Basic information on personal data protection

BASIC INFORMATION ON PERSONAL DATA PROTECTION

1. Who is responsible for processing your data?

ABANCA VIDA Y PENSIONES DE SEGUROS Y REASEGUROS, S.A.U., with Tax ID A-15140387 (hereinafter, "ABANCA Vida y Pensiones").

2. Where do your personal data come from and what data do we process?

2.1. Sources of your data: The personal data processed by ABANCA Vida y Pensiones may come from you, be generated by ABANCA Vida y Pensiones, or originate from external sources: i) Data provided by you; ii) Data generated about you derived from the management, development, and maintenance of contractual or pre-contractual relationships you have with ABANCA Vida y Pensiones; iii) Entities responsible for managing contingencies included in the contracts you have with ABANCA Vida y Pensiones; iv) Entity responsible for the custodial management of pension funds; as well as, where applicable, entities to which ABANCA Vida y Pensiones outsources any key function (Actuarial Function, Risk Management Function, and Internal Audit Function); v) Pension plan marketing entities; vi) Pension plan sponsoring entities; vii) Companies belonging to the Economic Group of ABANCA Corporación Bancaria, S.A. (to which ABANCA Vida y Pensiones belongs); viii) Publicly accessible sources (e.g., promotional census, official journals and bulletins, or open social networks); and ix) Public Administration bodies (e.g., the General Treasury of Social Security, the National Institute of Statistics -INE-, the State Tax Administration Agency -AEAT-, or the National Death Index -INDEF-).

If you provide data about third parties, you guarantee that you have the express consent of those third parties to communicate their data to ABANCA Vida y Pensiones. Likewise, you guarantee that the third parties whose data you provide have been duly informed of the processing that ABANCA Vida y Pensiones will carry out with such data, as described in this Basic Information on Personal Data Protection.

2.2. Categories of personal data: The data we process fall into the following categories: i) Identification and contact data; ii) Data related to your voice; iii) Signature data (handwritten and digitized) and data related to identification codes or keys; iv) Data on contracted products or services; v) Special categories of data (e.g., health data provided for the processing of contingencies covered by pension plans; or data associated with digital signature—signature on tablet or via surface); vi) Data on contingencies that have occurred in pension plans; vii) Personal data of third parties covered by the pension plan contract (e.g., beneficiaries); viii) Data on personal, family, and social circumstances; ix) Sociodemographic data; x) Geographical location data; xi) Online/app browsing and behavior data; xii) Academic and professional data; xiii) Employment data; xiv) Commercial activity data; xv) Economic data; xvi) Financial data; xvii) Transactional data; xviii) Data inferred or deduced from the analysis and processing of other categories of personal data; and xix) Data on individuals subject to international sanctions and financial countermeasures.

3. Why do we process personal data and under what legal basis?

Below, we inform you about the different processing activities for your personal data for which ABANCA Vida y Pensiones is responsible, specifying the respective legal bases and purposes for each:

3.1. Processing necessary for the execution of your contractual or pre-contractual relationships with ABANCA Vida y Pensiones. In order to execute the contractual or pre-contractual relationships you establish with ABANCA Vida y Pensiones and, therefore, to provide you with the services and products that are the subject of those relationships, we will carry out the following processing: i) we will process your data for the formalization, maintenance, and fulfillment of your contractual or pre-contractual relationships with ABANCA Vida y Pensiones (including receiving information or contracting requests you have made regarding our products or services; contacting you in case of any incident that may have prevented the completion of the contracting process and allowing you to resume it; registering the requested operation through the signing of the corresponding contract, if applicable; maintaining, developing, and controlling your relationships with ABANCA Vida y Pensiones; sending you strictly non-commercial communications related to the products and services you have contracted; recording, after prior notice, telephone conversations you have with us; analyzing and managing situations of non-payment that may arise; managing and responding to any claims you may submit; and managing the application of bonuses, discounts, or any other promotional conditions, as well as the delivery of prizes and/or promotional gifts that may be associated with or applicable to the contractual relationship established with ABANCA Vida y Pensiones); ii) additionally, the necessary processing of your health data for the management of contingencies covered by the pension plans you have contracted is based on the express consent you provide by signing and accepting both this document and any other documents required for such processing; and iii) consulting information in the National Death Index - INDEF.

3.2. Processing carried out to comply with legal obligations. To comply with the legal obligations applicable to us in each case, we may process your data to: i) respond, if appropriate, to information requests made by public administrations and bodies, and competent judges and courts; ii) prevent money laundering and terrorist financing; iii) communicate your data to the Institute of Accounting and Auditing; iv) communicate information about your monetary and in-kind receipts, as well as your tax residence and/or any other information about your personal and family situation requested by the competent Tax Administrations (e.g., AEAT) for the effective application of the state and customs tax system; and v) communicate information to external auditors for the purpose of conducting the audit required of ABANCA Vida y Pensiones under auditing regulations, due to its status as a pension plan management company.

