Privacy policy regarding the processing of data of the external freelance real estate consultant

INTRODUCTION

The protection of personal data is one of the values of EV MMC SPAIN, S.L.U. (Engel & Völkers). Compliance with the applicable personal data protection regulations is a priority objective for us.

The purpose of this policy is to explain to you how we will process the personal data that you provide to us through the various forms and other channels for the entry of personal data in connection with the conclusion of the commercial contract as a self-employed real estate consultant.

1. DATA CONTROLLER

2. PURPOSES AND BASIS OF LEGITIMACY

3. COMMUNICATION OF DATA

4. AUTOMATED DECISIONS AND PROFILING

5. INTERNATIONAL TRANSFERS

6. DURATION OF PROCESSING

7. EXERCISE OF RIGHTS

8. CONFIDENTIALITY AND SECURITY IN DATA PROCESSING

1. DATA CONTROLLER

The controller of the processing of your personal data is the company:

• Company name: EV MMC SPAIN, S.L.U.

• Address: Avda. Diagonal, 640, 6 planta, B, 08017, Barcelona

• Data protection officer: Ms Stefanie Wegener, Mittelweg, 10, 20148, Hamburg, (Germany), tel. +49 040 22697524, swegener@wegener-ra.de.

2. PURPOSES AND BASIS OF LEGITIMACY

The data will be processed for the purpose of processing the formalities associated with the conclusion of the business contract and the subsequent duration of the contractual relationship.

Phase prior to the conclusion of the business contract. The purpose of the processing in this phase will be limited to identifying the professional skills and previous experience of the person considering the object of the real estate brokerage contract, all within the framework of article 19 of the LOPDGDD.

We may process the following categories of data at this stage: first and last name, telephone number, e-mail address, tax address, professional experience, opinion of the evaluators, among others.

In this regard, the collection of this data in this preliminary phase is essential for the eventual recruitment. You are therefore informed that if you do not provide them, provide them incompletely, object to their processing or request their deletion, the commercial contract cannot be concluded.

Contracting phase. In this phase, Engel & Völkers will process your personal data collected on the basis of the execution of pre-contractual measures in order to formalise all necessary steps for your contract. In addition, we may process your data on the basis of legitimate interest, in accordance with the provisions of article 19 of the LOPDGDD.

The personal data that we may process in this phase are: first and last name, telephone number, email address, tax address, ID number, contract data, among others.

Contractual relationship phase. In order to manage the maintenance of the contractual relationship, we may carry out operations relating to the management of opportunities or settlement of commissions, among others.

The basis of legitimacy that supports such management is the execution of the contract that we have formalised with you, as well as the legitimate interest under the provisions of Article 19 of the LOPDGDD.

The personal data that we will process in this phase are those necessary for the maintenance of the contractual relationship with the consultant.

Post-contractual phase. Once the contractual relationship has ended, we will keep your data duly blocked before destroying them, on the basis of a legal obligation. Likewise, article 19 of the LOPDGDD enables us to process your data in this phase on the basis of legitimate interest.

The personal data we will process at this stage will be the data we have collected to date, as well as the data necessary to make or respond to complaints.

3. COMMUNICATION OF DATA

Your data will not be given, sold, rented or otherwise made available to any third party, except to those service providers of the company, who carry out certain activities on our behalf, but who will not process the data for their own purposes. Some of these service providers may be located outside the European Union, as indicated in the "International transfers" section of this text.

Engel&Völkers may be assisted by external business partners in the phase prior to the conclusion of the business contract

In the second phase of the contractual relationship, we may disclose the contact details of the consultants to persons interested in selling, buying or renting real estate or their representatives or third parties involved in the conveyancing process, on the basis of the execution of the contract.

4. INTERNATIONAL TRANSFERS

The company, as part of an international group, has international suppliers who may provide their services from outside the European Economic Area (EEA), so it is possible that your data may be processed outside the EEA (e.g. the provider sending newsletters, storing data, handling requests for information, etc.).

