Date of Last Revision: 05-09-2025

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Our Commitment to Your Privacy

This Charter sets out the principles and practices of Venthys Energy, S.L., an energy company operating from Palma, Spain via the website venthys.com.

As a Spanish Sociedad Limitada (S.L.), we are the Data Controller for the personal data we process and are fully committed to adhering to the highest standards of data protection, specifically the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Spanish national law, the Organic Law 3/2018 (LOPDGDD).

We aim to process your information lawfully, fairly, and transparently, ensuring confidentiality and security throughout its lifecycle.

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Data Controller Contact Details

For all matters related to this Privacy Charter and data protection, please reach out to our dedicated team:

• Company Name: Venthys Energy, S.L.

• Spanish Tax ID (NIF/CIF): B23961030

• Entry in: REGISTRO MERCANTIL DE MALLORCA

• Register number:  Numero de Entrada - 1/2025/15528 Asiento: 1/2-25/1111

• Registered Office: Calle Sant Miquel No 30 5A , 07002 Palma , SPAIN

• Contact Email (Preferred): servet.sert@venthys.com

• Telephone: +4915140560329

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1. Data Processing Activities: How and Why We Use Your Data

The personal data we collect allows us to provide reliable energy services, respond to inquiries, and ensure the operational integrity of our business. We only collect information that is strictly necessary for these functions.

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A. Data Collected and Its Purpose

We collect the following broad categories of information when you interact with us:

• Identity and Contact Information:This includes your name, email address, telephone number, and the company you represent.

• Purpose: We process this data primarily to respond to your direct queries, manage pre-contractual discussions, and prepare commercial quotes.

• Legal Basis: This processing is based either on your explicit consent(Art. 6.1.a GDPR) when you submit a form, or on ourLegitimate Interest (Art. 6.1.f GDPR) to manage our professional communications and grow our business relationships.

• Contractual and Financial Information: This covers agreement details, invoicing records, internal vendor/client IDs, Pricing & Costing Data, Transaction/Usage Metrics, Bank Information (limited).

• Purpose: the processing of contractual and financial data is strictly limited to the operational requirements necessary for effective delivery of agreed-upon advisory and technical services. 

• Legal Basis: The processing is necessary for the Performance of a Contract (Art. 6.1.b GDPR). Additionally, we process some data to comply with our Legal Obligations (Art. 6.1.c GDPR) related to Spanish tax and energy regulatory reporting.

• Technical and Usage Information:When you visit venthys.com, we automatically collect technical identifiers (like your IP address, browser type, and operating system) and usage data (like pages viewed).

• Purpose: This processing is vital for monitoring the security, stability, and proper functioning of our website, preventing unauthorized access, and improving the user experience.

• Legal Basis: We rely on our Legitimate Interest (Art. 6.1.f GDPR) to safeguard our digital infrastructure and ensure the continuity of our online presence.

• Marketing Communications: We may process your contact details to send you news and offers relevant to our services. 

• Purpose: To inform you about new products, services, or corporate updates from Venthys Energy.

• Legal Basis: This relies on yourConsent (Art. 6.1.a GDPR) for new subscribers, or ourLegitimate Interest (Art. 6.1.f GDPR) to market similar services to existing clients, provided you have not opted out (soft opt-in).

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B. Data Minimization and Retention

The personal data requested is strictly necessary for the provision of the relevant service. Refusal to provide essential data may prevent us from offering you the service. You are responsible for ensuring the accuracy of the data you submit and must notify us of any changes.

We retain your personal data only for the period necessary to fulfil the purpose for which it was collected, plus any legally mandated period required by Spanish financial or regulatory laws. For general inquiries through the contact form, data is typically kept for a period of two years following the last communication, unless a legal relationship is established.

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2. Disclosure of Your Personal Data

We do not sell, rent, or lease your personal data to third parties. Disclosure only occurs in the following limited and necessary circumstances:

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A. Necessary Service Provision

We engage carefully selected external Data Processors (e.g., IT hosting, specialized cloud services, accounting platforms) to perform functions on our behalf. These third parties are bound by Data Processing Agreements that impose stringent security and confidentiality requirements, ensuring they only process the data according to our explicit instructions and legal mandate.

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B. Legal and Regulatory Compliance

We are obligated to disclose data to the competent public authorities in Spain or the EU when required to do so by a law, regulation, or judicial order. This includes, for instance, the Agencia Tributaria (Spanish Tax Agency)and other energy sector regulators.

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C. International Transfers

Your data is primarily processed within the European Economic Area (EEA). If we transfer data outside the EEA, such as to a technology provider, we guarantee that the transfer is safeguarded by established legal mechanisms, such as:

1. Standard Contractual Clauses (SCCs): The agreement contains clauses approved by the European Commission to ensure data protection.

2. Adequacy Decisions: The destination country is officially deemed by the European Commission to offer an adequate level of protection.

3. Your Data Protection Rights Under GDPR/LOPDGDD

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Under Spanish and EU data protection law, you are granted robust rights concerning your personal information. To exercise any of these rights, please contact us via the dedicated email address provided in the Data Controller Contact Details section, attaching proof of identity (NIF/NIE/Passport).

• Right of Access (Transparency):The right to obtain confirmation that we are processing your personal data and to receive a detailed copy of that information.

• Right to Rectification: The right to have any inaccurate or incomplete personal data corrected promptly.

• Right to Suppression (Erasure / "Right to be Forgotten"): The right to request the deletion of your personal data when it is no longer necessary for the original purposes or if you withdraw your consent.

• Right to Restriction of Processing:The right to request that we temporarily suspend the processing of your data in specific scenarios (e.g., while disputing its accuracy).

• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance.

• Right to Object: The right to object to the processing of your personal data based on our legitimate interests or for direct marketing purposes.

• Right to Withdraw Consent: The right to withdraw your consent at any time, which revokes permission for future processing based on that consent.

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4. Addressing Concerns and Filing a Claim

If you believe that Venthys Energy, S.L. has failed to comply with its data protection obligations or has mishandled your rights, we encourage you to contact us directly first so we can resolve your issue.

If you remain dissatisfied, you have the ultimate right to file a claim with the official Spanish supervisory authority:

Agencia Española de Protección de Datos (AEPD):

• Website: https://www.aepd.es/

• Address: C/ Jorge Juan, 6. 28001 – Madrid, Spain

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5. Security Measures and Policy Updates

Venthys Energy, S.L. has implemented appropriate technical and organizational security measures to protect your personal data against accidental loss, unauthorized access, alteration, or disclosure. These measures include SSL/TLS encryption for data transmission, strict internal access protocols, and regular data backup procedures.

We reserve the right to modify this Privacy Charter at any time. Any changes will be published on our website, venthys.com, and will take effect immediately upon the "Date of Last Revision" being updated. We recommend you review this Charter periodically.

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