Website Privacy Policy

paddeloffsite.com

I. Privacy and Data Protection Policy

Respecting the provisions of current legislation, the operator of the Padel Offsite programme (hereinafter, also "Website" or "Padel Offsite") undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy complies with current Spanish and European regulations regarding the protection of personal data online. Specifically, it adheres to the following standards:

• 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 (GDPR).

• Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

• Royal Decree 1720/2007, of 21 December, which approves the Regulation for the development of Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).

• Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The data controller for the personal data collected through paddeloffsite.com, in connection with the Padel Offsite programme, is: Daniel Edward Cioffi, with tax identification number (NIF): X6255982M (hereinafter, the "Data Controller"). His contact details are as follows:

Address: Butano Village, 28
Contact phone number: 689 811 732
Contact email: dani.cioffi@smashpadelgroup.com

Registration of Personal Data

In compliance with the GDPR and the Spanish Data Protection Act (LOPD-GDD), we inform you that the personal data collected through paddeloffsite.com will be incorporated into and processed in our records in order to facilitate, expedite and fulfil the commitments established between Padel Offsite and the User, to maintain the relationship established through the forms completed by the User, to manage enquiries or bookings relating to the Padel Offsite retreat programme, or to respond to a request or enquiry from the User. Furthermore, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained, specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights:

• Principle of lawfulness, fairness and transparency: the User's consent will be required at all times after providing completely transparent information about the purposes for which personal data is collected.

• Principle of purpose limitation: personal data will be collected for specific, explicit and legitimate purposes.

• Principle of data minimization: the personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.

• Principle of accuracy: personal data must be accurate and always up to date.

• Principle of limitation of the storage period: personal data will only be kept in a form which permits identification of the User for no longer than is necessary for the purposes for which the personal data are processed.

• Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its security and confidentiality.

• Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met.

Categories of personal data

The categories of data processed by Padel Offsite include identification data (such as name, contact details and company information provided through enquiry or booking forms) and, in certain cases, special categories of personal data within the meaning of Article 9 of the GDPR — specifically, health-related data such as dietary requirements, allergies, or medical conditions disclosed by participants for the purposes of organizing retreat catering, activities, and wellness programming.

Special categories of personal data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation.

For the processing of special categories of personal data — including any health, dietary, or medical information provided in connection with a retreat booking — the explicit consent of the User will be obtained separately and specifically for that purpose, in addition to general consent for the processing of identification data.

Legal basis for the processing of personal data

The legal basis for processing personal data is consent. Padel Offsite is committed to obtaining the User's explicit and verifiable consent for the processing of their personal data for one or more specific purposes. Where special categories of personal data (such as health or dietary information) are processed, explicit consent specific to that processing will be obtained separately.

The User has the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, withdrawing consent will not affect the use of the Website, though it may affect Padel Offsite's ability to accommodate specific dietary or medical needs during a booked retreat.

When the User must or may provide their data through forms to make enquiries, request information, or book a place on the Padel Offsite programme, they will be informed if completing any of them is mandatory because they are essential for the correct execution of the booking or service requested.

Purposes of the processing for which the personal data is intended

Personal data is collected and managed by Padel Offsite in order to facilitate, expedite and fulfil the commitments established between the Website and the User, to maintain the relationship established in the forms that the User fills out, to process and administer bookings for the Padel Offsite retreat programme (including catering, accommodation and activity planning informed by any dietary or health information provided), or to attend to a request or enquiry.

Likewise, the data may be used for commercial purposes such as personalization, operational and statistical analysis, and activities related to the corporate purpose of Padel Offsite, as well as for data extraction, storage and marketing studies to tailor the content offered to the User, and to improve the quality, operation and navigation of the Website.

When personal data is obtained, the User will be informed about the specific purpose or purposes for which the personal data will be processed; that is, the use or uses that will be given to the information collected.

Personal data retention periods

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 2 years, or until the User requests its deletion.

