Privacy policy extended

1-WHO IS THE DATA CONTROLLER OF YOUR DATA PROCESSING?

The Data Controller and the owner of the website http://www.meridiarealestateiiisocimi.com is Meridia Real Estate III Socimi, S.A. is a Socimi (Spanish REIT) with registered office is at 640 Diagonal Avenue, Floor 5  08017-Barcelona, with tax identification number A66696741, registered in the commercial registry of Barcelona volume 46607, page 78, sheet B 480472,

+34 93 484 15 00

protecciondedatos@meridiacapital.com

2-WHICH IS THE PURPOSE OF YOUR PERSONAL DATA PROCESSING?

In MERIDIA REAL ESTATE III SOCIMI, S.A., we use your personal data collected when you contact us to request for information, to provide you information about our services or products, manage, internally and externally, the services or purchases you make to us, as well as comply with the mandatory legal provisions derived from these activities.

Likewise, the data collected during your browsing are processed to provide access to the online contents of the web, as well as to attend to the requests of the users of the web, keeping a record of users statistics (IP addresses, data of the browser, country, accessed page, etc.) for statistical purposes or apply measures aimed at improving web security.

3-WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA?

The legal basis for the processing of your personal data is:

  • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract.
  • Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.
  • Legitimate interests: we shall process information about you where it is in our legitimate interest in running a lawful business to do so in order to run that business, so long as it doesn’t outweigh your interests.
  • Your express consent: in some cases, we would ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Meridia Real Estate III Socimi, S.A. at protecciondedatos@meridiacapital.com.

The legal basis for the processing of the personal data of the suppliers is based on the contractual relationship that is generated when we contract with them. The legal basis for the processing of the data of our employees is based on the employment relationship.

Curriculum Vitae (CV)

We inform you that in accordance with the provisions of the personal data protection regulations in case you send your CV to Meridia Real Estate III Socimi, S.A., which is understood as any of the investee companies, managed or advised by Meridia Real Estate III Socimi, S.A., it will be stored and processed in order to participate in the Staff selection processes carried out by us. The legal basis that legitimizes our processing is your expressed consent by voluntarily sending us your CV.

Likewise, we inform you that your CV shall be erased, and we shall not keep any copies, in case your profile does not match any of the positions offered by the Company. If your profile could potentially be interesting for the Company, your CV will be retained for a maximum period of two years for future Staff selection processes. After this period has elapsed without being selected for any process, it shall be erased, and we shall not keep a copy or keep any of your personal data.

4. DATA RETENTION. ¿How long shall we keep your personal data?

The personal data you provide us shall be kept for the time necessary to manage the information you request, or as long as there are contractual obligations deriving from services or content requested by users and subsequently until the expiration of legal, contractual or professional responsibilities that require its retention.

Once the data has met the needs for which it was collected, we will delete it permanently. However, we will keep your data longer, if necessary, to comply with legal obligations. Likewise, it may be necessary to keep them for the time necessary until the prescription of the legal responsibilities that are generated.

5. DATA RECIPIENTS

Your Personal Data will be processed by duly authorized personnel, and, if necessary or practical to fulfill the purposes indicated above, they may be processed, in certain cases, by third parties.

The categories of recipients to whom your Personal Data may be communicated are the following:

a. Data processors, such as IT providers, consultants, and other companies.

b. Public entities and Authorities, exclusively for the purpose of complying with legal and regulatory obligations, as well as the requirements of the police authorities if requested.

c. Other suppliers to whom, where appropriate, your personal data may be transferred, when is necessary for our normal operation, as financial institutions, and insurers, among others.

d. Investee Companies managed or advised by Meridia Capital or with its same control partner, for operational reasons.

All of them are subject to the duty of professional secrecy.

6.  RIGHTS ¿what are your rights when you provide us with your data?

If you wish to exercise the rights that the data protection regulations grant you, please send us an e-mail to the following address protecciondedatos@meridiacapital.com  putting in the subject the right you want to exercise and attaching a copy of your national identity document or passport or by sending the same content by postal mail to MERIDIA REAL ESTATE III SOCIMI, S.A., Avenida Diagonal, 640, 5th Floor 08017 - BARCELONA.

The Rights that the current regulations recognize and that, where appropriate, may be exercised are:

Right of access to data:

You have the right to be informed by the Data Controller if your personal data is being processed or not, and if the process is confirmed, you shall be able to access it by providing the following information:

  • The purposes of processing.
  • The categories of data.
  • The term or criteria for data retention.

Right to rectification:

You will have the right to request the Data Controller to rectify your data when they are inaccurate or incomplete by means of an additional rectifying statement.

Right of Erasure:

The data subject will have the right to request the Data Controller to erase its data, when:

  • The processing is illegal.
  • The data subject has withdrawn its consent.
  • They are no longer necessary in relation to the purposes for which they were collected or processed.
  • The data subject has exercised the right of opposition and other legitimate reasons for the processing do not prevail.
  • The data must be erased to fulfill a legal obligation of the Data Controller.