3.3. Processing carried out for the legitimate interest of ABANCA Vida y Pensiones. We process your personal data based on the satisfaction of the legitimate interests pursued by ABANCA Vida y Pensiones, and to the extent that your own interests or fundamental rights and freedoms do not override those legitimate interests, for the following purposes: i) detecting and preventing fraud in contracting and during the provision or execution of our products and services that could result in harm to you, third parties, and/or ABANCA Vida y Pensiones; ii) creating, using exclusively data from our internal sources, commercial profiles (which allows us to analyze and predict your personal preferences, economic situation, interests, geographic location, and behavior), to offer you advertising information tailored to those profiles about our products and services similar to those you have contracted; iii) offering you advertising information, including through electronic means, about products and services similar to those contracted; iv) sending surveys to assess your level of satisfaction and the quality of the product or service you have contracted; and v) analyzing data to improve our internal processes and/or our products and services.

At any time, you may exercise your right to object to the sending of commercial communications and surveys, as well as to the processing of your data for the creation of the profiles mentioned in the previous section ii), by contacting the ABANCA Vida y Pensiones Customer Service through the channels referred to in the additional and detailed information on Data Protection found in the privacy policy available on our website https://www.abanca.com, within the "Legal and Security Aspects" section located at the bottom of the website.

3.4. Processing carried out with your consent. Only if we have requested and obtained your prior consent for this purpose, we may carry out the following processing of your personal data:

3.4.1. Offering you advertising information tailored to your profile about products and services of other companies in the Economic Group of ABANCA Corporación Bancaria, S.A. and collaborators. We will process your personal data to offer you, through any means (postal mail, telephone, any type of message to your mobile phone—SMS or push messages—, email, social networks, or our apps) information tailored to your commercial profile and, where applicable, your insurance risk profile (i.e., adapted to your interests, needs, preferences, and characteristics) about products and services of other companies in the Economic Group of ABANCA Corporación Bancaria, S.A. (hereinafter, "ABANCA Group Companies"), as well as third-party collaborators of ABANCA Vida y Pensiones (commercial entities and non-profit organizations with which ABANCA Vida y Pensiones has collaboration agreements).

3.4.2. Sharing your data with other companies in the Economic Group of ABANCA to facilitate their contracting processes with you. We will share your personal data with other companies in the Economic Group of ABANCA to facilitate and expedite the analysis (including the risk to be insured in case of insurance operations or credit risk in case of financing operations) and the possible formalization of a contract or pre-contract you have requested from the corresponding ABANCA Group company recipient of the data; or to facilitate and expedite the management and execution of a contract or pre-contract you already have with the corresponding ABANCA Group company recipient of the data.

3.4.3. Sharing your data with collaborators of ABANCA Vida y Pensiones to facilitate their contracting processes with you. We will share your personal data with collaborators of ABANCA Vida y Pensiones (commercial entities and non-profit organizations with which ABANCA Vida y Pensiones has collaboration agreements) to facilitate and expedite the analysis (including the risk to be insured in case of insurance operations or credit risk in case of financing operations) and the possible formalization of a contract or pre-contract you have requested from the corresponding collaborator of ABANCA Vida y Pensiones recipient of the data; or to facilitate and expedite the management and execution of a contract or pre-contract you already have with the corresponding collaborator of ABANCA Vida y Pensiones recipient of the data.

3.4.4. Sharing your data with other companies in the Economic Group of ABANCA so they can offer you advertising information tailored to your profile about their products and services. We will share your personal data with other companies in the Economic Group of ABANCA so that these companies can create or update your commercial profile and your insurance risk profile or, where applicable, your credit risk profile, and, using these profiles, prepare and offer you advertising information tailored to them (i.e., adapted to your interests, needs, preferences, savings capacity, and credit capacity) about the products and services they offer or market at any given time; information that, consequently, these companies will send you directly and through any means (including email, SMS messages, and other equivalent electronic communication means).

3.4.5. Sharing your data with collaborators of ABANCA Vida y Pensiones so they can offer you advertising information tailored to your profile about their products and services. We will share your personal data with collaborators of ABANCA Vida y Pensiones (commercial entities and non-profit organizations with which ABANCA Vida y Pensiones has collaboration agreements) so that they can create or update your commercial profile and your insurance risk profile or, where applicable, your credit risk profile, and, using these profiles, prepare and offer you information tailored to them (i.e., adapted to your interests, needs, preferences, savings capacity, and credit capacity) about the products and services they offer or market at any given time; information that, consequently, these collaborators will send you directly and through any means (including email, SMS messages, and other equivalent electronic communication means).

