Privacy and data protection policy

The Data Protection Policy of ZUNDER (GRUPO EASYCHARGER S.A.) is based on the principle of proactive responsibility, according to which the Data Controller is responsible for compliance with the regulatory and jurisprudential framework, being able to demonstrate this to the corresponding control authorities.

The data provided will be treated in accordance with the terms established in the RGPD; in this sense, ZUNDER (GRUPO EASYCHARGER S.A.) has adopted the legally required levels of protection, and has installed all the technical measures within its reach to avoid the loss, misuse, alteration, unauthorized access by third parties, as described below. However, the user must be aware that security measures on the Internet are not impregnable. However, the user should be aware that security measures on the Internet are not impregnable.

Data controller: Who are we?

Name: ZUNDER (GRUPO EASYCHARGER S.A.)

CIF: A34277434

Registered in the Commercial Register, sheet P-7870 Tomo 502 Folio 30
Address: Plaza Padres Dominicos, s/n, 34005, Palencia

Telephone: (+34) 979 300 500

Email: privacidad@zunder.com

Purpose and legitimacy of processing Why and for what purpose will we use your data?

All the data provided by our customers and/or visitors to the ZUNDER (GRUPO EASYCHARGER S.A.) website or to its staff will be included in files, automated or not, that are created and maintained under the responsibility of ZUNDER, which are essential to provide the services requested by the users, or to solve the doubts or questions posed by our visitors. The purpose of the data processing is as follows:

• Registration of users on the website (name, surname, email address, telephone, ID document, postal address, password and credit card number) for the execution of a contract or pre-contract (art 6.1 b, GDPR).
• Access to location by geolocation of the device (IP address) on the basis of the data subject’s consent (art 6.1 a, GDPR)).
• Resolution of queries (name, e-mail address and contact telephone number) on the basis of the data subject’s consent (art 6.1 a, GDPR).
• Sending commercial communications and/or newsletters (name, e-mail address, contact telephone number) on the basis of the data subject’s consent (art 6.1 a, GDPR).
• Sending of CVs and applications for participation in recruitment processes, based on the initial consent of the data subject (art.6.1 a, GDPR).
• Submission of Complaints through the Complaints Channel, based on compliance with the legal obligation under Law 2/2023 (art.6.1 c, GDPR).
• Processing of user/site visitor IDs through technical and strictly necessary cookies, in accordance with legitimate interest (art.6.1 f, GDPR) and on the basis of consent for analytical cookies, personalisation and advertising purposes, own or third parties (art.6.1 a, GDPR).

What information do we process?

1. The data you provide directly to us:

We collect information about you when you contact us through the channels provided for this purpose, such as the contact form, the form provided for submission to selection processes, when you download the Zunder App and register as a user, when you contact us through these channels, we will request personal data such as your email, name, surname, contact telephone number, interest in contact, academic or professional training, CV, etc. You can see the specific details in each of the forms on our website.

All fields marked with an asterisk (*) in the forms provided to you in the channels must be completed, so that the omission of any of them could make it impossible to provide you with the services requested. You must provide truthful information, and the impersonation of identity or the use of aliases or anonymous names is prohibited.

You may not, when providing any data that may be requested from you in the channels, choose expressions that are offensive, coincide with brands, commercial names, names or pseudonyms of public figures or celebrities for whose use you are not authorised.

In order to ensure that the information provided is always up to date and does not contain errors, you must inform ZUNDER as soon as possible of any changes in your personal data.

Likewise, by clicking on the “I accept” button (or equivalent) included in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.

1. The data obtained indirectly:

When you browse, various cookies and other tracking devices may be installed on your device, as explained in our Cookies Policy.

What is the origin of the data?

We consider that all data processed by ZUNDER have been freely provided by you. In the event that the personal data provided are those of a third party, you guarantee that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to ZUNDER for the purposes indicated above. Likewise, you guarantee that the data provided are accurate and up to date, and you accept responsibility for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.

To whom is the data communicated?

We do not disclose your data to third parties beyond the necessary communications to the public or legal administrations for the fulfilment of the legal obligations applicable to us, and for the provision of certain services. In the latter case, ZUNDER informs you that the data provided may be communicated to the entities of the GROUP for this purpose. However, if it is necessary to carry out any transfer, we will inform you beforehand and this will always be carried out on the basis of a legal basis that legitimises the processing. For example, the Tax Law makes it compulsory to provide the Tax Agency with certain information on economic transactions exceeding a certain amount.

