PRIVACY POLICY

PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, Chef Leaks (hereinafter also referred to as Chef Leaks) is committed to adopting the necessary technical and organizational measures, according to the level of security appropriate to the risk of the collected data.

LAWS INCORPORATED IN THIS PRIVACY POLICY

This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following regulations:

- Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).

- Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights (LOPD-GDD).

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

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

IDENTITY OF THE DATA CONTROLLER

The Data Controller for the personal data collected at Chef Leaks is: the Chef Leaks team (hereinafter referred to as the Data Controller). Their contact details are as follows: hello@chefleaks.com.

PERSONAL DATA REGISTRATION

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Chef Leaks through the forms provided on its pages will be incorporated and processed in our file to facilitate, streamline, and fulfill the commitments established between Chef Leaks and the User or to maintain the relationship established in the forms completed by the User, or to address a request or inquiry from the User. Furthermore, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR.

APPLICABLE PRINCIPLES FOR 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 Articles 4 and following of Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights:

**Principle of legality, fairness, and transparency:** The User's consent will be required at all times, with completely transparent information regarding 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 be only those strictly necessary concerning the purposes for which they are processed.

**Principle of accuracy:** Personal data must be accurate and kept up to date at all times. **Principle of storage limitation:** Personal data will only be retained in a manner that allows the identification of the User for the time necessary to fulfill the purposes of its processing.

**Principle of integrity and confidentiality:** Personal data will be processed in a way that ensures its security and confidentiality.

**Principle of proactive responsibility:** The Data Controller will be responsible for ensuring compliance with the above principles.

CATEGORIES OF PERSONAL DATA

The categories of data processed by Chef Leaks are solely identification data. Under no circumstances are special categories of personal data, as defined in Article 9 of the GDPR, processed.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The legal basis for the processing of personal data is consent. Chef Leaks is committed to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

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, the withdrawal of consent will not condition the use of the Website.

In cases where the User must or can provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory due to its necessity for the proper development of the operation being performed.

PURPOSES OF THE PROCESSING TO WICH PERSONAL DATA IS INTENDED

Personal data is collected and managed by Chef Leaks for the purpose of facilitating, streamlining, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms completed by the User or to address a request or inquiry.

Similarly, the data may be used for commercial purposes of personalization, operational and statistical activities, and activities related to the corporate purpose of Chef Leaks, as well as for data extraction, storage, and marketing studies to tailor the content offered to the User and to improve the quality, functionality, and navigation of the Website.

At the time the 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 made of the collected information.

RETENTION PERIODS FOR PERSONAL DATA

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: 12 months, or until the User requests its deletion.

At the time the personal data is obtained, the User will be informed about the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

RECIPIENTS OF PERSONAL DATA

The User's personal data may be shared with the following recipients or categories of recipients: the Chef Leaks platform itself at chefleaks.com for customer management.

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

PERSONAL DATA OF MINORS

In accordance with the provisions of Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, only individuals over 14 years old may provide consent for the lawful processing of their personal data by Chef Leaks. If it involves a child under 14 years old, parental or guardian consent will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

CONFIDENTIALITY AND SECURITY OF PERSONAL DATA

Chef Leaks is committed to adopting the necessary technical and organizational measures, according to the appropriate security level relative to the risk of the collected data, to ensure the security of personal data and to prevent the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, as well as unauthorized communication or access to such data.

The Website is equipped with 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, since Chef Leaks cannot guarantee the invulnerability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller is committed to promptly informing the User when a breach of personal data security occurs that is likely to result in a high risk to the rights and freedoms of individuals. Following the provisions of Article 4 of the GDPR, a breach of personal data security is understood as any breach of security that results in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who is committed to informing and ensuring, through a legal or contractual obligation, that such confidentiality is respected by their employees, associates, and anyone to whom they make the information accessible.

RIGHTS ARISING FROM PROCESSING OF PERSONAL DATA

The User has rights over Chef Leaks and may therefore exercise the following rights recognized in the GDPR and Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights, against the Data Controller:

**Right of access:** This is the User's right to obtain confirmation of whether Chef Leaks is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Chef Leaks has carried out or is carrying out, including information available about the origin of such data and the recipients of communications made or planned regarding them.

**Right to rectification:** This is the User's right to have their personal data modified if it is inaccurate or, considering the purposes of processing, incomplete. **Right to erasure ("the right to be forgotten"):** This is the User's right, provided that current legislation does not state otherwise, 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 processing, and there is no other legal basis for it; the User objects to processing and there is no other legitimate reason to continue; the personal data has been processed unlawfully; 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 minor under 14 years old. In addition to erasing the data, the Data Controller, considering the available technology and the cost of its application, must take reasonable steps to inform those responsible for processing the personal data of the request from the interested party for the erasure of any link to that personal data.

**Right to restriction of processing:** This is the User's right to limit the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to processing.

**Right to data portability:** If the processing is carried out by automated means, the User will have the 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. Whenever technically feasible, the Data Controller will transmit the data directly to that other Controller.

**Right to object:** This is the User's right not to have their personal data processed or to cease processing by Chef Leaks.

**Right not to be subject to a decision based solely on automated processing, including profiling:** This is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation states otherwise. The User may exercise their rights by sending a written communication to the Data Controller with the reference "GDPR-https://chefleaks.com," specifying: - Name, surname of the User, and a copy of the ID. In cases where representation is accepted, the identification of the person representing the User by the same means will also be necessary, along with the document certifying the representation. The photocopy of the ID may be replaced by any other legally valid means that proves the identity. - Request with specific reasons for the request or information to which access is desired. - Address for notification purposes. - Date and signature of the applicant. - Any document that proves the request being made. This request and any other attached documents may be sent to the email address: hello@chefleaks.com. LINKS TO THIRD-PARTY WEBSITES

The Website may include hyperlinks or links that allow access to third-party websites other than Chef Leaks, which are therefore not operated by Chef Leaks.

The owners of such websites will have their own data protection policies, and they themselves will be responsible for their own files and privacy practices in each case.

COMPLAINTS TO THE SUPERVISORY AUTHORITY

If the User believes that there is a problem or violation of the current regulations regarding the way their personal data is being processed, they have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the country where they have their habitual residence, workplace, or where the alleged infringement occurred. In Spain, the supervisory authority is the Spanish Agency for Data Protection (http://www.agpd.es).

ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

Chef Leaks reserves the right to modify its Privacy Policy at its own discretion or due to a legislative, jurisprudential, or doctrinal change from the Spanish Agency for Data Protection. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are encouraged to periodically check this page to stay informed of the latest changes or updates.

This Privacy Policy has been updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of natural persons in relation to the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018 of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights.