DATA CONTROLLER

Company" or the "Provider")

CIF: B16755407

Postal address: Calle Arias Montano 5, 28007 Madrid Email: hey@peoople.app DataProtection Delegate: hey@peoople.app Ad2End, S.L., as Responsible for the platform,in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016(RGPD) regarding the protection of natural persons in terms of the processing ofpersonal data and the free circulation of these data and other current regulations on theprotection of personal data, and by Law 34/2002, of July 11, on Services of theInformation Society and Electronic Commerce (LSSICE), informs you that hasimplemented the necessary security measures, of a technical and organizationalnature, to guarantee and protect the confidentiality, integrity and availability of the dataentered. The platform is made up of the website www.peoople.app and thePeoople" or thePlatform").

1. DATA PROCESSED

Peoople processes the following personal data wich it accesses in the following ways:a. Data from the Platform Forms and the User Profile: to be able to register as a user ofthe Application (the “User” or “Users”) and/or perform certain actions on the Platform(for example, to contact Peoople ) the User must complete the electronic registrationform that appears on the Platform, providing a series of necessary data for theprovision of our services. Access and registration to the Platform is prohibited to thoseunder 18 years of age. Registration is done through the Double Opt-In system, aprocess by which we establish a double validation system for all those users whoregister. The user who gives his consent by filling out a form, later accepts againthrough a confirmation email or an SMS, which will be sent to his email or telephonenumber. By registering on the Platform as a User, you guarantee that you are of legalage. The personal data collection form specifies the data that users must fill in, and therefusal by users to provide them will imply not being able to register as a User (in thecase of the registration form) or You will not be able to perform the determined actionon the platform (for example, contact us). Likewise, the fact of being a registered Useron the Platform implies having a profile with open fields in which the User can indicatewhat he deems appropriate (except with respect to the Prohibited Data indicatedbelow). The data requested in the registration form are: (1) e-mail or social networkaccount login data, (2) username and (3) password in the case of using the e-mail toregister . When the registration data is extended to become a User with the option of areward (as detailed in the Conditions of Use), the User must complete acomplementary form in which they must add (4) the country of tax residence, (5) theirID number or other document proving your identity, (6) your full name and surname, (7)the province of residence in the case of residents in Spain, (8) the full address in thecase of non-residents in Spain and (9) date and place of birth (in the case of non-residents in Spain). The data requested in the contact form are: (1) name andsurname, (2) e-mail address, (3) telephone number and (4) message sent. b. Dataprovided by third-party companies: the User may have the option not to fill out theregistration form but to identify themselves on the Platform through user accounts ofthird-party services such as Facebook, Inc., Apple, Inc or Instagram, LLC. In addition,the web portals to which users are redirected from the Platform (generally e-commerceportals of firms or fashion brands), may send us information indicating that you as aUser have made purchases on your own web page influenced by the Platform TheUser knows that in all these cases these companies will provide us with certain dataabout the User in accordance with the privacy and/or cookie policies of said companies(which the User has previously consented to). Peoople will make their best efforts notto access more data than is necessary to guarantee a good user experience andproper functioning of the Platform. c. Data automatically processed by the Application:when using the Application, it automatically accesses a series of data and elements ofyour mobile device on which it is installed. Most operating systems inform the userbefore allowing the download of the Application and some of them allow the user tolimit this access (although they may prevent normal use of the Application). The currentversion of the Application uses the following accesses (with the treatment of personaldata that each access implies): (1) access to the photographs and multimedia files ofthe device, (2) access to the camera of the device, ( 3) device Wi-fi connectioninformation, (4) device identifier, (5) device country and language settings, and (6)when User enables location services within their device settings, we collect informationabout the approximate location of your device. d. Data associated with navigationrelated to the Platform: When a User accesses any of the Platform formats, Peooplecollects the browsing data associated with each