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Basic information on personal data protection

1. Who is responsible for processing your data?

ABANCA Corporación Bancaria, S.A. ("ABANCA" or the "ENTITY"), with Tax ID: A-70302039.

2. What is the source of your personal data and what data do we process?

2.1. Sources of your data:

The personal data processed by ABANCA may come from you, be generated by ABANCA, or originate from external sources: i) Data provided by you; ii) Data generated about you derived from the management, development, and maintenance of the contractual or pre-contractual relationships you have with ABANCA; iii) Companies within the ABANCA Economic Group; iv) Spanish credit institutions or those with a branch in Spain; v) Publicly accessible sources (e.g., promotional census, official journals and bulletins, or open social networks); vi) Public Administration bodies (e.g., General Treasury of Social Security or State Tax Administration Agency); vii) Files containing information on asset solvency and credit (e.g., BADEXCUG or ASNEF); viii) Common files for identity protection and fraud prevention (e.g., the "CONFIRMA" file or the "IBERPAY" file); ix) Payment service providers; x) Central Credit Register of the Bank of Spain –CIRBE– (ABANCA may consult and process, where appropriate, the data that may be registered in the CIRBE, for the purposes of granting and managing the credit operations you request, including the evaluation, assessment, and monitoring of the credit risk of such operations through scoring techniques and expert analysis, as well as to ensure effective compliance with regulations on risk concentration and any other that, within the scope of prudential supervision of credit institutions, applies to ABANCA); xi) Appraisal and management entities; and xii) Public Registers (e.g., Land Registry or Commercial Registry).

2.2. Categories of personal data:

The data we process fall into the following categories: i) Identification and contact data; ii) Data relating to your voice and image; iii) Signature data (handwritten and digitized) and data relating to identification codes or keys; iv) Personal, family, and social circumstances data; v) Sociodemographic data; vi) Academic and professional data; vii) Employment data; viii) Commercial activity data; ix) Economic and asset solvency data; x) Financial data; xi) Transactional data; xii) Insurance data; xiii) Data inferred or deduced from the analysis and processing of the other categories of personal data; xiv) Special categories of data; xv) Geographical location data; xvi) Online/app browsing and behavior data; xvii) Data on persons subject to international sanctions and financial countermeasures.

Below, we inform you about the different processing activities of your personal data for which ABANCA is responsible, specifying the respective legal bases that legitimize them and the purposes of each:

3.1. Processing necessary for the execution of your contractual or pre-contractual relationships with ABANCA.

In order to execute the contractual or pre-contractual relationships you establish with ABANCA and, therefore, to provide you with the services and products that are the subject of those relationships, we will carry out the following processing activities: i) we will process your data for the formalization, maintenance, and fulfillment of your contractual or pre-contractual relationships with ABANCA, which includes: receiving, analyzing, and evaluating requests for information or contracting that you have made regarding our products or services; contacting you in the event of any incident that may have prevented the completion of the contracting process and allowing you to resume it; proceeding, where appropriate, with the activation of the requested operation through the signing of the corresponding contract; maintaining, developing, and controlling your relationships with ABANCA; sending you non-commercial communications strictly related to the products and services you have contracted; allowing access to the different remote banking channels we make available to you (e.g., Online Banking, Mobile Banking, and Telephone Banking); after informing you, recording 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; 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; and/or allowing the verification of your account ownership at the request of a third party with whom you have initiated a contractual relationship involving payment by direct debit or account charge; ii) if you request or maintain with us a product that involves financing or deferred payment of installments, we will process your data for the analysis of your solvency and repayment capacity (which includes collecting and recording the necessary data and documentation to carry out such analysis; performing the indicated analysis using "scoring" techniques and expert analysis rules, both at the time you request the financing product and, if contracted, during the term of the corresponding contract; consulting data relating to risks that, where appropriate, are registered in your name in the Central Credit Register of the Bank of Spain -CIRBE-, as well as data relating to your non-compliance with monetary, financial, or credit obligations that, where appropriate, are recorded in common credit information systems, such as the ASNEF and BADEXCUG files); and iii) where appropriate, obtaining your updated contact details to manage non-payment situations when it is impossible to contact you through the information you provided when formalizing the contractual relationships.