The data subject will not have the right to request the Data Controller to erase their data when the processing is necessary:

  • To exercise the right to freedom of expression and information.
  • To fulfill a legal obligation of the Data Controller.
  • For the preparation, exercise or defense of claims.
  • For public interest based on current legislation for public health reasons or for historical, statistical or scientific research purposes.

Right to data portability:

You have the right to request the Data Controller to transfer your data to another Data Controller or to the same data subject, through a structured format of usual use and mechanical reading, when the processing is carried out by automated means and is based on:

  • The consent of the data subject for specific purposes.
  • The execution of a contract or pre-contract with the data subject.

The right to data portability will not apply when:

  • The transmission is technically impossible.
  • It can negatively affect the rights and freedoms of third parties.
  • The processing has a public interest mission based on current legislation.

Right to restriction of processing:

1.The data subject shall have the right to obtain from the Data Controller restriction of    processing where one of the following applies:

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the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data;

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the processing is unlawful, and the data subject opposes the erase of the personal data and requests the restriction of their use instead;

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the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;

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the data subject has objected to processing, pending the verification whether the legitimate grounds of the Data Controller override those of the data subject.

2.   Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

3.   A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Data Controller before the restriction of processing is lifted.

Right of opposition:

The data subject shall have the right to object to processing of personal data, on grounds relating to his or her situation, at any time. The Data Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Right not to be subject to profiling:

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, mainly when is referred to the following personal aspects:

  • -Professional performance.
  • -Economic situation.
  • -Health.
  • -Preferences or personal interests.
  • -Reliability.
  • -Behavior.
  • -Location or movements of the person.

When profiling is based solely on automated processing:

  • -The data subject will have the right to be informed if the decision that can be taken could have legal effects that significantly affect him.
  • -The data subject will have the right to obtain human intervention from the Data Controller, to express their point of view and to challenge the decision, if the processing has been authorized by:
  • -The explicit consent of the data subject.
  •  -A contract between the Responsible and the data subject.

This right shall not apply if the decision:

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is necessary for entering, or for the performance of, a contract between the data subject and the Data Controller;

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is authorized by European Union or Member State law to which the Data Controller is subject, and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or

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is based on the data subject's explicit consent.

If you consider that MERIDIA REAL ESTATE III SOCIMI, S.A. has violated any of your rights protected by the personal data protection regulations or that it has violated any obligation regarding the protection of Personal Data, you have the right to submit a claim to the competent Supervisory Authority which in Spain is the Spanish Agency for Data Protection located at Calle Jorge Juan, 6. 28001 - Madrid. Tel. 901 100 099 - 912 663 517

You can also submit an electronic claim through the electronic address that is available on their website https://www.aepd.es/

8. GOVERNING LAW AND JURISDICTION

This privacy policy is governed in each and every one of its aspects by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons in regard to the processing of personal data and the free circulation of this data.

It is also governed by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights. Likewise, our website is governed by Law 34/2002, of July 11, on Information Society and Electronic Commerce Services.

Any dispute arising from matters relating to our Website shall be exclusively subject to the jurisdiction of the courts of the city of Barcelona.

9. DATA PROTECTION OFFICER

MERIDIA REAL ESTATE III SOCIMI, S.A.  has a Data Protection Officer that will perform the following functions:

• Inform and advise MERIDIA REAL ESTATE III SOCIMI, S.A. on the obligations that it must carry out to comply with the data protection regulations.

• Supervise that the suppliers of MERIDIA REAL ESTATE III SOCIMI, S.A. comply with what is required in the contracts of the person in charge of processing and ultimately with the regulations for the protection of personal data.

• Supervise the application at MERIDIA REAL ESTATE III SOCIMI, S.A. of the data protection regulations.

• Ensure the correct preservation of documentation related to the protection of personal data.

• Supervise documentation, notification and communication of personal data violations or security breaches.

• Act as a point of contact with the control authority of each country in which MERIDIA REAL ESTATE III SOCIMI, S.A. has a presence on issues related to data processing.

• Supervise the response to the requests of the supervisory authority, as well as cooperate with it when required.

• Offer information or advice to interested parties, regarding data protection.

You can contact our Data protection officer: protecciondedatos@meridiacapital.com

10. ADDITIONAL INFORMATION

SECURITY MEASURES:

The data you provide will be treated confidentially. MERIDIA REAL ESTATE III SOCIMI, S.A. has adopted all the technical and organizational measures and all the necessary levels of protection to guarantee the security in the treatment of the data and avoid its alteration, loss, theft, treatment or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in current regulations.

LANGUAGE

The language applicable to this Privacy Policy is English. Therefore, in case there is any contradiction in any of the versions we could provide in other languages, the English version will prevail.

11. UPDATE

This Privacy Policy was last updated in October 2020 but may be updated at any time. We recommend that you check it every time you access our Website in case it has  suffered alterations.