of the Users. In this way, all the actionscarried out by the user within the Platform are collected (for example, seeing anotheruser's publication, saving a product...) associated with the user ID, the IP address, thegeneral information of the device and its operating system/browser, the date and time,as well as the IDs of the rest of the elements associated with that action (for example,the ID of the publication that liked) with the aim of verifying [(i) the effective registrationas a User; (ii) obtaining the consent and acceptance of the interested party of thisPrivacy Policy; (iii) control of foreign or duplicate IPs; (iv) fraud detection, etc. e. Dataassociated with the Cookie Policy: We use cookies and similar tracking technologies tooperate and provide the Platform to you. For example, we use cookies to rememberyour language preferences, for security purposes. We also use these technologies formarketing purposes. For more information about our use of cookies, see our Platformcookie policy, in web format at https://peoople.app/politica-de-privacidad; and in appPrivacy Policy" section (Profile >> Settings >> Privacy Policy) f. Datafrom your communications with Peoople: when sending us a communication, we collectthe metadata of the same (time and date of the call or e-mail, identity of the sender andreceiver, technical data) and the data incorporated in any communication between theUser and Peoople. g. Data included in User Content: when posting User Content, weTerms of Use"),which is processed by the company on behalf of and for User account. We collect thecontent that you have created, shared or published through the Platform, such as:photographs, videos, audio recordings, comments, hashtag or any other identifyingsign, information (when, where and who created the published content). We collectUser Content at the time you create, upload or import User Content within the Platform,regardless of whether the User chooses to post or share such Content on the Platform.Your location information will be collected if you choose to add location information toUser Content that you recommend or share. Regardless of whether you are not a userof the Platform, information about you may appear in content created or published byusers of the Platform. h. Data from social networks: If the registration occurs through asocial network or connects a Peoople service with it, the User authorizes Peoople toobtain, store and use the personal data of said social network for its treatment inaccordance with this Privacy Policy. The data may include the identity or usernameassociated with said social network and any information that allows the social networkto share with Peoople, as well as any other personal data that may have been madepublic through said social network. i. Direct messages. If the User contacts otherpeople through direct messages, we collect the content of the message and theassociated metadata (such as the time the message was sent, received or read, aswell as the participants in the communication). j. Data provided by advertising,measurement and other partners. Advertisers, measurement partners, among others,share information with us about users and about actions you have taken outside of thePlatform, such as your activities on other websites and apps or in stores, includingproducts or services that you have bought These partners also share information withus, such as mobile identifiers for advertising, hashed email addresses, and cookieidentifiers, which we use to match you and your actions off the Platform with yourPeoople account. Some of our advertisers and other partners allow us to collect similarinformation directly from their website or app by integrating with our advertiser tools. k.Prohibited data: in any case, it is prohibited to provide Peoople or publish on thePlatform, (especially but not exclusively in User Content) any content that contravenesany prohibition and limitation established in the Conditions of use (especially but notexclusively, the prohibition to use personal data -both of the User himself and of thirdparties- that contain sensitive information related to identifiable or identified persons,such as: racial origin; union membership; religion, ideology or sexual orientation; healthdata; or data relating to criminal records, proceedings and sanctions or fines derivedtherefrom or non-compliance with monetary obligations). The user guarantees (a) theauthenticity and veracity of all those data (especially but not only those that arepersonal data) that he communicates through the Platform, (b) that are personal dataand the image of his person or who has the permission of the interested party to usesaid data and has informed of the terms contained herein for this purpose, (c) and whowill keep the information provided to Peoople updated, so that it responds at all timesto their real situation, being the solely responsible for the false or inaccurate statementsthat it makes, as well as for the damages that it causes to Peoople or to third parties.

