PRIVACY POLICY

At Habber Tec, S.L. (hereinafter, the “Controller” or “Habber Tec”), we wish to provide you with all the details of how we process the personal data you provide when interacting with us. Accordingly, this privacy policy applies to all persons who provide or have provided us with personal data by any means, specifically where this policy is referred to, including in a form, on this website itself, etc.

Below, we inform you about our Privacy Policy, bearing in mind that safeguarding the privacy of the personal data of our customers and users of our services is an essential value for us. In accordance with both 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, and repealing Directive 95/46/EC (General Data Protection Regulation), and Organic Law 3/2018 of 5 December on Personal Data Protection and the guarantee of digital rights, the following is detailed information about the processing of your personal data:

HOW WE TREAT YOUR PERSONAL DATA

Identity of the data controller

• Name: Habber Tec, S.L.
• Registered office: Caleruega, 81 – 1º B, 28033 Madrid, Spain.
• Tax Identification Number (NIF): B-81739781
• Contact email for our data protection officer: protecciondedatos@habber.com

Purposes of processing

Below we indicate the purposes for which your personal data may be processed:

• Managing enquiries and applications for registration at events organised by Habber Tec or collaborating third parties, which may take place in person or remotely.
• Managing requests and contact made through the various forms and contact channels provided for this purpose on the website.
• Receiving CVs from candidates interested in vacancies advertised through the website.

• The management, administration, provision and improvement of our services, as well as the maintenance and improvement of our website.
• Sending newsletters about our products or services which we consider may be of interest to you.
• Communications for purely administrative or internal organisational purposes with other companies in our group, located in Portugal:

• • HABBER TEC PORTUGAL SA – PT508542855Av. Miguel Bombarda, 36 31050-165 LisboaPORTUGAL

Legal basis for processing

The legal basis for processing your data will depend on the purpose for which the personal data is processed:

1. With regard to managing enquiries and requests received through our forms (including managing requests to attend events), as well as managing, administering and improving our services – through the installation of cookies on the device – and sending newsletters, we will process your personal data if you have given your express, freely given and unequivocal consent, in accordance with Article 6(1)(a) GDPR.

2. With regard to requests relating to our products, and the management of CVs received in response to vacancies advertised on the website, the processing of personal data will be based on the implementation of pre-contractual measures (Article 6(1)(b) GDPR).

3. Lastly, regarding communications to other entities in our group, this processing will be based on Habber Tec’s legitimate interest, for purely administrative, internal management and financial purposes, in accordance with Articles 6(1)(f) GDPR and 19 LOPDGDD.

The data we request is adequate, relevant and strictly necessary to fulfil the purposes described. For your part, you must guarantee the authenticity, accuracy and truthfulness of all information you provide, undertaking to keep the data updated so that it reflects your actual circumstances at all times.

WHAT DO WE TREAT YOUR DATA FOR

To whom do we disclose your data?

• Your personal data may be disclosed to public authorities if we must comply with a legal obligation or receive a request from those authorities.
• We may also disclose it to the companies related to us indicated above for the administrative and financial control and management of Habber Tec and the other associated entities, or for sending newsletters where expressly consented to, or to effectively manage attendance at events organised by those third-party entities.
• Finally, we inform you that the above disclosures of data may entail transfers of data to third countries, whether or not they offer protection equivalent to that guaranteed by us. Nevertheless, we wish to inform you that we have signed the corresponding document governing this access to data with all these third parties, which regulates the adoption of sufficient security measures to guarantee your right to the protection of personal data. In any case, we remain at your disposal to clarify any questions regarding the processing of your data by us or by these third parties.

TO WHOM WE COMMUNICATE YOUR DATA

We do not transfer your personal data to anyone. We will only communicate them when we are obliged by a law or when you have previously given us your express authorization. However, in case your data must be communicated, we will use all the means at our disposal to provide you with all the information in this regard.

