Social Networks policy

Social Media Participation Guidelines

On social media, we are open; we want our followers and/or consumers to share, show and exchange information, opinions and suggestions across the various platforms. And to keep everything running smoothly, we have some participation rules that apply to all of our social network accounts (Facebook, Twitter, Instagram, YouTube):

1. Being of legal age is mandatory. No exceptions!

2. Disrespectful behaviour of any kind will not be tolerated. Estrella Damm will not tolerate racism, sexism, homophobia or any other form of discourse or contribution that can be interpreted as such. After all, social networks are designed for interacting, making friends and having a good time, aren’t they?

3. When posting copyrighted information without the permission of the author, the source URL must be included.

4. We hate spam and illegal content of any kind.

5. We recommend that users do not post personal details like physical or electronic addresses, telephone numbers, bank account details, etc. on any of Estrella Damm’s social media profiles.

6. If you share your Estrella moment with us or a visit to a spot from our #EstrellaGuide, remember that your content cannot be related to:

- underage people

- activities that associate beer with driving

- activities related to the excessive consumption of alcoholic beverages

- activities related to tobacco or the consumption of drugs

Estrella Damm reserves the right to delete any messages that do not comply with the respect and legal guidelines applicable to social media content. All content deemed offensive and/or threatening will be deleted to the extent that the platform allows.

Estrella Damm waives any responsibility associated with the breach of these participation guidelines by the users, and any consequences that may arise from said breach.

1. INTRODUCTION

This Social Media Privacy Policy describes the use made by SA DAMM (hereinafter referred to as SA DAMM) of the personal data provided by Users when registering through the profile that SA DAMM maintains on the social networks of Facebook, Twitter, Instagram etc., and when navigating using their social network account, for the purposes listed below.

When registering with their ID from Facebook, Twitter, Instagram, etc. or any other social network, the User gives express consent for their personal data to be processed in accordance with the provisions stated in the Privacy Policy of SA DAMM.

2. PERSONAL DATA PROTECTION: IDENTIFICATION OF THE PARTY RESPONSIBLE FOR DATA PROCESSING

Users who provide their personal data and the information that is made available through their user account and/or profile on the social media accounts owned by SA DAMM are hereby informed that SA DAMM is responsible for processing the collected personal data, unless express notification of other terms regarding specific processing is provided.

In compliance with the provisions of the applicable law on data protection, SA DAMM respects the privacy of Users and the confidentiality and safety of personal data by implementing any legal, technical and organisational measures that are required to prevent the loss, misuse, modification, unauthorised access and theft of the provided personal data, taking into account the status of the technology, the nature of the data and the risks to which said data are exposed.

The personal data of Users will only be collected for processing when it is appropriate, relevant and non-excessive to do so with regards to the field and purposes for which said data are collected. Therefore, the processing of personal data will be limited to the purposes that the Users are informed of in each instance.

When personal data are collected, Users will receive prior notification in a clear and unequivocal fashion of the circumstances related to the processing of their data, in accordance with the requirements related to data protection that are currently in force. Likewise, any personal data provided to SA DAMM will be stored, provided that the interested party (i) does not request the deletion or modification of said data, (ii) does not oppose the processing of their personal data, or (iii) in cases in which processing requires the authorisation of the User, said User does not withdraw their consent. Notwithstanding the foregoing, and in addition to the terms mentioned herein, the data will be stored in a duly protected fashion, and will exclusively be made available to judges and courts, the Tax Office or the appropriate Public Administrations, data protection authorities in particular, for a period of 3 years, in order to handle any potential claims that may arise regarding the use of said data.

For further details regarding the processing of personal data, Users should consult the Privacy Policy of SA DAMM, where they will find detailed information regarding data protection.

3. DATA OF MINORS OR THE INCAPACITATED

Access and registration through the social media profiles of SA DAMM by persons under 18 years of age is prohibited. In cases where the User is incapacitated, intervention from the person entrusted with the custody or guardianship of said User, or their legal representative, by means of a valid document that proves legal representation of the incapacitated User, is required for access.

SA DAMM will be expressly exonerated from any responsibility that may arise from the use of social media by minors or incapacitated persons. The social media profiles of SA DAMM do not consciously collect the personal information of minors; therefore, if the User is a minor, they must not register, make use of the social media profiles of SA DAMM, or provide any personal information.

4. INTENDED PURPOSES OF SOCIAL MEDIA DATA

The information and personal data provided voluntarily by the User through the social media profiles of SA DAMM will be processed for the following purposes:

· Managing the registration of the User, the creation of their account and the use of the social media pages of SA DAMM.

