1. PRIVACY AND DATA PROTECTION POLICY

In accordance with the provisions of current legislation, Namarauto (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 collected data.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data online. Specifically, it adheres to the following standards:

• 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 Regulations 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 personal data controller

The data controller responsible for the personal data collected at Namarauto is: GRUPO ORMEMOTOR S.L., provided with Tax Identification Number (NIF/CIF): B93218105. The contact details are as follows:

Address: Calle Dublín, 2, Marbella, 29670, Málaga.

Contact telephone: +34 952 780 771

Contact email: caorza@caorza.com

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Namarauto through the forms provided on its pages will be incorporated into and processed in our file in order to facilitate, expedite, and fulfill the commitments established between Namarauto and the User, or to maintain the relationship established through the forms completed by the User, or to address an inquiry or request from the User. Furthermore, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained detailing, according to its 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 forth in Article 5 of the GDPR and Article 4 et seq. 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 will be required at all times following fully transparent information regarding the purposes for which personal data is collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit, and legitimate purposes.
• Principle of data minimization: personal data collected will be strictly limited to what is necessary in relation to the purposes for which it is processed.
• Principle of accuracy: personal data must be accurate and kept up to date at all times.
• Principle of storage limitation: personal data will only be retained in a form that permits identification of the User for no longer than necessary for the purposes of its processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures appropriate security and confidentiality.
• Principle of proactive accountability: the Data Controller will be responsible for ensuring compliance with the principles above.

Categories of personal data

The categories of data processed at Namarauto consist exclusively of identification data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for personal data processing

The legal basis for the processing of personal data is consent. Namarauto 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 has the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.

Whenever the User is required or able to provide their data through forms to submit inquiries, request information, or for reasons related to the content of the Website, they will be informed if completing any of them is mandatory because the data is strictly necessary for the proper execution of the requested operation.

Purposes of personal data processing

Personal data is collected and managed by Namarauto in order to facilitate, expedite, and fulfill the commitments established between the Website and the User, to maintain the relationship established in the forms filled out by the User, or to address a request or inquiry.

Likewise, data may be used for commercial purposes such as personalization, operational and statistical analysis, and activities inherent to Namarauto's corporate purpose, as well as for data extraction, data storage, and marketing studies to tailor the Content offered to the User, and to enhance the quality, performance, and navigation of the Website.

At the time personal data is collected, the User will be informed about the specific purpose or purposes for which the personal data will be processed; that is, the intended use or uses of the collected information.

Personal data retention periods

Personal data will only be retained for the minimum period necessary for the purposes of its processing or until the User requests its deletion.

At the time personal data is collected, the User will be informed about the period for which the personal data will be retained or, where 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:

In the event that the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed at the time the personal data is collected about 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 European Commission.

Personal data of minors

In compliance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only persons over 14 years of age may lawfully give their consent for the processing of their personal data by Namarauto. If the user is under 14 years of age, the consent of parents or legal guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.

Security and confidentiality of personal data

Namarauto undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, to ensure the security of personal data and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

However, as Namarauto cannot guarantee the invulnerability of the internet nor the complete absence of hackers or other parties fraudulently accessing personal data, the Data Controller undertakes to notify the User without undue delay whenever a personal data breach 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 ensure, through legal or contractual obligations, that such confidentiality is respected by its employees, associates, and any person granted access to the information.

Rights arising from personal data processing

The User has the following rights recognized under the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, and may therefore exercise them against the Data Controller at Namarauto:

• Right of access: This is the User's right to obtain confirmation as to whether or not Namarauto is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Namarauto has carried out or is carrying out, as well as, among other things, the information available regarding the origin of such data and the recipients of any communications made or planned for them.
• Right to rectification: This is the User's right to have their personal data modified should it prove to be 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 establish 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; when the User has withdrawn their consent to the processing and there is no other legal basis; when the User objects to the processing and there is no other legitimate reason to continue with it; when the personal data has been unlawfully processed; when the personal data must be erased in compliance with a legal obligation; or when 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 available technology and the cost of implementation, must take reasonable steps to inform any controllers processing the personal data of the data subject's request to erase any links to that personal data.
• Right to restriction of processing: This is the User's right to restrict the processing of their personal data. The User has the right to obtain the 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: Where 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 data controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.
• Right to object: This is the User's right not to have their personal data processed, or to have Namarauto cease the processing thereof.
• Right not to be subject to automated individual decision-making, including profiling: This is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Therefore, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference "GDPR-www.namarauto.com", specifying:

• Name, surname(s) of the User, and a copy of their National Identity Document (DNI/ID). In cases where representation is permitted, identification by the same means of the person representing the User will also be required, along with the document proving such representation. The photocopy of the ID document may be replaced by any other legally valid means that proves identity.
• Request with the specific reasons for the application or the information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request made.

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

Postal address: Calle Dublín, 2, Marbella, 29670, Málaga.

Email: caorza@caorza.com

Links to third-party websites

The Website may include hyperlinks or links that provide access to web pages of third parties other than Namarauto, and which are therefore not operated by Namarauto. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

Should the User consider that there is a problem or breach of current regulations regarding 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 in which 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/).

1. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agree with the conditions on personal data protection 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, for the periods, and for the purposes indicated. Use of the Website will imply acceptance of its Privacy Policy.

Namarauto reserves the right to modify its Privacy Policy according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to check this page periodically to keep abreast of the latest changes or updates.

This Privacy Policy has been 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 with Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).