2. PURPOSE OF PROCESSING

Your personal data will only be used for the following purposes:- Carrying out the necessary commercial and administrative procedures with the usersof the platform, allowing them to create, share and view content, interact with otherusers and their content, as well as offer user assistance.- Sending or viewing electronic commercial communications. They can be of two types:(a) User Content recommendations or similar that - based on the information that thePlatform has about the user is considered to be of interest (as an inseparable aspect ofthe set of services provided by the Platform for the purpose of principle, that is, itcannot be rejected by the User except by unsubscribing from the Platform) or (b) theperiodic remission of electronic commercial communications (e-mails, pushnotifications -through your mobile terminal- or in -app -included within the applicationitself-, telephone calls, or through messaging applications, such as Instagram,Whatsapp, Telegram or similar) for promotion or advertising of the services andproducts offered by Peoople or who offer these same information services or whobelong to one or more of the following sectors with the purpose of making offers andpromotions of products and services: insurance, business and finance, banking,education, automotive, construction, computing, telephony, technology andtelecommunications, consulting, energy and water, health, home, NGOs, fashion,clothing and accessories, hygiene, health, beauty, drugstore, real estate, furniture,collecting, musical arts, retail trade (among others, articles consumption, electronics,garden, toys, children, household appliances, pharmacy and pets), tourism andtransport, sports, leisure and entertainment, editorial, games of chance, culture,appointments, events, advertising, surveillance, security, offices and offices, food anddrink, hotels, restaurants and others (astrology, genres, resources, ISP, spirituality,information and notifications, exchange platforms, portals, promotion servers, auctionsand promotions, web services, social networks). Communications may include links toexternal pages and promotions offered by brands or companies collaborating withPeoople. - The User will have the option to oppose the receipt of these types ofelectronic commercial communications and the processing of personal data referred toboth in the data collection and in each of the electronic commercial communications). -The monitoring of user activity on the web portals to which users are redirected fromthe Platform (generally e-commerce portals of firms or fashion brands), including theregistration of purchases or possible purchases of products in order to generaterewards in favor of Users and manage the relationship between Peoople and thoseresponsible for said web portals; - Respond to queries and/or provide informationrequired by the User; - Carry out the provision of services and/or products contractedor subscribed to by the User. - Use your data to contact you, by any means, to obtainyour opinion about the service provided and, - Notify you of changes, importantdevelopments of the privacy policy, legal notice or cookie policy. - Profile and usabilityanalysis will be carried out. To create a profile, we take into account the personal datathat Peoople have accessed through the different channels, the behavior of the userthrough our website or mobile application, the interaction with the electroniccommunications that we send them. In none of these processes are automatedindividual decisions made about your data. - The data of clients and/or suppliers will beprocessed, within the contractual relationship that links them with the person in charge,in compliance with the administrative, fiscal, accounting and labor obligations that arenecessary under current legislation. Following Purposes according to category:Data from the Platform and Profile Forms": the Platform may include formsthat are clearly linked to specific purposes and so indicate on the Platform itself (forform contact" will be treated for the purpose ofresponding and communicating with whom you want to communicate with Peoople).Data associated with the Cookies Policy": They will also be processed forData included in the User: they will only be treated by Peoople as data processors (not as data13. Peoople as Processor”.UNSUBSCRIBING FROM THE SERVICE. To unsubscribe, you can go to theapplication at any time, in the section: Profile, Settings, edit profile, and choose theunsubscribe option. In the event that the previous option was not enabled or did notwork for any reason, you can also revoke your consent at any time by sending an emailUser Unsubscribe" to hey@peoople.app, including in the body of theemail the user name (username) and the email or username on the social networkused when registering on the Platform. In accordance with the LSSICE, in allcommunications that you will receive from Peoople, the user has the possibility ofcanceling their express consent to receive such communications. Peoople will notprocess your personal data for any other purpose than those described except by legalobligation or judicial requirement.

3. LEGITIMACY OF THE PROCESSING

The legal basis for data processing is your prior, informed and express consent grantedto carry out the purposes described above, which is requested at the time the userregisters on the Platform and accepts the conditions of service. Failure to provide therequested personal data or failure to accept this data protection policy implies theimpossibility of subscribing, registering or receiving information on the Provider'sproducts and services. In cases where there is a prior contractual relationship betweenthe parties, the legitimacy for the development of administrative, fiscal, accounting andlabor obligations that are necessary under current legislation will be the prior existenceof the commercial relationship established between the parties. . In any case, the freeand voluntary subscription to the Peoople app is considered the establishment of acontractual relationship between Peoople and the user. Said relationship is based onthe provision of information on trends, interests and, in general, on any of thecategories on which the recommendations made or consulted by said user may refer(i.e. movies, books, restaurants, fashion, accessories, clothing, etc.) by Peoople to theuser. Therefore, the sending of informative communications that fall within this categoryis considered part of the service contracted by the User at the time of subscribing to theAPP. This without prejudice to the fact that the User may, at any time, unsubscribe fromcommunications through the mechanisms enabled for this purpose in the commercialcommunications themselves or configure their profile so as not to receive them or bywriting directly to Peoople through the addresses indicated above. In the case ofcommercial communications, the legitimizing basis is the informed, unequivocal andexpress consent of the User. This is voluntary, although without it it will be impossibleto provide you with generic commercial communications of services and/or productsfrom Peoople based on your interests and needs and the sectors indicated above.

