Privacy and Cookies Policy

                     PRIVACY AND COOKIES POLICY

LEGAL INFORMATION AND ACCEPTANCE OF THE PRIVACY AND COOKIES POLICY

We wish to inform you through this Privacy and Cookies Policy of the treatment that we will give to the data that you provide us in the registration process, to those data that may be generated in the use of the website www.saba.es (hereinafter, the "Website") and the SABA application (hereinafter, the "App"), as well as the data processed in the process of acquisition and provision of services and products.

Use of the Website/App implies acceptance of this Privacy and Cookies Policy. SABA reserves the right to modify or update this Privacy and Cookies Policy at any time, notifying registered Users of any changes and applicable from the date indicated therein.

PRIVACY POLICY

1.    BASIC INFORMATION ON PERSONAL DATA PROTECTION DATA CONTROLLER

Saba Aparcamientos, S.A.

In addition, if you purchase a service or product, the company owning the car park will inform you during the purchase process.

PURPOSES

•    Manage user registration on the Website/App;

•    Show you the closest car parks to your location;

•    Manage the activation or purchase of services or products through the Website/App;

•    Manage and execute the provision of the contracted services or products;

•    Manage, where appropriate, loyalty schemes;

•    Comply with the legal obligations imposed;

•    To contact you to offer you information about services or products related to those already contracted and that best suit your needs. You can object at any time by exercising your right to object by sending an email to dpo.saba.es@sabagroup.com;

•    Where you have given us your consent, to send you information about services or products from other companies with which we collaborate and which may be of interest to you, related to the mobility or automotive sectors.

LEGITIMACY

•    For the management of user registration on the Website/App: user consent;

•    To introduce you to the nearest car parks: user consent;

•    For the activation or acquisition of services or products, as well as for the provision of services or products: execution of the contract;

•    For the management of loyalty schemes: user consent;

•    For processing necessary to comply with SABA's legal obligations: compliance with legal obligations;

•    To inform you about services or products similar to those contracted offered by SABA: legitimate interest of the data controller;

•    To inform you about other SABA or third-party services or products and to send you personalised promotions: consent of the interested party.

TARGET

The data provided will not be transferred to third parties, unless legally obliged to do so, unless such transfer is necessary for the execution of the contract or with consent.

The service providers that SABA contracts or may contract and who have the status of data processors may have access to the personal data, always acting in accordance with SABA's instructions.

RIGHTS

You may exercise your rights of access, rectification, opposition, deletion, limitation of processing and data portability in the cases and to the extent established in the applicable regulations by contacting dpo.saba.es@sabagroup.com. If you have given your consent for the purposes described above, you may withdraw it at any time.

MORE INFORMATION

In the following sections of the Privacy and Cookies Policy.

2.    WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR DATA?

Saba Aparcamientos, S.A., with CIF number A08197931, registered office at Avenida Parc Logístic, 22-26 08040 Barcelona, is responsible for the processing of the personal data you provide to register, the data that may be generated when using the Website/App, as well as the data processed in the process of purchasing and providing services or products.

In the event that you purchase a service or product, in the purchase process you will be informed about the identification of the company with which you are contracting depending on the location of the car park, which will also be responsible for your personal data, treating them in accordance with this Privacy Policy.

SABA has appointed a Data Protection Officer (DPO) who can be contacted at any time with any queries you may have about the processing of your data by e-mail at dpo.saba.es@sabagroup.com or at the postal address indicated above.

3.    FOR WHAT PURPOSES DO WE PROCESS YOUR DATA? Registration as a user of the Website/App

If you register as a user on the Website/App, your data will be processed for the purpose of managing your registration as a User of the SABA Website/App and managing the services available to you as a User of the Website/App, which you can access through the private area of the Website/App.

In the private area of the Website/App you can manage your data and you also have information about your transactions, invoices or simplified invoices, associated means of access and other administrative information.

If you wish, you can use your already created social media accounts to register as a User on the Website/App. In this case, the third parties will share your personal data with SABA. To enable access and import of your data, you must identify and authenticate yourself on the external network from which your data will be extracted. We recommend that you review the terms of use and privacy policy of the networks from which data will be imported. Once the data has been imported and incorporated into the User's registration account, the User's data will be processed by SABA for the purposes described in this Privacy Policy.