· Responding to any requests submitted by the User through the social media pages of SA DAMM.

· Sending information and promotional material from SA DAMM, through any means, electronic or otherwise.

· Gauging the opinions and assessments of the User and providing updates regarding activities, news, special offers and promotions from the relevant brand of SA DAMM.

· Sending information, advertisements and marketing promotions regarding products, services and activities from the foods and beverages sector, through any means, including electronic (email or equivalent means, such as SMS, telephone, mobile phone). The foregoing is applicable provided that prior and express authorisation has been given by the User.

· Find out the opinion and rating of the User and keep them updated on activities, news, special offers and promotions from the SA DAMM brand of their interest.

· Analysis and development of commercial profiles based on the provided information for the purpose of seeking content that is relevant to the User, using profiling techniques to conduct targeted marketing and for direct marketing. The development of said profiles will be based on information obtained from SA DAMM's internal sources as well as external sources, such as, for instance, social media, public sources, other companies from the group or collaborating companies. The foregoing is applicable provided that prior and express authorisation has been given by the User.

The information provided by the User through the social media pages of SA DAMM, including personal data, may be published. This is always dependent upon the services used by the User, which means that said information may be made public and available to third-party Users of the social media pages. Through the profile of each social network, the User is able to configure the information that they wish to make public in each instance, view the granted permissions, remove or deactivate said permissions, as is possible with any third-party application they no longer wish to use.

In the event that the application of SA DAMM, or permissions granted to third-parties, are expressly deactivated in the User’s profile on a social network, the social network will stop providing their user ID from said social network.

On social media, Users may share text, photos, videos and other kinds of information and/or other content. If they do so, they will be doing it freely, of their own accord and consciously. In such event, said content will be subject to both this policy and to the Rules and Terms of Access and Use of the relevant social network. The User will be responsible for ensuring that all the content they publish complies with the current law, this policy and the related disclaimer. The User shall only publish personal data, photographs and information or other content that is owned by them or for which they have received authorisation from any relevant third parties.

SA DAMM has the right to remove from its official page—unilaterally and without prior communication or consent from the User—any content published by the User that is in breach of or infringes upon the current law, the rules established in this policy and/or those of the social networks.

5. ACCOUNTABILITY AND QUALITY OF DATA

SA DAMM is only accountable for and can only guarantee the confidentiality, safety and processing of data as per the provisions of this policy, and with regard to the personal data collected from the registered User through their ID on the social network. SA DAMM waives all accountability relating to any processing and later use of personal data that may be made by the owner of the social network, or by third-party service providers from the society of information external to SA DAMM that may access said data during the course of the provision of their services or the execution of their activity, or third-parties that establish hyperlinks to the social network.

SA DAMM warns that no User can use the identity of another person and/or provide personal details of third parties without prior authorisation. Users must at all times take into account that they can only provide personal data corresponding to their own identity and which are appropriate, relevant, current, precise and accurate. In any case, Users must respect the privacy of others, whether they are users of the social media profile of SA DAMM or not.

6. EXERCISING PERSONAL DATA PROTECTION RIGHTS

SA DAMM informs Users of the possibility of exercising the following rights:

- The right to request access to their personal data that is being processed and to receive said information in writing through the requested means.

- The right to request the modification of inaccurate personal data, or the deletion of said data when, among other reasons, the data are no longer necessary for the purpose for which they were originally collected.

- The right to request the limiting of the processing of their data.

- The right to oppose the processing of their personal data, when appropriate.

- The right to move their personal data when the processing is based on a specific piece of consent and is made through automated means. In these instances, the data will be delivered in a structured manner, for common use and mechanical reading.

- The right to withdraw their consent.

- The right to make a claim to the Spanish Agency of Data Protection.

The User may exercise the rights listed above by writing to the following postal address: Sociedad Anónima SA DAMM (ATT. OFICINA PRIVACIDAD) C/ Rosselló, 515, 08025 Barcelona), or to the following email address: privacidad@estrelladamm.com

7. OTHER RELEVANT INFORMATION

SA DAMM may modify and/or replace this policy at any moment which, depending on the case, will replace, complete and/or modify the published policy. In said instances, if the User is registered, SA DAMM must inform them directly of any changes that may affect them legally, and provide access to the policy so that Users can stay updated and informed at all times.

Users may contact SA DAMM via the internal messaging service of the social network or through the following contact details:

SA DAMM

Adress: C/ Rosselló, 515, 08025 Barcelona

Email: privacidad@estrelladamm.com