PRIVACY POLICY OF THE WEBSITE

I. PRIVACY AND DATA PROTECTION POLICY Respecting the provisions of current legislation, MASSAGES MARBELLA BY SUSAN (hereinafter, also 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 the current Spanish and European regulations on the protection of personal data on the Internet. Specifically, it complies with the following rules:

The 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 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD). Royal Decree 1720/2007 of 21 December approving the Regulation implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD). Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE). Identity of the data controller The data controller for the personal data collected on MASSAGES MARBELLA BY SUSAN is: xxxnombretitularxxx, with NIF: (hereinafter, the «Data Controller»). The contact details are as follows:

Address: Urbanización Dama de Noche bloque 1 bajo i

Contact phone number: 676 029 814

Contact email: info@massagemarbellabysusan.com

Registration of Personal Data In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by MASAJISTA MARBELLA SUSAN through the forms on its pages will be incorporated and processed in our file in order to facilitate, streamline, and fulfill the commitments established between MASSAGES MARBELLA BY SUSAN and the User, or the maintenance of the relationship established in the forms that the User fills out, or to attend to a request or inquiry from the User. 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 register of processing activities specifying, according to their purposes, the processing activities carried out and the other circumstances set out in the GDPR, is maintained.

Principles applicable to the processing of personal data The processing of the User’s personal data will be subject to the principles set out in Article 5 of the GDPR and in Articles 4 and following of Organic Law 3/2018 of 5 December 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 prior to completely transparent information on the purposes for which the personal data are collected. Principle of purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes. Principle of data minimization: The personal data collected will be strictly necessary in relation to the purposes for which they are processed. Principle of accuracy: Personal data must be accurate and kept up to date. Principle of storage limitation: Personal data will be kept for no longer than is necessary for the purposes of the processing. Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures appropriate security and confidentiality. Principle of proactive responsibility: The Data Controller will be responsible for ensuring compliance with the above principles. Categories of personal data The categories of data processed at MASSAGES MARBELLA BY SUSAN are solely identifying data. Under no circumstances 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. MASSAGES MARBELLA BY SUSAN 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 will be as easy as giving it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must 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 out any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing of personal data Personal data is collected and managed by MASSAGES MARBELLA BY SUSAN in order to facilitate, streamline, and fulfill the commitments established between the Website and the User, or the maintenance of the relationship established in the forms filled out by the User, or to respond to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operation, statistics, and activities related to the purpose of MASSAGES MARBELLA BY SUSAN, as well as for data extraction, storage, and marketing studies to adapt the Content offered to the User and improve the quality, functionality, and navigation of the Website.

At the time the personal data is obtained, the User will be informed about the specific purpose(s) for which the personal data will be processed, i.e., the use(s) that will be given to the collected information.

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

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be stored, or if that 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 is 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 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only individuals over 14 years of age may provide their consent for the lawful processing of their personal data by MASSAGES MARBELLA BY SUSAN. 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 such consent is given.

Secrecy and security of personal data MASSAGES MARBELLA BY SUSAN undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data, in order to guarantee the security of personal data and prevent its destruction, loss, alteration, or unauthorized access or disclosure of the personal data transmitted, stored, or processed in any other way.

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, as MASSAGES MARBELLA BY SUSAN 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 when a personal data security 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 security breach means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or processed in any other way.

The personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee, by means of a legal or contractual obligation, that confidentiality is respected by its employees, associates, and any person to whom the information is made available.

Rights derived from the processing of personal data The User has the following rights recognized in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, and may therefore exercise them against MASSAGES MARBELLA BY SUSAN as the Data Controller:

Right of access: The right of the User to obtain confirmation as to whether or not MASSAGES MARBELLA BY SUSAN is processing their personal data and, if so, to obtain information about their specific personal data and the processing that MASSAGES MARBELLA BY SUSAN has carried out or is carrying out, as well as, among other things, information about the origin of such data and the recipients of the communications made or planned for such data. Right of rectification: The right of the User to have their personal data modified if it is inaccurate or, considering the purposes of the processing, incomplete. Right to erasure (the «right to be forgotten»): The right of the User, provided that the 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; the User has withdrawn their consent to the processing, and there is no other legal basis for the processing; the User objects to the processing, and there are no overriding legitimate grounds for the processing; the personal data has been unlawfully processed; the personal data must be erased for compliance with a legal obligation; or the personal data has been obtained in relation to the offer of information society services directly 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 implementation, must take reasonable steps to inform other data controllers processing the personal data of the User’s request for the erasure of any links to, or copies or replications of, such personal data. Right to restriction of processing: The right of the User 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 for the establishment, exercise, or defense of legal claims; and the User has objected to the processing. Right to data portability: Where the processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit those data to another data controller. Where technically feasible, the Data Controller will directly transmit the data to the other controller. Right to object: The right of the User to object to the processing of their personal data or to the cessation of processing by MASSAGES MARBELLA BY SUSAN. Right not to be subject to a decision based solely on automated processing, including profiling: The right of the User not to be subject to a decision based solely on automated processing of their personal data, including profiling, unless the current legislation establishes otherwise. Therefore, the User may exercise their rights by written communication addressed to the Data Controller with the reference «GDPR-» specifying:

Name and surname of the User and a copy of their ID. In cases where representation is admitted, the identification of the person representing the User by the same means, as well as the document proving the representation, will also be necessary. The photocopy of the ID may be replaced by any other valid legal means that prove the identity. Request with specific reasons for the request or information to which access is sought. Address for notifications. Date and signature of the applicant. Any document proving the request being made. This request and any attached documents can be sent to the following address and/or email:

Postal address: Urbanización Dama de Noche bloque 1 bajo i

Email: info@massagesmarbellabysusan.com

Links to third-party websites The Website may include hyperlinks or links that allow access to third-party websites other than MASSAGES MARBELLA BY SUSAN and that are therefore not operated by MASSAGES MARBELLA BY SUSAN. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and privacy practices.

Complaints to the supervisory authority If the User considers that there is a problem or infringement of the current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State where they have their habitual residence, place of work, or 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 TO THIS PRIVACY POLICY It is necessary for the User to have read and agree to the conditions regarding 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 implies acceptance of its Privacy Policy.

MASSAGES MARBELLA BY SUSAN reserves the right to modify its Privacy Policy in accordance with 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. It is recommended that the User consult this page periodically to stay informed 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 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 Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.