By registering as a User, we will be able to send you transactional, operational and informative communications.

The legal basis for this data processing is your consent, given during the registration process by accepting the Privacy and Cookies Policy and, where applicable, by authorising the use of your access data by third parties for registration with SABA.

Show you the closest car parks to your location

If you give us permission, through the Website and the App, we may use your location data to suggest the nearest car park to you. We will always ask your permission to use your location.

For the correct use of the App, it is recommended that you activate geolocation, so that the App can suggest the nearest car park. The data used are the coordinates.

The legal basis for this data processing is your consent, given by allowing the Website and the App to access your location. You can change the settings at any time and not allow us to use your location.

Activation, procurement and provision of services or products

If you activate or purchase services or products through the Website/App, your data will be processed in order for Saba to provide the functionality, manage the purchase, provide the services or products, process the payment and, if applicable, issue the invoice and/or receipt.

The activation, acquisition and provision of services or products will allow us to send you transactional, operational and informative communications, as well as to manage your queries and requests through all our customer service channels.

For the activation of certain services, you will need to enter your credit card number. When you purchase services or products, you will need to enter your credit card number in order to process the payment. Payments are made through a secure third party payment gateway and SABA does not process this information.

Refusal to provide the personal data requested, or the provision of inaccurate or incomplete data, may result in the impossibility of providing you with the contracted services in an appropriate manner. In this regard, we remind you that, as a user, you are responsible for the accuracy of the data provided, as well as for notifying SABA of any changes to them.

Once you have activated or purchased a service or product, your data will be processed in order to provide you with the contracted service. You can find more information about the processing of your personal data in the Rules of use and operation of the car park, which are available in each car park.

•    In general, the data processing necessary for the provision of services or products are:

•    Management of the contractual relationship: your data will be processed for the activation of the services and, where appropriate, formalisation of the contract, for the administrative, economic and fiscal management associated with it, including the management of recoveries;

•    Video surveillance system: the car parks are equipped with a video surveillance system informed by camera signals, with the aim of guaranteeing the security ofgoods and facilities;

•    Number plate reading system: the number plate data will be captured by the number plate recognition system in order to comply with current parking regulations. Likewise, in certain cases and for certain services, the number plate reading allows entry and/or exit from the car park and even payment, if you have activated this function;

•    ViaT device reading system: it is possible to access the car parks using your ViaT device as a payment method. Also, if you are a subscriber, you can use your device as a method of access. If you do not wish to use your device, you can remove it or ask SABA to include you on a list which means that your device will not be accepted when you enter the car park;

•    Any other data processing that may arise from the provision of the service or product, such as claims management, claims handling, claims management...

The legal basis for data processing is the contractual relationship, which requires the processing of your data for its execution.

Sending commercial communications about products and services of your interest.

Your data will be processed in order to contact you to offer you information about services or products related to those already contracted and which best meet your needs. The legal basis is SABA's legitimate interest.

You can object at any time to receiving commercial communications by exercising your right to object by sending an e-mail to dpo.saba.es@sabagroup.com.

In addition, if you expressly consent to it in the registration process, your data may be processed to send you selected information, by any means, about offers and promotions of services or products and services products offered by SABA Group companies or by third party companies that provide services related to the mobility and automobile sector or that provide services related to parking. For this purpose, we will not communicate your data to third parties, as the information will be sent to you by SABA.

Likewise, in the process of contracting a subscription, if you expressly consent to it, your personal data may be used to create individualized profiles and to send you personalized information, by any means, about offers and promotions for services or products offered by SABA Group companies or by third party companies that provide services related to the mobility and automobile sector or that provide services related to parking. If available, the following data may be incorporated into the profile that is created, either provided directly by you or generated during your use of the services or products of SABA, other SABA Group companies and third parties: contact details (such as name, address, email); additional information (such as hobbies); customer history (such as purchase data); vehicle data (such as registration data or use of the SABA app); data collected through the Website/App.

The legal basis for commercial purposes is your consent, formalised in the registration process or, where applicable, in the product contracting documentation by ticking the corresponding box.

Sending satisfaction surveys

Your data may be processed in order to contact you to find out your opinion on the products or services contracted. The legal basis for the processing of data is the legitimate interest of SABA.