4. COMMUNICATIONS FROM PEOOPLE

Any communication that is sent will be incorporated into the Peoople systems. Byaccepting these conditions, terms and policies, the User expressly accepts thatPeoople can carry out the following activities and/or actions, unless the User expresslyindicates otherwise: Sending commercial and/or promotional communications by anyauthorized means, informing the Users of the activities, services, promotions,advertising, news, offers and other information on the services and products related tothe activity. In the event that the User has expressly consented to the sending ofcommercial communications electronically by subscribing to the newsletter, the sendingof said communications by electronic means informing Users of the activities, services,promotions, publicity, news, offers and other information about the services andproducts of Peoople that are the same or similar to those that were initially contractedor of interest to the User.

6. RECIPIENTS OF ASSIGNMENTS OR TRANSFERS AND VIEWING CONSENT

Peoople may carry out transfers of personal data for their own purposes, as well asinternational transfers with the same objective. When registering, new Users areproposed to give their prior, express and informed consent, for their data to betransferred for their own direct marketing. The provider will provide information to thesecurity forces and bodies under court order or by obligation of a legal norm, withoutprejudice to being able to block or cancel your account if there may be indications ofthe commission of a crime by the user. The information provided will only be thatavailable at this time to the provider. Users know, consent and are informed thataccording to their configuration and actions on the Platform some personal data (whichthe User himself decides what they are) may be consulted or viewed by other users ofthe Platform in accordance with this Privacy Policy and the Conditions of Use, for thepurposes of providing the Service as indicated in the Conditions of Use. Theinformation that you provide us through both the web and the application will be hostedon Peoople's servers.

7. RIGHTS OF DATA SUBJECTS

As an interested User, you can request the exercise of the following rights beforePeoople by submitting a letter to the postal address in the heading or by sending anGDPR: Rights affected", specifying the right youwish to exercise, and attaching a photocopy of your ID or any legally analogous means,as indicated by law. Rights Right of access: allows the interested party to know andobtain information about their personal data submitted to treatment. Right ofrectification or deletion: allows errors to be corrected and data that turns out to beinaccurate or incomplete to be modified. Right of cancellation: allows data that turnsout to be inadequate or excessive to be deleted. Right of opposition: right of theinterested party not to carry out the processing of their personal data or to cease it.Limitation of treatment: involves marking the personal data stored, in order to limit itsfuture treatment. Data portability: allows obtaining the data that Users have provided toa third entity/company/organization in a structured, commonly used and machine-readable format. Right not to be subject to automated individual decisions (includingprofiling): right not to be subject to a decision based on automated processing thatproduces effects or significantly affects. As a User, you have the right to withdraw theconsent given at any time. The withdrawal of consent will not affect the legality of thetreatment carried out before the withdrawal of consent. You also have the right to file aclaim with the control authority if you consider that your rights may have been violatedin relation to the protection of your data (agpd.es).