To comply with the legal obligations applicable to us in each case, we may process your data for: i) the prevention of money laundering and terrorist financing; ii) reporting to the CIRBE the credit risks you incur with ABANCA; iii) communicating information about your tax residence and your accounts to the State Tax Administration Agency (AEAT) and other competent tax authorities; and iv) compliance with the provisions imposed by MiFID regulations (Markets in Financial Instruments Directive).

3.3. Processing carried out based on ABANCA's legitimate interest.

We process your personal data based on the satisfaction of the legitimate interests pursued by ABANCA, and to the extent that your own interests or fundamental rights and freedoms do not override those legitimate interests, for the following purposes: i) sharing your data with ABANCA Servicios Financieros, E.F.C., S.A. (a company belonging to our Economic Group dedicated to consumer credit) whenever you request a product that involves financing or deferred payment of installments, to ensure that the requested product is suitable for your debt capacity; ii) 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; iii) 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) and credit risk profiles for commercial purposes (which allows us to assess your solvency and credit capacity to assign you a maximum financing limit), in order to offer you advertising information tailored to these profiles about our products and services similar to those you have contracted; iv) offering you advertising information, including through electronic means, about products and services similar to those contracted. At any time, you may exercise your right to object to the sending of such advertising information, as well as to the processing of your data for the creation of the profiles mentioned in the previous section iii), by contacting ABANCA's Customer Service through the channels referred to in the additional and detailed information on Data Protection found in the privacy policy accessible on our website (www.abanca.com), within the "Legal and security aspects" section, located at the bottom of said website; v) communicating your data related to credit, loan, or other operations involving financing or deferred payment to files containing information on asset solvency and credit (e.g., ASNEF and BADEXCUG), provided that the legally established requirements are met; vi) communicating your data to third parties (investors) in processes of selling the credit rights derived from the risk contracts you maintain with us; vii) sending surveys to assess your level of satisfaction and the quality of the product or service you have contracted; and viii) analyzing data to improve our internal processes and/or improve our products and services.

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

3.4.1. Offer you advertising information tailored to your profile about products and services of other companies in the ABANCA Economic Group and partners. 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 remote banking services), information tailored to your commercial and credit risk profiles (i.e., adapted to your interests, needs, preferences, savings capacity, and credit capacity) about products and services of other companies in the ABANCA Economic Group, as well as third-party partners of ABANCA (commercial companies and/or non-profit entities with which ABANCA has collaboration agreements).

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

3.4.3. Transfer your data to ABANCA partners to facilitate their contracting processes with you. We will share your personal data with ABANCA partners (commercial companies and/or non-profit entities with which ABANCA has collaboration agreements) in order to facilitate and expedite the analysis (including credit risk analysis in the case of financing operations) and the possible formalization of a contract or pre-contract that you have requested from the corresponding ABANCA partner receiving the data; or to facilitate and expedite the management and execution of a contract or pre-contract that you already have with the corresponding ABANCA partner receiving the data.

3.4.4. Transfer your data to other companies in the ABANCA Economic Group so that 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 ABANCA Economic Group so that these companies can create or update your commercial and credit risk profiles and, using these profiles, prepare, for 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. Transfer your data to ABANCA partners so that they can offer you advertising information tailored to your profile about their products and services. We will share your personal data with ABANCA partners (commercial companies and/or non-profit entities with which ABANCA has collaboration agreements) so that they can create or update your commercial and credit risk profiles and, using these profiles, prepare, for 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 partners will send you directly and through any means (including email, SMS messages, and other equivalent electronic communication means).

3.4.6. Creation of your commercial and credit risk profiles for commercial purposes using external sources. We will enrich the information about you that we already have from our internal sources (i.e., the information you have provided or generated at ABANCA in connection with the management of the products and services you have contracted with ABANCA), with other data about you provided by various external sources, such as public registers (e.g., Land Registry, Commercial Registry, 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 ABANCA Economic Group that you have authorized to transfer your personal data to us for the creation of your commercial and credit risk profiles; geomarketing tools and databases; browsing data on third-party websites or applications, if you have accepted the use of cookies and other similar technologies on the relevant browsing devices; as well as files on asset solvency and credit (e.g., BADEXCUG and ASNEF) and the Central Credit Register of the Bank of Spain (CIRBE). All this with the purpose of creating a more complete and in-depth commercial and credit risk profile for you than those created with internal sources, which will allow us to more accurately personalize the offers we send you regarding our products and services.