You can object to this data processing at any time by exercising your right to object by sending an e- mail to dpo.saba.es@sabagroup.com.

Loyalty schemes

Saba has loyalty plans and formalises agreements with third parties so that customers, members or users of these third parties can benefit from discounts or rebates on services or products in the car parks in Saba's network.

In these cases, Saba may receive the data from these third parties with which it has formalised an agreement, always with the prior express and informed consent of the data subject.

Loyalty and discount schemes mean that customers, members or users of these third parties can benefit from discounts or rebates on Saba's services or products, for which it is necessary:

•    That the data be shared with the Saba Group companies that provide the services or products that are the object of the loyalty plan, for the sole purpose of being able to apply the discounts or bonuses defined in the plan;

•    That the user receives operational and commercial communications related to the loyalty and discount scheme or to Saba's activity.

The legal basis for joining a loyalty and discount scheme is the consent of the data subject.

 The owner of the data may object to their data being communicated to Grupo Saba companies, but it may not be possible to apply the discounts or bonuses due to the type of plan. You may, however, object at any time to receiving commercial communications.

Likewise, when an agreement is made, mechanisms are articulated to guarantee the security of the data, as well as the correct exercise of the data subjects' rights.

4.    TO WHOM WILL WE DISCLOSE YOUR PERSONAL DATA?

If you do not purchase any service or product, your data will not be disclosed to third parties. Otherwise, your data may be communicated to:

•    The entity managing the payment gateway, for the purpose of processing the payment, the legal basis being the correct development of the contractual relationship;

•    To Public Administrations, Authorities and Public Bodies, State Security Forces and Corps, including Courts and Tribunals, when so required by the applicable regulations;

•    Insurance Companies when an incident occurs at SABA's facilities or those of third parties that so requires;

•    The Saba Group company responsible for providing the contracted service or product, depending on the location of the car park, which will be identified at the time of contracting, in order to provide the service or product;

•    In the event that the service or product contracted so requires, your data may be communicated to other Saba Group companies for the purpose of applying loyalty policies specific to the service (this aspect will be described in the terms and conditions of the product or service contracted);

•    In the event that you have voluntarily joined a loyalty and discount plan as a customer, user or member of a group of a third party with which Saba has signed an agreement, your data may be communicated to other Saba Group companies for the purpose of applying loyalty policies specific to the plan;

•    In any other case where there is a law authorising it or where it is necessary for the proper performance of the contractual relationship.

In any case, the service providers that SABA contracts or may contract and that have the status of Data Processors may have access to your personal data. Said providers shall carry out the processing of personal data in accordance with SABA's instructions, in all cases expressly requiring that the third parties comply with the legislation in force and must implement the appropriate technical and organisational measures to guarantee the confidentiality of the information. These third parties collaborate with SABA in the provision of services related to information systems, recovery management, marketing and professional services.

5.    HOW LONG WILL WE KEEP YOUR DATA?

The data provided for registration on the Website/App will be kept until you decide to unsubscribe as a User. You can unsubscribe through the Website by accessing your private area or by sending an email to dpo.saba.es@sabagroup.com.

Even if you decide to unsubscribe, if you have purchased a service or product or if there are other legitimate reasons for us to process your data, we will keep your data blocked for the applicable statutory periods. Once these retention periods have expired, the data will be deleted.

6.    HOW DO WE PROTECT YOUR DATA?

SABA is committed to the security of information and has adopted the necessary technical and organisational security measures to prevent its alteration, loss, misuse, unauthorised processing and access or theft, depending on the state of technology.

7.    WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA?

You may exercise your rights at any time, as well as revoke the consents granted, where appropriate and in accordance with the terms set out in the regulations in force.