In the event that, apart from the aforementioned cases, we need to disclose your personal information to other entities, we will request your prior permission through clear options that will allow you to decide in this regard, and we inform you that any transfer that takes place will be carried out taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers in accordance with the regulations.

Likewise, ZUNDER guarantees that in the case of suppliers located in countries outside the European Union or other countries not considered adequate in accordance with data protection regulations, the necessary precautions are taken to guarantee that the data can be transferred securely, either because the supplier offers adequate guarantees, through, among others, the signing of Standard Contractual Clauses of the European Commission, or because any of the exceptions included in the regulations are complied with.

Communication: Where may we send your data?

We will not make international transfers of your personal data for any of the above purposes.

In the event that analytical cookies from third parties (Google) are authorised, international data transfers will be carried out by Google Inc. for the provision of the Google Analytics service.

Retention: How long will we keep your data?

We will only keep your personal data for as long as is necessary to achieve the purposes for which it was collected. In determining the appropriate retention period, we consider the risks involved in the processing, as well as our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests as described in this Privacy Notice and Cookie Policy.

In this sense, ZUNDER (EASYCHARGER GROUP S.A.) will keep the personal data once the relationship with you has ended, duly blocked, for the period of prescription of the actions that may arise from the relationship maintained with the interested party.

In the processing of the Complaints Channel, the data of complaints that are processed by ZUNDER will be retained for the legally applicable periods; in the case of complaints that are not processed, the retention period is 3 months.

Once blocked, your data will be inaccessible to ZUNDER (GRUPO EASYCHARGER S.A.), and will not be processed except to make them available to the Public Administrations, Judges and Courts, for the attention of the possible responsibilities arising from the processing, as well as for the exercise and defence of claims before the Spanish Data Protection Agency.

Security: How will we protect your data?

We use all reasonable efforts to maintain the confidentiality of personal information processed on our systems. We maintain strict levels of security to protect the personal data we process against accidental loss and against unauthorised access, processing or disclosure, taking into account the state of technology, the nature of the data and the risks to which it is exposed. However, we cannot be held responsible for the use you make of the data (including username and password) you use on our website. Our staff follow strict privacy standards and where we engage third parties to provide support services, we require them to abide by the same standards and allow us to audit them for compliance.

Minors.

Minors under the age of 14 may not use the services available through our website without the prior permission of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the site by minors in their care, including the completion of forms with the personal data of such minors and the ticking, where appropriate, of the boxes that accompany them.

Your rights: What rights can you exercise as a data subject?

We inform you that you may exercise the following rights:

• Right of access to your personal data, to know which personal data are being processed and the processing operations carried out thereupon;
• Right to rectification of any inaccurate personal data; right to erasure of your personal data, where this is possible (e.g. by law).
• The right to restrict the processing of your personal data where the accuracy, lawfulness or necessity of the data processing is in doubt, in which case we may retain the data for the purpose of asserting or defending claims.
• The right to object to the processing of your personal data, when the legal basis that enables us to process such data is our legitimate interest. ZUNDER (GRUPO EASYCHARGER S.A.) will stop processing your data unless it has a legitimate interest or it is necessary for the defence of claims, when this right applies.
• The right to data portability, when the legal basis that enables us to process your data is the existence of a contractual relationship or your consent.
• Right to revoke the consent given to ZUNDER (GRUPO EASYCHARGER S.A.)

To exercise your rights, you may do so free of charge and at any time, by contacting us at the address Plaza Padres Dominicos, s/n, 34005, Palencia, Palencia, or by writing to us at the following address privacidad@zunder.com.

Protection of rights: Where can you make a complaint?

In the event that you feel that your rights have been disregarded by our entity, you may file a complaint with the Spanish Data Protection Agency, by any of the following means:

• Electronic headquarters: https://sedeagpd.gob.es.
• Postal mail: Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001, Madrid
• Telephone: (+34) 901 100 099 or (+34) 912 663 517

Making a complaint to the Spanish Data Protection Agency does not entail any cost and the assistance of a lawyer or solicitor is not necessary.

Updates: What changes may there be to this Privacy Policy?

ZUNDER (GRUPO EASYCHARGER S.A) reserves the right to modify this policy in order to adapt it to new legislation or jurisprudence that may affect its compliance.

This privacy policy has been revised as of 03 April 2025.