PRIVACY POLICY

1. DATA CONTROLLER

In compliance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), it is hereby stated that personal data will be processed by:

• Company name: Tempel, S.A.
• Tax ID (CIF): A08526345
• Registered office: C/ Cobalto, 4 – 08097 L’Hospitalet de Llobregat, Barcelona (Spain)
• Email: dataprotection@tempelgroup.com

2. PURPOSES OF THE PROCESSING

The personal data processed correspond mainly to company professionals, clients, suppliers or collaborators, and will be used to manage and respond to requests for information, queries or communications received through the channels provided.

Likewise, the data may be used to maintain, develop and manage the commercial or contractual relationship with the companies to which the interested parties belong, as well as to manage the purchase, sale or supply of products and services offered by Tempel, S.A.

2.1. COMMERCIAL COMMUNICATIONS AND NEWSLETTERS

Tempel, S.A. may send, by electronic or conventional means, commercial communications, newsletters, information about products, promotions, news, events, marketing campaigns, and technical, corporate or commercial content related to its business activity.

Where a prior contractual relationship with the interested party exists, Tempel, S.A. may send commercial communications relating to its own products or services similar to those previously contracted or requested, in accordance with Article 21.2 of Law 34/2002 on Information Society Services and Electronic Commerce (LSSI).

Where no prior contractual relationship exists or where the applicable regulations so require, commercial communications will be sent solely on the basis of the prior, free, specific, informed and unambiguous consent of the interested party.

The data may also be used to carry out satisfaction surveys, loyalty actions, statistical analysis linked to the commercial relationship and improvement of the products and services offered.

The interested party may object at any time to receiving commercial communications or withdraw the consent given, through the unsubscribe link included in each electronic communication or by means of a request addressed to dataprotection@tempelgroup.com, without affecting the lawfulness of the processing carried out prior to such withdrawal.

Likewise, the data may be processed for the purpose of ensuring the correct operation and security of the website, as well as for compliance with the applicable legal obligations.

Certain browsing data may be processed in accordance with the provisions of the Cookie Policy.

3. LEGAL BASIS FOR THE PROCESSING

The processing of personal data is based, mainly, on the performance of contractual or pre-contractual relationships in the professional and business sphere.

Likewise, the processing is based on the duly weighted legitimate interest of Tempel, S.A. in the development of its activity and the management of commercial relationships with companies and professionals.

Where a prior contractual relationship exists, the sending of commercial communications relating to its own products or services similar to those previously contracted or requested will be based on the provisions of Article 21.2 of Law 34/2002 on Information Society Services and Electronic Commerce (LSSI).

In cases where no prior contractual relationship exists or where the applicable regulations so require, the processing will be based on the prior consent of the interested party.

Likewise, certain processing operations may be based on compliance with legal obligations.

No automated decisions or profiling with legal effects on the interested parties are carried out.

Tempel, S.A. has carried out the corresponding legitimate interest balancing analysis, ensuring that the rights and freedoms of the interested parties do not prevail.

4. SOURCE AND TYPES OF DATA

Personal data may be collected through website forms, email communications, commercial or contractual relationships, as well as from publicly accessible sources or from third parties in the professional sphere.

The categories of data processed include identification data, professional contact data, data relating to the company to which the interested party belongs, as well as economic, financial and billing data where necessary for the management of the commercial relationship and compliance with legal obligations.

5. RECRUITMENT PROCESSES

In the event that users submit their curriculum vitae or provide their personal data with the aim of participating in Tempel, S.A. recruitment processes, such data will be processed for the purpose of managing their application and, where applicable, their participation in future recruitment processes in line with their professional profile.

The processing of these data is based on the application of pre-contractual measures at the request of the interested party and, where applicable, on the consent of the interested party.

The data may be retained for the time necessary to manage the recruitment process and, where applicable, for a maximum period of two years for future processes, unless the interested party requests their deletion beforehand.

The data will not be transferred to third parties except by legal obligation, without prejudice to the fact that they may be processed by providers acting as data processors.

The interested party may exercise their rights at any time in accordance with the provisions of this Privacy Policy.

6. RECIPIENTS OF THE DATA

Personal data may be communicated to authorised personnel of Tempel, S.A., as well as, where applicable, to other companies of the Tempel group exclusively for internal administrative and corporate management purposes.

Likewise, they may be processed by service providers acting as data processors, such as providers of technological, IT, logistics or management services, with whom the corresponding contracts are signed in compliance with current regulations.

Likewise, the data may be communicated to Public Administrations, competent authorities, courts and tribunals where required by the applicable regulations.

Under no circumstances will the data be transferred to third parties for commercial purposes.

7. INTERNATIONAL TRANSFERS

As a general rule, personal data will be processed within the European Economic Area.

However, in the event of using providers located outside that area, appropriate safeguards will be adopted in accordance with the GDPR, such as the signing of standard contractual clauses or equivalent mechanisms recognised by European regulations.

8. DATA RETENTION

Personal data will be retained for the time necessary for the development of the commercial or contractual relationship with the company to which the interested party belongs.

Once that relationship has ended, the data will be kept for the periods legally required in commercial, tax and legal liability matters for the fulfilment of legal obligations or the handling of possible liabilities arising from the processing, after which they will be blocked or securely deleted.

In the case of data processed for sending commercial communications or newsletters based on the interested party’s consent, these will be retained while such consent remains valid and is not withdrawn by the interested party.

In the case of commercial communications sent to clients about its own products or services similar to those previously contracted or requested, the data will be processed for that purpose while the commercial relationship is maintained and the interested party does not exercise their right to object.

9. RIGHTS OF THE INTERESTED PARTIES

The persons whose data are processed may exercise their rights of access, rectification, erasure, restriction of processing, objection and portability, as well as withdraw their consent where this constitutes the basis of the processing.

They also have the right to lodge a complaint with the Spanish Data Protection Agency if they consider that the processing does not comply with current regulations, at www.aepd.es.

These rights may be exercised by means of a request addressed to dataprotection@tempelgroup.com or by post to the address indicated, with the identity of the applicant being duly evidenced.

Tempel, S.A. will respond to requests within the periods established by the applicable regulations.

10. NECESSITY OF THE DATA

The data requested are necessary for the correct management of commercial and professional relationships. Refusal to provide them may prevent the adequate development of such relationships or the provision of the services requested.

11. DATA SECURITY

Tempel, S.A. adopts the necessary technical and organisational measures, such as access control, confidentiality, backup and systems monitoring, to guarantee the security, integrity and confidentiality of the personal data processed, preventing their alteration, loss or unauthorised access.

Nevertheless, the user should be aware that security measures on the Internet are not absolutely infallible.

12. LINKS TO THIRD PARTIES AND SOCIAL NETWORKS

The website may contain links to third-party pages, and therefore Tempel, S.A. is not responsible for the privacy policies or the data processing of such sites.

Likewise, the company may have a presence on social networks, where the processing of data will be governed by the conditions of each platform.

13. CHANGES TO THE POLICY

Tempel, S.A. reserves the right to modify this Privacy Policy in order to adapt it to legislative developments or changes in its activity.

Users are advised to review this document periodically.

14. DATE OF UPDATE

Last updated: June 2026.