acting in good faith.

• Transparency: Informants will be informed about the investigation status when requested, as will the affected party.

Rights of the Informant:

• To be free from retaliation for reporting in good faith.

• To receive acknowledgment of the report within seven calendar days.

• To receive a response to the investigation within a maximum of three months, extendable by three more months depending on the investigation’s complexity.

• To request additional information.

• To request updates or opt-out of further updates about the case.

• To choose between anonymous or identified reporting.

• To have data protection rights respected.

• To have all guarantees of the Internal Information System respected.

Rights of the Person Affected by the Report:

• To be informed of the progress of the investigation.

• To be informed in an understandable manner of the facts reported.

• To participate in the investigation, provide information, testify, or request investigative actions within legal limits.

• To have legal representation, including a lawyer or union representative.

• To have personal data protection rights respected.

Channels for Reporting Violations:

• Data Protection Violations: Report to the data protection channel.

• Labor and Harassment/Equality Issues: Report to the human resources channel.

• Anti-Money Laundering Violations: Report to the anti-money laundering (AML) channel.

• Other Violations: Report to the general violations channel.

Data Protection Rights:

THE OWNER’s Internal Information System complies with data protection regulations, ensuring the confidentiality of both the informant and the person affected. Personal data contained in the reports or during investigations will remain strictly confidential and accessible only to:

• The Responsible Officer for the Internal Information System and its manager.

• The Human Resources Manager.

• The Data Protection Security Officer.

• Data processors if the system is outsourced in whole or in part.

However, data may be accessed or disclosed to others if necessary for corrective measures or legal or disciplinary procedures.

Data Processing Information:

• Controller: THE OWNER (MZL REAL ESTATE S.L.), Tax ID: B75421990, Address: Valentuñana, 2, 7ºdcha, 29601 Marbella.

• Purpose: To manage communications made by informants and investigate reported incidents that may constitute violations of EU law, criminal or administrative offenses, anti-money laundering regulations, internal rules, workplace health, safety, harassment, equality, or data protection breaches.

• Legal Basis: Legal obligation under Articles 6.1(c) of Regulation (EU) 2016/679, Article 8 of Organic Law 3/2018, December 5, Organic Law 7/2021, May 26, and Article 10 of Law 2/2023, February 20.

• Recipients: Data may be disclosed only if legally required, such as to law enforcement, judicial authorities, or relevant public administration.

• Retention Period: Reports and personal data will be retained for up to three months, extendable by three more months if the investigation requires, for a total of six months. After this period, the data will be locked for evidentiary purposes as required by law. Anonymous reports will be recorded only in an anonymized form.

Rights of the Data Subject:

The informant may exercise their rights to access, delete, rectify, object, restrict, and request data portability or withdraw consent by contacting the Data Protection Security Officer via email at info@streetandpartners.com. They may also file a complaint with the Spanish Data Protection Agency (www.aepd.es).

External Reporting Channel:

Informants may also report directly to the Independent Authority for Whistleblower Protection (A.I.I.), which manages the external reporting channel.

If the Independent Whistleblower Protection Authority has not been established in Madrid, informants may use the reporting channel provided by the Madrid Community: Canal del Informante, accessible via this link: Canal del Informante.

Informants can also contact law enforcement agencies (e.g., National Police, Civil Guard, Municipal Police) or the relevant judicial authority.