8. ADDITIONAL INFORMATION INTELLECTUAL PROPERTY AND IMAGE RIGHTS

Through this Privacy Policy, the User is informed that the photographs that are postedon the platform are the property of Peoople, including those of minors, in which, inorder to obtain these, the prior consent of parents, guardians or legal representativesby signing the forms made for this purpose by the centers in which the minors are part.Regarding the image rights of the Users and their realization of any creation or contentcapable of generating intellectual property rights, by registering and using the Platform,the Users agree to assign the intellectual property rights, as well as the image rightsthat are referred to Peoople in the terms set forth below. To this end, it is recalled thatuploading photographs on the Platform constitutes an act of public communication.Image rights.- In accordance with Law 1/1982 on civil protection, the right to honor,personal and family privacy and their own image, Users assign to Peoople the rights totheir image derived from their participation and use in the Platform through, includingbut not limited to, any means of reproduction, whether electronic (Internet, cd and otheranalogues) or conventional (paper, photographs and the like), in any currently existingtechnical or technological medium or system or future (including, by way of example,Internet exploitation; television exploitation in any form; exploitation through mobiletelephony or through any other means that is of interest to Peoople), for the maximumtime legally permitted and for the world territory to be used for advertising, commercialor similar purposes legitimately linked to the public projection of Peoople as well as itsexposure in public events of any kind. Participation in the platform and, whereappropriate, the acceptance of the privacy policy by the User implies the expressauthorization by the User of the assignment of rights set forth herein. The use andpublication of the images and data of the Users according to the above does notgenerate or grant reimbursement, fee payment or economic rights of any kind for theUser.

9.- SOCIAL NETWORKS

Peoople expressly informs the User that they can have a presence on social networks.The treatment of the data that is carried out of the people who become followers in thesocial networks (and/or carry out any link or connection action through the socialnetworks) of the official pages of Peoople will be governed by this section. , as well asthose conditions of use, privacy policies and access regulations that belong to thesocial network that is appropriate in each case and previously accepted by the user.Peoople is not responsible for the security or privacy of information collected by suchthird parties. Therefore, it is recommended, in advance, to consult the privacy policiesof said social networks before giving your consent. Peoople will process your data forthe purpose of correctly managing your presence on the social network, informing youof the provider's activities, products or services. The publication of content isprohibited: - That are allegedly illegal by national, community or internationalregulations or that carry out allegedly illegal activities or contravene the principles ofgood faith. - That violate the fundamental rights of Peoople, lack of courtesy in thenetwork, annoy or may generate negative opinions in our users or third parties and ingeneral whatever the content that Peoople consider inappropriate. - And in general thatcontravene the principles of legality, honesty, responsibility, protection of human dignity,protection of minors, protection of public order, protection of private life, consumerprotection and intellectual and industrial property rights. Likewise, Peoople reserves theright to withdraw, without prior notice from the corporate social network, those contentsthat are considered inappropriate. The communications sent through social networkswill be incorporated into a file owned by Peoople, being able to send information ofinterest to you.

10. SECURITY MEASURES

The data provided to Peoople by Users will be treated confidentially. The Provider hasadopted all the technical and organizational measures and all the levels of protectionnecessary to guarantee the security in the treatment of the data and to avoid itsalteration, loss, theft, treatment or unauthorized access, according to the state of thetechnology and nature of the data stored. Likewise, it is also guaranteed that thetreatment and registration in files, programs, systems or equipment, premises andcenters comply with the requirements and conditions of integrity and securityestablished in current regulations and the current state of technology. We periodicallyreview our security measures to include new technologies and methods available.

11 DATA RETENTION PERIOD.

Your data will be kept for the duration of the commercial relationship with us or youexercise your right to cancel or oppose, or limit treatment. However, we will keepcertain personal identification and traffic data for a maximum period of 2 years in theevent that it is required by the Judges and Tribunals or to initiate internal actionsderived from the improper use of the website or the application. You will not be subjectto decisions based on automated processing that have effects on your data.

12.SEND CV

In the event that the User sends his CV through our website enabled for this purposehttps://peoople.factorialhr.com/, he is informed that the data provided will be processedto make him a participant in the selection processes that may be , carrying out ananalysis of the applicant's profile in order to select the best candidate for the vacantposition of the Manager. This is the only official procedure to accept your CV, so CVssubmitted by a different procedure will not be accepted. In the event of any change inthe data, the User will be asked to communicate it in writing as soon as possible, inorder to keep their data duly updated. Likewise, the offers will also be published onPeoople's social networks. However, the CV can only be sent through the websiteenabled for this purpose. The data will be kept for a maximum period of one year, afterwhich the data will be deleted, guaranteeing the User full respect for confidentiality bothin the treatment and in its subsequent destruction. In this sense, after theaforementioned period has elapsed, and if you wish to continue participating in theselection processes of the Responsible, you will be asked to submit your CV again.The data may be processed and/or communicated to the member companies of ourgroup during the time your resume is kept and for the same purposes previouslyreported.

