PRIVACY POLICY AND PERSONAL DATA PROTECTION

The purpose of this policy is to explain how we will process the personal data you provide to us through the different forms and other data entry channels present in the real estate brokerage process in your relationship and interaction with NEST DEVELOPERS, S.L.

In this regard, it is the intention of NEST DEVELOPERS, S.L., in compliance with personal data protection regulations, to make this Privacy Policy available to users of this website, in order to provide information onhow we process their personal data and protect their privacy and information. To this effect, we inform youofthe following:

This Privacy Policy applies to the website of NEST DEVELOPERS, S.L., made available to the public at the URL www.thenesthomes.com, as well as to the interactions that the user carries out with NESTDEVELOPERS, S.L. through the aforementioned website.

NEST DEVELOPERS, S.L. may modify this Privacy Policy when necessary. In the event of modifications, we will inform you through the website or by other means so that you can be aware of the new Privacy Policy conditions. Continuing to use the functionalities provided by NEST DEVELOPERS, S.L. after being notified of such modifications implies that you agree to them unless your explicit consent is required.

The data controller of personal data is the entity NEST DEVELOPERS, S.L., a Spanish company with tax identification number CIF nº B-16593345 and registered address for notifications at Calle Ca’n Ribera, nº4, entresuelo 5º, 07012, Palma de Mallorca (Illes Balears).

To ensure proper management of your personal data processing, NEST DEVELOPERS, S.L. has appointed a “Data Protection Officer,” whom you may contact to resolve any inquiries you may have, and whom you can reach at the following email address: igone@thenesthomes.com.

The functions of the Data Protection Officer are as follows:

• Inform and advise the controller and employees on their obligations under the General Data Protection Regulation (GDPR) and other data protection provisions.
• Monitor compliance with the provisions of the Regulation, other data protection provisions, and the personal data protection policies of the data controller, including the assignment of responsibilities, awareness-raising, and training of personnel involved in processing operations, and corresponding audits.
• Provide the requested advice on data protection impact assessment matters and monitor its implementation.
• Cooperate with the Data Protection Agency.
• Act as a point of contact for the Data Protection Agency regarding processing-related matters, including prior consultation.

The personal data that the user provides through this website may be processed by NEST DEVELOPERS, S.L. for the following purposes, depending on the type of data provided by the user, as well as the interactions the user establishes with NEST DEVELOPERS, S.L. through this website:

• Evaluation and monitoring of your interest in the urban development of the projects developed by NEST DEVELOPERS, S.L.: The personal data of users who contact NEST DEVELOPERS, S.L. through any of the contact channels provided on the platform will be processed to manage such contact, respond to requests received through them, and provide the required services.
• Manage and process the requests or inquiries you make to NEST DEVELOPERS, S.L.: The personal data of users who use the functionalities provided by the platform (request and management of after-sales services, reporting and notification of after-sales incidents in the real estate properties brokered by NEST DEVELOPERS, S.L., etc.) will be processed by NEST DEVELOPERS, S.L. to manage the platform’s functionalities and user requests.
• Adoption of measures to prevent fraud and money laundering: Users’ personal data will be processed to comply with established legal and corporate regulations, as well as to cooperate with competent authorities to prevent crimes or fraud.
• Sending advertising, promotional information, or information that may be of interest to you through postal, telephone, or electronic means (email, SMS, messaging, WhatsApp, and other electronic communication means) regarding any promotion developed by NEST DEVELOPERS, S.L.: The personal data of website users who are also customers of NEST DEVELOPERS, S.L. may be processed to send advertising, promotional information, or information that may be of interest regarding the products, promotions, and commercial offers of NEST DEVELOPERS, S.L. through any means, including postal, electronic (email, messaging, SMS, WhatsApp, or other equivalent electronic communication means), or social media, including based on the analysis and profiling of their data, which will be done exclusively with internal data.

The data processed by NEST DEVELOPERS, S.L. originate from the following sources:

• Data provided by the user through the completion of forms made available by NEST DEVELOPERS, S.L. or through any other means by which the user communicates with NEST DEVELOPERS, S.L.
• Data generated as a result of the development, processing, and management of the relationship established between the user and NEST DEVELOPERS, S.L.
• To this effect, it is expressly stated that NEST DEVELOPERS, S.L. may process your personal/identification data, such as, by way of illustration only, name and surname, email address, telephone number, postal address, IP address, and any other similar or analogous data.

NEST DEVELOPERS, S.L. processes your personal data in accordance with the following legal bases:

• The processing of your data for the purposes of “evaluation and monitoring of your interest in the urban development of the projects” and “sending advertising and promotional information” is based on your consent.
• Data processing arising from the purposes of “contact” and “management of inquiries” is based on the execution of the legal relationship established between NEST DEVELOPERS, S.L. and you, as well as the application of pre-contractual measures requested by you.

