WEB PRIVACY POLICY: KOMMONS

Version 13 May 2025

Below is the privacy policy (hereinafter, “web privacy policy” or “policy”) governing the Web Platform https://kommons.com/uk/ (hereinafter, “the Platform”), owned by MONMAR GESTION 3 S.L. (hereinafter, “MONMAR GESTION 3 S.L.”), with tax ID B66816497 and registered address at Calle Valencia 164 1er 1a, Barcelona (08036), registered in the Commercial Registry of Barcelona, Entry T 45468, F 1, S 8.

PLEASE TAKE A FEW MINUTES TO READ OUR PRIVACY POLICY. IT WON’T TAKE LONG. WITH THIS POLICY, WE AIM TO EXPLAIN IN A SIMPLE, CLEAR, AND TRANSPARENT WAY HOW WE HANDLE AND PROTECT YOUR PERSONAL INFORMATION AND YOUR RIGHTS. THE SECURITY OF YOUR PERSONAL DATA IS FUNDAMENTAL TO MONMAR GESTION 3 S.L., AND WE TAKE ITS PROPER PROTECTION VERY SERIOUSLY.

1. Who is this policy for and who does it apply to?

This policy applies to all users of the Platform, whether or not they are customers of MONMAR GESTION 3 S.L. (hereinafter, interchangeably, “the user” or “the users”) who are natural persons. By personal data, we mean any information relating to an identified or identifiable natural person. If you are already a client of MONMAR GESTION 3 S.L., by having entered into a contract with us, you should also refer to the information contained therein regarding specific privacy terms.

2. If you browse or use oir wel platform, who is responsible for processing your personal data?

We are responsible for processing your personal data:

Legal entity name: MONMAR GESTION 3 S.L.
Registered address: Calle Valencia 164 1er 1a, Barcelona (08036)
Tax ID: B66816497
Contact phone number: +44 161 818 8005
General contact email: [email protected]

3. Data processing carried out through the platform

Purpose of processing Additional information Categories of data Legal basis Conservation period
Browsing the website Allowing you access to the information and content provided therein.
Furthermore, if you access our website, we inform you that we will process your browsing data for analytical, advertising, and statistical purposes, provided you have accepted the corresponding cookies in accordance with the Cookie Policy provided for this purpose. You may configure your preferences at any time regarding the processing of your personal data for these purposes. 		Web browsing data (your web browsing data supported by cookies, websites you visit, connection time, etc.). Your consent, in particular, if you accept or authorize the use of cookies that require it, in accordance with the provisions of our Cookie Policy (ex-Article 6.1 a) of the GDPR).
Depending on the case, the satisfaction of the legitimate interest, whether our own or a third party's, associated with the proper technical usability, management, maintenance, development, and evolution of the Website, tools, network, and associated information systems will also apply (ex-Article 6.1 f) of the GDPR). 		Your data will be retained for the time necessary to enable you to browse and use our website and its content correctly. Regarding the data associated with your browsing profile, in relation to the analytical cookies you have accepted, please refer to the section regarding their duration (see Cookie Policy).
Responding to requests or inquiries To do so, a contact form is available in the “Contact” section of the platform. • Personal identification data (first and last name).
• Personal contact information (personal telephone number or mobile phone number, email address).
• Personal data processed as a result of the inquiry. 		Your consent For the time strictly necessary to resolve or address them.
Handling incidents or complaints [email protected] • Personal identification information (name and surname, tax identification number).
• Personal contact information (personal telephone number or mobile phone number, email address).
• Personal data processed as a result of the claim. 		Your consent and, where applicable, the execution of pre-contractual measures at the request of the user/interested party. For the time necessary to properly address your claims, or, if they consist of the execution of pre-contractual measures or the signing of a contract with MONMAR GESTION 3 S.L., for all the time necessary to duly satisfy such execution or request.
Registering new advertisers For this purpose, the following address is enabled on the Platform for registration: “Advertise” • Personal identification information (first and last name).
• Personal contact information (personal phone number or cell phone number, email address).
• Image 		Your consent. For the time strictly necessary to manage your ad on our platform and, subsequently, for the time strictly necessary to comply with applicable legal obligations and only during the statute of limitations.

When the legitimate basis for processing your personal data is your consent, we remind you that you have the right to revoke it at any time, easily and free of charge, by writing to us at [email protected].

Regarding the retention period, generally speaking, when personal data is no longer necessary for the processing purposes for which it was collected, it will be blocked and made available only to the competent authorities for the possible determination of legal responsibilities during its processing, always in accordance with applicable regulations. It may not be used for any purpose other than these. After the corresponding legal deadlines have elapsed in the event of blocking, your data will be deleted in accordance with applicable regulations. If applicable, it may also be securely anonymized by MONMAR GESTION 3 S.L. (anonymized/non-personal data).