13. PEOOPLE AS PROCESSOR OF TREATMENT AND INTERNATIONAL TRANSFERS

The User in his use of the services provided by Peoople through the Platform and hisuse of the Platform may include, through User Content, personal data of third parties orhis own in said User Content (“Content Data” ). Said User is solely responsible for thisResponsible for the Treatment". Peoople provides a service for theTreatment for the purpose of allowing the use of the Platform and providing the servicesProcessor", (a) itimplements technical and organizational measures to safeguard the Content Data fromany unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) onlyprocesses the Content Data in accordance with the instructions provided by the User,clicks" on thePlatform) regarding this specific material, (c) does not use the Content Data forpurposes other than those related to the development of the Services or in accordancewith the instructions provided by the User, (d) does not communicate the Content Data,not even for its conservation to third parties (this does not prevent that, if the instructionof a User is that a User Content must be public and subject to recommendations,logically Peoople complies with said instruction and allows access to the Users of saidContent Data and may even recommend the display of said User Content). With thecancellation of the account and request for cancellation of the User's data, Peoople willstop using any Content Data, which will be destroyed. Peoople reserves the right tosave such Blocked Content Data before deleting it for as long as Peoople may be heldliable for such data processing. If you discover that another User uses your old ContentData in Peoople without authorization, you must inform Peoople of this, since Peoopledoes not monitor, edit or control User Content. The User responsible for the ContentData authorizes us, as Data Processor, to allow access and processing of said ContentData to one or more service providers (data hosting and messaging), as asubcontractor on his behalf. , if we reasonably consider that said access and treatmentis necessary for the development of the Services. These providers process the data forthe sole purpose of providing us with the aforementioned services that we haveindicated and are currently the Google group (whose subsidiaries with possible accessto the data would be: (i) Google Ireland Limited, with offices at Gordon House, BarrowStreet, Dublin 4, Ireland, (ii) Google Asia Pacific Pte. Ltd., with offices at 8 Marina ViewAsia Square 1 #30-01 Singapore 018960, or (iii) Google Inc., with offices at 1600Amphitheater Parkway, Mountain View, California 94043, (in Ireland, Singapore and theUS respectively) Amazon group (whose affiliates with possible access to the data are(i) Amazon.com, Inc. in the US and (ii) Amazon Web Service Ireland Ltd in Ireland); orthe Facebook group (whose affiliates with possible access to the data are (i) Facebook,Inc., with offices at 1601 S California Ave; Palo Alto, California 94304 and (ii)Instagram, Inc. , with offices at 1601 Willow Rd; Menlo Park, California 94025)Countries in which data may be processed that are outside the European EconomicArea (all of them except Ireland) may not have personal data protection rules.equivalent to the Spanish/European ones). Before this treatment occurs, a contract hasbeen signed with said third parties that offers sufficient and necessary guaranteesoriented in accordance with the legislation for the treatment carried out by those thirdparties on our behalf and guarantee that it is in accordance with the applicableprovisions of this Policy. The User responsible for the Content Data declares andguarantees to have all the necessary consents of the Peoople whose personal data isprovided and shared, which will be treated in accordance with this clause (includingeven the International Transfer of data of this subcontracting or to other users of thePlatform of other countries to which access). The User, responsible for the ContentData, will indemnify Peoople and hold it harmless in relation to any claim, damage orloss that they may suffer that is related to the processing of personal data of thirdparties processed in accordance with this clause.

14. CHANGES TO THIS PRIVACY POLICY

Peoople reserves the right to modify this policy to adapt it to new legislation orjurisprudence. In the event that said modifications are related to the consentsrequested, we will request your consent again. In any case, the modification of theprivacy policy will be notified in general to Users.

15. LEGISLATION

For all purposes, the relations between Peoople and the Users of its telematic services,present on this Platform, are subject to Spanish legislation and jurisdiction to which theparties expressly submit, being competent for the resolution of all derived or related