Privacy Policy of the Website https://tomasrussi.com/

I. PRIVACY POLICY AND DATA PROTECTION Respecting the provisions of current legislation, Tomas Russi (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security to the risk of the data collected.

Laws incorporated into this privacy policy This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it respects the following rules:

Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of this 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, which approves the Regulation for the development of 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 data controller for the personal data collected at Tomas Russi is: [name], with Tax ID: 60089623F (hereinafter, Data Controller). Their contact details are as follows:

Address: Romans 41, Principal 1. Barcelona, 08025

Contact phone: 612576918

Contact email: russi.tomas@gmail.com

Registry of Personal Data In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Tomas Russi through the forms on its pages will be incorporated and treated in our file in order to facilitate, expedite, and fulfill the commitments established between Tomas Russi and the User, or the maintenance of the relationship established in the forms that the latter fills out, or to attend to a request or query from the same. 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 will 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 legality, loyalty, and transparency: the User’s consent will be required at all times after prior transparent information on the purposes for which the personal data are collected. Principle of purpose limitation: personal data will be collected for specific, explicit, and legitimate purposes. Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed. Principle of accuracy: personal data must be accurate and always kept up to date. Principle of storage limitation: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its processing. Principle of integrity and confidentiality: personal data will be processed in such a way as to ensure its security and confidentiality. Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with. Categories of personal data The categories of data processed at Tomas Russi are only identifying data. In no case 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. Tomas Russi 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 will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawal of consent will not condition 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 filling them out is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing to which the personal data are intended Personal data are collected and managed by Tomas Russi for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or the maintenance of the relationship established in the forms filled out by the latter, or to attend to a request or query.

Likewise, the data may be used for a commercial purpose of personalization, operation, and statistics, and activities inherent to the social object of Tomas Russi, 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, functioning, and navigation of the Website.

At the time the personal data are obtained, the User will be informed about the specific purpose(s) of the processing to which the personal data will be destined; that is, the use or uses that will be given to the collected information.

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

At the time the personal data are obtained, the User will be informed about the period during which the personal data will be retained or, when this is not possible, the criteria used to determine this period.

Recipients of personal data The User’s personal data will not be shared with third parties.

In any case, at the time the personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors Respecting 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 to the processing of their personal data lawfully by Tomas Russi. If the individual is under 14 years of age, the consent of their parents or guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data Tomas Russi undertakes to adopt the necessary technical and organizational measures, according to the appropriate level of security to the risk of the data collected, to ensure the security of personal data and to prevent their destruction, loss, or alteration, whether accidental or unlawful, of personal data transmitted, stored, or processed in any other way, or unauthorized access or disclosure of such data.

The Website has an SSL certificate (Secure Socket Layer), 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 Tomas Russi 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 promptly notify the User in the event of an undue delay in the event of a breach of the security of personal data that is likely to pose a high risk to the rights and freedoms of individuals. Pursuant to Article 4 of the GDPR, a breach of the security of personal data is understood to be any breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure 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, 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 available.

Rights derived from the processing of personal data The User has the following rights over Tomas Russi and may, therefore, exercise them against the Data Controller as recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

Right of access: It is the User’s right to obtain confirmation from Tomas Russi as to whether or not their personal data is being processed and, if so, to obtain information about their specific personal data and the processing that Tomas Russi has carried out or is carrying out, as well as, among others, the available information on the origin of such data and the recipients of the communications made or planned regarding them. Right to rectification: It is the User’s right to have their personal data modified if they are inaccurate or, taking into account the purposes of the processing, incomplete. Right to erasure (“right to be forgotten”): It is the User’s right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; 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 in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child 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 measures to inform the controllers who are processing the personal data of the interested party’s request to erase any link to that personal data. Right to restriction of processing: It is the User’s right to restrict 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: If 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 them to another controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller. Right to object: It is the User’s right to oppose the processing of their personal data or to cease the processing thereof by Tomas Russi. Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, except where current legislation provides otherwise. Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-https://tomasrussi.com/“, specifying:

Name, surname of the User, and copy of the ID card. In cases where representation is admitted, the identification by the same means of the person representing the User, as well as the accrediting document of the representation, will also be necessary. The photocopy of the ID card may be replaced by any other valid means of law that certifies the identity. Request with the specific reasons for the request or the information to which you want to access. Address for notification purposes. Date and signature of the applicant. Any document proving the request made. This request and any other attached document may be sent to the following address and/or email:

Postal address: Romans 41, Principal 1. Barcelona, 08025

Email: russi.tomas@gmail.com

Links to third party websites The Website may include hyperlinks or links that allow access to third-party websites other than Tomas Russi, and therefore are not operated by Tomas Russi. 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 If the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will 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 (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES IN 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 can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Tomas Russi 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. It is recommended that the User 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 April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of this data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

This website’s Privacy Policy document was created using the online privacy policy template generator on 01/07/2021.