When personal data is obtained, the User will be informed about the period for which the personal data will be stored or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User's personal data may be shared with the following categories of recipients, where strictly necessary to deliver the Padel Offsite programme:

• Payment and booking processors, for the purpose of handling retreat payments and reservations.

• Hotel, venue and activity partners, for the purpose of coordinating accommodation, catering (including dietary requirements) and on-site programming.

• Email and customer relationship management (CRM) tools, for the purpose of managing enquiries, bookings and communications with Users.

Padel Offsite does not sell or rent personal data to third parties for their own marketing purposes. At the time personal data is obtained, the User will be informed of the specific recipients or categories of recipients relevant to that data, where this is not already specified above.

If the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed, at the time the personal data is obtained, about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights, only individuals aged 14 and over may lawfully consent to the processing of their personal data by Padel Offsite. For individuals under 14 years of age, parental or guardian consent is required for processing, and such processing will only be considered lawful to the extent that the parents or guardians have authorized it.

Privacy and security of personal data

Padel Offsite undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized disclosure of or access to such data. Special category data, such as health or dietary information, is subject to additional safeguards given its sensitivity.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, because Padel Offsite cannot guarantee the impenetrability of the internet or the complete absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to inform the User without undue delay when a personal data breach occurs that is likely to pose a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is defined as any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and guarantee through a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights arising from the processing of personal data

The User has rights over Padel Offsite and may, therefore, exercise the following rights recognized in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, against the Data Controller:

• Right of access: the User's right to obtain confirmation as to whether or not Padel Offsite is processing their personal data and, if so, to obtain information about their specific personal data and the processing carried out, as well as, among other things, information available on the origin of said data and the recipients of communications made or planned regarding them.

• Right of rectification: the User's right to have their personal data modified if it is inaccurate or, taking into account the purposes of the processing, incomplete.

• Right to erasure ("the right to be forgotten"): the User's right, unless otherwise provided by applicable law, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate ground for continuing it; the personal data has been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age.

• Right to restriction of processing: the User's right to restrict the processing of their personal data when they contest its accuracy, the processing is unlawful, the Data Controller no longer needs the data but the User needs it to establish, exercise or defend legal claims, or the User has objected to the processing.

• Right to data portability: if the processing is carried out by automated means, the User's right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit it to another data controller. Where technically feasible, the Data Controller will transmit the data directly to that other controller.

• Right to object: the User's right to prevent the processing of their personal data or to have such processing cease.

• Right not to be subject to a decision based solely on automated processing, including profiling: unless otherwise provided by current legislation.

The User may exercise their rights by sending a written communication to the Data Controller with the reference "GDPR-paddeloffsite.com", specifying:

1. The User's name, surname, and a copy of their national identity document (DNI) or passport. Where representation is permitted, the representative must also be identified by the same means, and the document proving their authority to represent the User must be provided. The photocopy of the identity document may be substituted by any other legally valid means of proving identity.

2. A request with the specific reasons for the request or information to which access is sought.

3. An address for notification purposes.

4. The date and signature of the applicant.

5. Any document that proves the request being made.

This application and any other attached documents may be sent to the following address and/or email:

Postal address: Poblado Butano, 28
Email: dani.cioffi@smashpadelgroup.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than paddeloffsite.com, and which are therefore not operated by Padel Offsite. The owners of these websites will have their own data protection policies, and they themselves will be responsible, in each case, for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User believes there is a problem or infringement of applicable regulations regarding the processing of their personal data, they have the right to effective judicial remedy and to file a complaint with a supervisory authority, in particular, in the Member State of their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. Acceptance and Changes to this Privacy Policy

The User must have read and agreed to the terms and conditions regarding the protection of personal data contained in this Privacy Policy, and must also consent to the processing of their personal data so that the Data Controller can process it in the manner, for the periods, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Padel Offsite reserves the right to modify its Privacy Policy at its own discretion, or due to legislative, jurisprudential, or doctrinal changes by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to consult this page periodically to stay informed of the latest changes or updates.

This Privacy Policy was updated to comply with 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 (GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.