In order to provide our services we need to work with companies that process your data on our behalf (hosting providers, email providers, etc.), as part of the provision of a service that we have contracted with them, with whom we sign the corresponding management contracts. treatment and we require them to comply with the regulations on personal data.

FOR HOW LONG DO WE KEEP YOUR DATA

How long will we retain your data?

We will retain the data for as long as necessary to fulfil the purpose for which it was collected, to ensure provision of the service and to comply with our legal obligations.

• Specifically, for processing purposes based on the user’s consent, we will retain the data until that consent is withdrawn or until the data is no longer necessary to fulfil the processing purpose.
• Furthermore, with regard to data processed on the basis of pre-contractual measures:
• Regarding requests for information about our products, if a service provision agreement is ultimately not concluded, the data will be retained for the time necessary to fulfil the purpose for which it was collected.
• If the product is subsequently contracted, the retention period will correspond to the contractual obligations and needs of which Habber Tec will provide information at the time of contracting.
• CVs received from candidates who are not selected will be retained for one year from receipt.
• Data processed on the basis of Habber Tec’s legitimate interest for administrative or internal management purposes will be retained for the time necessary to fulfil the processing purpose, while the relationship between Habber Tec and the data subject remains active.

Once the retention period indicated above has elapsed, following deletion using the appropriate security measures, we will keep the data duly blocked for the indispensable period under the legislation applicable in each case, in order to respond to possible future claims and defend our interests.

You may unsubscribe from the newsletter, if you have subscribed, at any time via the link provided for that purpose in the newsletter itself, or by emailing protecciondedatos@habber.com

HOW WE CUSTODIZE YOUR DATA

How does Habber Tec safeguard your data?

Habber Tec undertakes to adopt the security measures necessary to prevent its modification, alteration, loss, unauthorised processing or access, in accordance with the GDPR.

Habber Tec guarantees that it has implemented appropriate technical and organisational policies to apply the security measures established by the GDPR and LOPDGDD in order to protect users’ rights and freedoms, and has provided them with the appropriate information so that they may exercise those rights.

Habber Tec recognises and takes very seriously its responsibility to protect your personal data. We therefore maintain personal data protection security levels in accordance with the GDPR and have established all technical means available to us to prevent the loss, misuse, alteration, unauthorised access and theft of the data you have provided, while informing you that Internet security measures are not 100% impregnable. Furthermore, Habber Tec holds ISO 27001 certification for the purpose of ensuring compliance with information security requirements.

HOW CAN YOU CONTROL THE MANAGEMENT OF YOUR DATA

How can you manage the processing of your data?

You may exercise your rights of access, rectification, erasure and objection, as well as restriction and portability, by emailing protecciondedatos@habber.com and indicating what action you request from us.

The exercise of all these rights is free of charge and, in the interests of greater transparency, we provide further information about these rights:

You may also exercise your rights vis-à-vis the entities receiving your personal data of which we have previously informed you, by contacting those entities directly.

We also inform you that you have the right to lodge a complaint with the Spanish Data Protection Agency at www.aepd.es. However, given our strong commitment to privacy, we invite you to contact us directly to resolve any matter relating to your personal data; we will be pleased to assist you.www.aepd.es

MODIFICATION OF THE PRIVACY POLICY

Amendment of this personal data policy

Habber Tec reserves the right to amend this policy to adapt it to future legislative or case-law developments, as well as industry practices, informing users beforehand through our website. We recommend that you consult this page reasonably frequently to review the latest version. The date of the last update is indicated at the bottom of this document.

The new privacy notice will take effect upon publication. If you do not accept amendments to the new notice, you may exercise any of your rights or stop using our service. If you continue to access or use our services after those amendments take effect, you agree to be bound by the new privacy policies.

Under no circumstances will such amendments affect the choice you have made as to how Habber Tec may process your personal data. If at any time we wish to use your data for a purpose other than that established at the time of collection, we will notify you by email and request your consent.

Habber Tec also reserves the right to terminate the services it provides to users who do not comply with the legal terms and conditions of use or with the legislation in force.

Last amended in October 2026