4. What are the consequences of not providing your data?

We strive to request or apply the minimum and essential data necessary to process your personal data in the full development of our purpose and corporate purposes. All of this is in accordance with the principles contained in applicable regulations.

However, failure to provide your personal data may result in the impossibility of: 1) being able to navigate our website correctly (disabling technical cookies).

In any case, the information and personal data you provide must be sufficient, accurate, and limited to what is requested through the platform forms; 2) accurate, up-to-date, and truthful, so that we can adequately verify your identity and allow you to access the platform's services.

Users will be fully responsible for the data and personal information they provide to MONMAR GESTION 3 S.L. within the framework of the platform and, where applicable, for the services they request or contract.

5. Do we share your personal data with third parties?

In general, we do not share your data with third parties, nor do we sell or offer it to them. However, as a customer of MONMAR GESTION 3 S.L., your personal data may be shared with these collaborating entities, in the manner and for the purposes described in the contracts signed with them and/or us. In accordance with the aforementioned purposes, your personal data may be communicated, where appropriate, to the following recipients:

Similarly, certain third parties may access your personal information in the course of the services they may provide to MONMAR GESTION 3 S.L. For example, in the case of third-party cookies used on the platform (see cookie policy).

MONMAR GESTION 3 S.L. has various data processors under its control, allowing access to these, as trusted providers, to the extent strictly necessary for the provision of the contracted services. These data processors operate under a service contract under the terms, conditions, and guarantees contained in Article 28 of the GDPR. MONMAR GESTION 3 S.L. carries out the corresponding controls, inspections, and audits in this area to verify that these data processors strictly comply with the contracts signed for this purpose and the applicable regulations.

In the case of advertisers, and for the purpose of advertising your advertisement through our platform, we inform you that your personal contact information, including your telephone number, will be accessible to users who access the website, allowing them to contact you through instant messaging applications such as WhatsApp or other means you choose to use.

By accepting these terms, you expressly acknowledge and consent that any information you choose to share during such communications, including messages, files, images, or any other type of personal data, will be transmitted directly between you and the users, without any intervention, control, or liability on the part of MONMAR GESTION 3 S.L.

Consequently, MONMAR GESTION 3 S.L. is not responsible for the processing, use, storage, or disclosure that such users may make of the information exchanged, as such communication takes place outside the scope of our platform's control.

6. Are your personal data transferred internationally?

We inform you that, as a general rule, international transfers of your personal data are not planned. MONMAR GESTION 3 S.L. has adopted the necessary measures and guarantees in this regard in accordance with current personal data protection regulations. Notwithstanding the foregoing, our Cookie Policy contains information on the use of cookies by third parties that may carry out international transfers of personal data. You can consult the privacy information of the third parties that serve cookies on this website through our Cookie Policy.

7. What rights do you have and how can you exercise them?

You may exercise your rights of access, rectification, erasure, data portability, restriction of processing, and objection by sending a letter to the company's registered office at Calle Valencia 164 1er 1a Barcelona (08036) or by email to [email protected]. You may also include, if necessary, proof of identity, a copy of your national identity document or equivalent identification document (passport, NIE, etc.).

We also inform you that if you believe your personal rights have not been properly respected, you may file a complaint with the competent supervisory authority, in this case, the Spanish Data Protection Agency (AEPD). For more information, please visit www.aepd.es.

This privacy policy complies with the provisions of Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), and, in relation to users located in the United Kingdom, with the UK GDPR (Data Protection Act 2018 and complementary regulations). We inform you that the personal data we process will be managed in accordance with these regulations. Users in the United Kingdom may exercise their rights recognized by the UK GDPR, including the right to access, rectify, erase, restrict processing, object to processing, and obtain data portability. They may also file a complaint with the Information Commissioner's Office (ICO) if they believe their rights have been violated.

8. Are security measures applied to your personal data?

Taking into account the nature, scope, context and stated purposes of the processing, as well as the risks of varying likelihood and severity to your rights and freedoms, MONMAR GESTION 3 S.L. applies (and will apply) appropriate technical and organizational measures to ensure the proper security and protection of your personal data, taking into account privacy criteria by design and default, as well as applying a concurrent risk approach system that will be reviewed and updated by MONMAR GESTION 3 S.L. when necessary. The use of the Hypertext Transfer Protocol (HTTPS) on our platform is a reinforced guarantee for the security of your personal data.

9. Validity and modification of the privacy policy

This policy is effective as of 28th of May 2025.

MONMAR GESTION 3 S.L. reserves the right to modify this policy to adapt it to future legislative, doctrinal, or jurisprudential developments that may apply, or for technical, operational, commercial, corporate, or business reasons, informing you in advance of any changes whenever possible. In any case, it is recommended that you read this policy carefully each time you access this platform, as any modifications will be published on the platform.