•    Right of access: allows you to confirm whether we are processing your personal data and, if so, which ones;

•    Right of rectification: allows you to help us correct errors and amend data that may be inaccurate or incomplete;

•    Right of deletion: this allows you to request the deletion of your data, which will mean that SABA will stop processing them unless there is a legal obligation to keep them, in which casethey will be duly blocked, or other legitimate reasons for us to process them prevail;

•    Limitation of processing: this allows, under the legally established conditions, the processing of your data to be stopped, although the data may be kept duly blocked in order to respond to claims or to defend against administrative or legal actions;

•    Right to object: this allows you to ask us to stop processing your personal data where we believe we have a legitimate interest in processing it, for example, as in the case of offers of products and services. We will stop processing your data, unless there are compelling legitimate reasons, or it is necessary to respond to claims or to defend against administrative or judicial actions, in which case they will remain duly blocked;

•    Portability: allows you to receive your personal data in a structured, commonly used and machine-readable format so that you can transmit it to another data controller;

•    Withdraw consent: this allows your data to stop being processed for a purpose that you previously authorised, for example, the receipt of commercial communications from third party companies with which we collaborate.

To do so, you can contact SABA at the postal address indicated or by e-mail to the Data Protection Delegate dpo.saba.es@sabagroup.com.

Moreover, if you consider that a breach of data protection legislation has been committed with regard to the processing of your data, you can lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos).

COOKIES POLICY

This website uses own and third party cookies. They help us understand how you use our website and display content based on your browsing history. You can accept them, reject them or even set your preferences.

Detailed information on the cookies that may be installed, as well as the purpose of each one of them, is available in the cookie management tool accessible at the bottom of the Website.

If you reject the use of cookies you can still access the content, but the quality of the website may be affected.

1.    WHAT ARE COOKIES?

Cookies are small files that are installed on the equipment (computer, smartphone or tablet) from which a website is accessed and in which certain information is stored.

2.    WHAT TYPE OF COOKIES MAY BE USED BY THIS WEBSITE?

There are different types of cookies:

Depending on the entity that manages the equipment or domain from which the cookies are sent and processes the data obtained:

•    First-party cookies: these are those that are sent to the user's computer from a computer or domain managed by SABA and from which the service requested by the user is provided;

•    Third-party cookies: these are cookies that are sent to the user's computer from a computer or domain that is not managed by SABA, but by another entity that processes the data obtained through the cookies.

Depending on the length of time they remain activated in the terminal equipment:

•    Session cookies: these are designed to collect and store data while the user accesses a website and remain on the user's computer during the visit (for example, until the browser is closed and the visit ends);

•    Persistent cookies: these are cookies that remain stored in the equipment and can be accessed and processed for a period defined by the party responsible for the cookie, which can range from a few minutes to several years.

Depending on the purpose for which the data obtained through the cookies are processed:

•    Technical cookies: are those necessary for the correct functioning of the website and the use of the different options and services it offers, for example, identifying the user's session, customising the page interface, allowing video content to be played or displaying the banner with the warning about the use of cookies, etc..;

•    Personalisation/preference cookies: these are cookies that allow the user to access the service with some general characteristics predefined according to a series of criteria on the user's computer, such as, for example, the language, the type of browser usedtoaccess the website, the regional configuration from which the user accesses the website, etc..;

•    Analysis/statistical cookies: these are cookies that, either processed by the website owner or by third parties, allow the monitoring and analysis of the behaviour of the website users, quantify the number of users and thus carry out the measurement and statistical analysis of the use of the website through aggregate or statistical information;

•    Advertising/marketing cookies: these are those that allow the management, in the most effective way possible, of the advertising spaces that, where appropriate, the owner has included on the website based on criteria such as the edited content or the frequency at which the advertisements are shown. This category also includes so-called social cookies: these are those necessary for external social networks (Facebook, Google, Twitter, Pinterest, Instagram, etc.) and their function is to control interaction with social widgets within the Website.

3.    HOW CAN YOU MANAGE COOKIES?

You can at any time allow, block or delete cookies installed on your computer through your browser options or by using the cookie management tool. However, disabling cookies may affect the proper functioning of certain sections of the Website.

Through the links below, you can find information on how to disable the use of cookies by modifying your browser settings:

Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647

Explorer:

https://support.microsoft.com/es-es/help/17442/windows-internet-explorerdeletemanage-cookies

Firefox:

https://support.mozilla.org/es/kb/cookies-informacion-que-los-sitios-web-guardan-en-

Safari: http://support.apple.com/kb/ph5042

Finally, we would like to inform you that you may revoke your consent to the use of cookies by SABA at any time by using the cookie management tool or by configuring your browser in the terms indicated above.

DATE: 09 May 2022