3.4.6. Improvements in the insurance premium calculation process and creation of your commercial profile using external sources. We will enrich the information about you that we already have from our internal sources (i.e., information provided by you or generated by ABANCA Vida y Pensiones in connection with the management of products and services you have contracted with ABANCA Vida y Pensiones), with other data about you provided by various external sources, such as public records (e.g., Property Registry, Commercial Registry, INE, and Cadastre); publicly accessible sources (e.g., public lists of people associated with professional associations, official journals and bulletins, social media, and open social networks); companies in the Economic Group of ABANCA to which you have authorized to transfer your personal data to us (e.g., banking scoring) for the creation by us of your commercial profile and your insurance risk profile; geomarketing tools and databases; browsing data on third-party websites or applications, if you have accepted the use of cookies and similar technologies on the relevant browsing devices; as well as common insurance sector files (e.g., risk selection and rating files and files for the preparation of technical and statistical-actuarial studies). All this is to have relevant information to calculate the premium amount and create a more complete and in-depth commercial and insurance risk profile for you than those created with internal sources, allowing us to more accurately personalize the proposals we send you regarding our products and services, including the creation of a personalized rate or price based on your profile.

3.4.7. Maintaining the processing of your personal data after our relationship ends for the management of a new request. We will retain your personal data after our relationship with you ends, for a maximum period of 5 years, to manage new requests for products or services you may submit to us.

3.4.8. Maintaining the processing of your personal data after our relationship ends to continue sending you advertising information tailored to your profile about products and services of ABANCA Vida y Pensiones. We will retain your personal data after our relationship with you ends, for a maximum period of 5 years, to continue sending you, through any means (postal mail, telephone, any type of message to your mobile phone—such as SMS or push messages—, email, social networks, or our app), advertising information tailored to your commercial and insurance risk profiles (i.e., adapted to your interests, needs, and preferences) about products and services of ABANCA Vida y Pensiones.

3.4.9. Maintaining the processing of your personal data after our relationship ends to continue sending you advertising information tailored to your profile about products and services of other companies in the Economic Group of ABANCA and collaborators. We will retain your personal data after our relationship with you ends, for a maximum period of 5 years, to continue sending you, through any means (postal mail, telephone, any type of message to your mobile phone—such as SMS or push messages—, email, social networks, or our app), information tailored to your commercial and insurance risk profiles (i.e., adapted to your interests, needs, and preferences) about products and services of other companies in the Economic Group of ABANCA and third-party collaborators of ABANCA Vida y Pensiones (commercial entities and non-profit organizations with which ABANCA Vida y Pensiones has collaboration agreements).

4. With whom do we share your data?

Processing, to fulfill the purposes detailed above according to the specified legal basis for each purpose, may involve your personal data being communicated to third parties, such as: i) Financial Entities to carry out the necessary collections and payments; ii) The National Death Index - INDEF; iii) The Institute of Accounting and Auditing; iv) External auditors; v) Entities responsible for managing contingencies included in the contract you have with ABANCA Vida y Pensiones; vi) Entities sponsoring pension plans (e.g., the employer that initiates the creation of a pension plan included in the employment system modality); vii) Entities responsible for the custodial management of pension funds; as well as, where applicable, entities to which ABANCA Vida y Pensiones outsources any key function (Actuarial Function, Risk Management Function, and Internal Audit Function); viii) ABANCA Group Companies and collaborating entities; ix) Service providers; x) National and European Union supervisory authorities (such as, for example, the Directorate General of Insurance and Pension Funds); xi) The Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses ("SEPBLAC") and other competent authorities in the prevention of money laundering and terrorist financing; xii) The State Tax Administration Agency and other competent tax administrations; xiii) Judges and Courts; xiv) State Security Forces and Corps; xv) The Participant Ombudsman; and xvi) The Spanish Union of Insurance and Reinsurance Entities –UNESPA–.

We also inform you that certain companies providing services to ABANCA Vida y Pensiones are located outside the European Union, which involves International Data Transfers. In this regard, ABANCA Vida y Pensiones guarantees the application of technical, organizational, and legal security measures appropriate to the level of risk of the processing, regardless of the territory where it takes place.

5. What rights do you have?

You may exercise your rights of access, rectification, erasure, restriction, objection, and portability of your personal data, as well as revoke any previously granted consents, by contacting the ABANCA Vida y Pensiones Customer Service through the channels referred to in the additional and detailed information on Data Protection found in the ABANCA Vida y Pensiones Privacy Policy available on the website https://www.abanca.com, within the "Legal and Security Aspects" section located at the bottom of the website, or by clicking here.

6. Where can you consult detailed information on Data Protection?

You can consult additional and detailed information on Data Protection in the ABANCA Vida y Pensiones Privacy Policy available on the website https://www.abanca.com, within the "Legal and Security Aspects" section located at the bottom of the website https://www.abanca.com/es/legal/politica-privacidad-abanca-vida-pensiones/informacion-adicional/, or by clicking here. The Privacy Policy also details, for each processing activity carried out by ABANCA Vida y Pensiones, the specific categories of data used in each of these processing activities, and includes an explanation of the logic applied to profiling that may be carried out on your personal data according to the corresponding legal basis.