In any case, the company will ensure that such data processing is always protected by appropriate safeguards, which may include, among others, the signing of EU-approved Standard Contractual Clauses in force: These are contracts approved by the European regulator and which provide sufficient guarantees to ensure that the processing complies with the requirements set out in the European Data Protection Regulation.

5. DURATION OF PROCESSING

In the event that the pre-contract phase is terminated without the conclusion of a commercial service contract, Engel&Völkers will destroy all documents containing personal data, unless you consent to their retention for future cooperation.

Documents containing personal data of self-employed real estate consultants will be retained for the period of time strictly necessary to achieve the purposes of the processing, without prejudice to their retention for the purpose of making them available to the competent authorities and for the purpose of dealing with complaints. In this case, the data will be kept blocked until the end of the limitation period, at which time they will be deleted.

You are also informed that the company may keep your data duly anonymised for statistical purposes, whenever possible, without prejudice to the appropriate blocking in order to comply with any applicable legal obligations.

6. EXERCISE OF YOUR RIGHTS

The regulations in force grant you the following rights:

• Right of access: You shall have the right to know what personal data we process in relation to your person.

• Right of rectification: You shall have the right to be able to rectify or complete any data that is inaccurate or incomplete.

• Right of erasure: You may request that your personal data be deleted from our systems and files.

• Right to object: You may object to the processing of your data in connection with direct marketing actions. As well as for personal reasons, unless the basis for the processing is legitimate interest.

• Right to restrict processing: You may request the restriction of processing where you contest its accuracy or where it is unlawful and you object to the erasure of your personal data and request instead the restriction of its use. Also when the data are no longer necessary for processing, but you need them for the formulation, exercise or defence of claims. And finally, when you have objected to the processing, while it is being verified whether the legitimate interest of the controller prevails over that of the data subject.

• Right to data portability: You have the right to obtain a copy of all the data you have provided to us and where technically possible, you have the right to request that your personal data be communicated to another data controller.

You may exercise these rights free of charge, as well as withdraw your consent at any time, by contacting our company by any of the following means:

• By post: addressed to the Head of the Recruitment Department.

• By e-mail which should be sent to the following address:.

In the case of sending by e-mail or post, you must identify the message with the reference "Data Protection".

We also inform you that, should we have any doubts as to the identity of the applicant, we may request a copy of your National Identity Card in order to verify your identity and be able to process your request to exercise your rights.

In the event that you need to make a query or suggestion in relation to the processing of your personal data, you may also contact us at the addresses provided for the exercise of your rights.

If you have any questions about this privacy policy and data protection, you can contact the Engel&Völkers Group's data protection officer at any of the following addresses:

• By post: Dr. Stefanie Wegener, Mittelweg, 10, 20148, Hamburg, Germany

• By e-mail to be sent to the following address swegener@wegener-ra.de.

• By telephone: +49 040 22697524

The duties of the Data Protection Officer are as follows:

• Informing and advising the controller of their obligations under the General Data Protection Regulation (GDPR) and other data protection provisions;

• Monitoring compliance with the GDPR, other data protection provisions and the Controller's policies on personal data protection, including the allocation of responsibilities, awareness-raising and training of staff involved in processing operations, and related audits;

• Providing advice on request on the data protection impact assessment and monitoring its implementation;

• Cooperate with the Data Protection Agency;

• Act as a point of contact for the Data Protection Agency for matters relating to processing, including prior consultation.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), www.aepd.esthe competent data protection authority in Spain, if you consider that your data have not been processed correctly.

7. CONFIDENTIALITY AND SECURITY IN DATA PROCESSING

The data received by Engel&Völkers will be treated with the utmost confidentiality and secrecy. Engel&Völkers has established all the technical and organisational means at its disposal to prevent the loss, misuse, alteration, unauthorised access or copying of the data provided.