NEST DEVELOPERS, S.L. informs users that the data processing described in this Privacy Policy does not, under any circumstances, imply the communication or transfer of their data by NEST DEVELOPERS, S.L. to third-party entities.

NEST DEVELOPERS, S.L. will retain your personal data for the time necessary to fulfill the purposes established in this privacy policy, without prejudice to its retention for making it available to competent authorities and for handling claims.In this case, the data will be kept blocked until the expiration of the statute of limitations, at which point they will be deleted. In particular, it is reported that the company will retain for a period of ten (10) years the documentation that formalizes compliance with the obligations established in Law 10/2010, of April 28, on the prevention of money laundering and the financing of terrorism, proceeding thereafter to its deletion.

After five (5) years from the termination of the business relationship or the completion of the occasional transaction, the retained documentation will only be accessible by the internal control bodies of the obligated entity, including the technical prevention units, and, where appropriate, those responsible for legal defense.

Furthermore, the company may retain your data in an anonymized manner for statistical or market research purposes, whenever possible, without prejudice to the necessary blocking for compliance with any applicable legal obligation.

Without prejudice to the foregoing, and provided that the user has not exercised their right to deletion, their data will be retained for the legal periods applicable in each case, taking into account the type of data and the purpose of the processing.

In any case, the user may request detailed information on the data retention periods applied by NEST DEVELOPERS, S.L. by contacting our Data Protection Officer at igone@thenesthomes.com.

NEST DEVELOPERS, S.L. informs users that when personal data are collected through a form made available on our website, it will be necessary for the user to provide the requested information/data. If such information is not provided, NEST DEVELOPERS, S.L. will not be able to carry out the intended purpose.

The user guarantees that the data they provide to NEST DEVELOPERS, S.L. are true, accurate, complete, and up-to-date, being responsible for any damage or harm, direct or indirect, that may result from non-compliance with this obligation.

If the user provides data belonging to a third party, they guarantee that they have informed said third party of all aspects contained in this Privacy Policy and obtained their consent to provide us with their data for the intended processing purpose. All this must be done before supplying third-party data through our website.

NEST DEVELOPERS, S.L. informs you that to provide your personal data in any way through our website, you must be at least 16 years old. The user who provides data to NEST DEVELOPERS, S.L. through this website declares and guarantees that they are over 16 years old, assuming full responsibility for this statement.

In response to NEST DEVELOPERS, S.L.’s concern for ensuring the security and confidentiality of your data, the required security levels for the protection of personal data have been adopted, and technical measures have been implemented to prevent the loss, misuse, alteration, unauthorized access, and theft of personal data provided through this website. In any case, please note that security measures on the Internet are not impregnable.

NEST DEVELOPERS, S.L. informs you that you have the right to obtain confirmation as to whether or not we are processing personal data concerning you.

Similarly, NEST DEVELOPERS, S.L. informs you that you have the following rights regarding your personal data:

• **Right of access:** You have the right to know the personal data we process concerning you.
• **Right of rectification:** You have the right to rectify or complete any inaccurate or incomplete data.
• **Right of deletion:** You may request that your personal data be deleted from our systems and files.
• **Right to object:** You may object to the processing of your data for direct marketing purposes as well as for personal reasons unless the basis for processing is legitimate interest.
• **Right to restrict processing:** You may request the restriction of processing if (i) you contest its accuracy or when it is unlawful and you object to the deletion of your personal data, requesting instead the restriction of its use, (ii) when the data are no longer necessary for processing but you need them for the formulation, exercise, or defense of claims, and (iii) when you have objected to processing while verifying whether the controller’s legitimate interest prevails over yours.
• **Right to data portability:** You have the right to obtain a copy of all the data you have provided us and, when technically possible, the right to request that your personal data be communicated to another data controller.
• **Right to file a complaint with the Spanish Data Protection Agency (https://www.aepd.es/), the competent authority in Spain regarding data protection, if you believe your data has not been processed correctly.**

You may exercise these rights free of charge, as well as revoke the consent given at any time, by contacting our company through any of the following means and attaching a copy of your ID card or equivalent document proving your identity:

NEST DEVELOPERS, S.L., S.A. calle Ca’n Ribera, nº4, entresuelo 5º, 07012, Palma de Mallorca (Illes Balears); igone@thenesthomes.com.

NEST DEVELOPERS, S.L. will provide the requested information within a maximum period of one (1) month from receipt of the request, although we inform you that this period may be extended by two (2) additional months considering the complexity and number of requests.

Finally, NEST DEVELOPERS, S.L. informs you that you may file a complaint with the competent Data Protection Authority, which in Spain is the Spanish Data Protection Agency (www.agpd.es). However, in the first instance, you may file a complaint with our Data Protection Officer at igone@thenesthomes.com, who will resolve your claim within a maximum period of two (2) months.