3.4.7. Maintain the processing of your personal data once our relationship has ended to manage a new request. We will retain your personal data once our relationship with you has ended, and for a maximum period of 5 years, to manage new requests for products or services that you may submit to us.

3.4.8. Maintain the processing of your personal data once our relationship has ended to continue sending you advertising information tailored to your profile about ABANCA products and services. We will retain your personal data once our relationship with you has ended, and 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 remote banking services), advertising information tailored to your commercial and risk profiles (i.e., adapted to your interests, needs, preferences, savings capacity, and credit capacity) about ABANCA's own products and services.

3.4.9. Maintain the processing of your personal data once our relationship has ended to continue sending you advertising information tailored to your profile about products and services of other companies in the ABANCA Economic Group and partners. We will retain your personal data once our relationship with you has ended, and 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 remote banking services), information tailored to your commercial and credit risk profiles (i.e., adapted to your interests, needs, preferences, savings capacity, and credit capacity) about products and services of other companies in the ABANCA Economic Group and third-party partners of ABANCA (commercial companies and/or non-profit entities with which ABANCA has collaboration agreements).

4. Who do we share your data with?

Processing, in order 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) Notaries or public certifiers; ii) Appraisal companies; iii) Public registers; iv) To the insurance companies ABANCA Vida y Pensiones de Seguros y Reaseguros, S.A. and ABANCA Generales de Seguros y Reaseguros, S.A., as well as to other insurance companies we work with; v) To Official Public Credit Organizations; vi) To Mutual Guarantee Societies; vii) To the corresponding management or marketing entities of Collective Investment Institutions (ICC); viii) To the corresponding management and depositary entities of pension plans and to Voluntary Social Welfare Entities (EPSV); ix) To other financial institutions; x) To payment service providers; xi) To third parties (investors) in processes of selling the credit rights derived from the risk contracts you maintain with us; xii) To entities managing common credit information systems (e.g., ASNEF and BADEXCUG); xiii) To common files for identity protection and fraud prevention (e.g., CONFIRMA and Iberpay); xiv) To the applicant for an account ownership verification with whom you have initiated a contractual relationship involving payment by direct debit or account charge; xv) To companies in the ABANCA Economic Group and their partners; xvi) To service providers; xvii) To the Central Credit Register of the Bank of Spain –CIRBE– (ABANCA is obliged to report to the CIRBE, under the terms provided by current legislation, data on the credit risks the Client incurs with the ENTITY, and, if the Client is a sole proprietor and has incurred the aforementioned risks in the course of their business activity, ABANCA must indicate this status in the aforementioned report); xviii) To the Financial Ownership File of the State Secretariat for Economy and Business Support; xix) To national and European Union supervisory authorities (such as, for example, the Bank of Spain, the European Central Bank, the European Banking Authority, and the National Securities Market Commission); xx) To the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses ("SEPBLAC") and other competent authorities in the field of money laundering and terrorist financing prevention; xxi) To the State Tax Administration Agency and other competent tax authorities; xxii) To lawyers and court representatives; xxiii) To State Security Forces and Corps; and xxiv) To Judges and Courts.

Regarding the common files for fraud prevention, you can consult information regarding the participating entities, the retention period of your data in these files, and how to exercise your rights with respect to them in the additional and detailed information on Data Protection found in the privacy policy accessible on our website www.abanca.com., within the "Legal and security aspects" section, located at the bottom of said website.

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

5. What are your rights?

You may exercise your rights of access, rectification, erasure, restriction, objection, and portability of your personal data, as well as revoke your previously granted consents, by contacting ABANCA's Customer Service through the channels referred to in the additional and detailed information on Data Protection found in the privacy policy accessible on our website www.abanca.com., within the "Legal and security aspects" section, located at the bottom of said website.

6. Where can you consult detailed Data Protection information?

You can consult additional and detailed information on Data Protection in the privacy policy accessible on our website www.abanca.com., within the "Legal and security aspects" section, located at the bottom of said website https://www.abanca.com/es/legal/politica-privacidad-clientes/informacion-adicional. The Privacy Policy also details, for each processing activity carried out by ABANCA, 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 using your personal data depending on the corresponding legal basis.