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Data Protection

Last updated: March 2026

1. Data controller

In compliance with current personal data protection regulations, including European legislation (Regulation (EU) 2016/679) and Organic Law 3/2018, we inform you that the data controller of the personal data obtained through this Internal Information System or Ethics Channel is EXPLOTACIONES AGRÍCOLAS HERMANOS CHUMBOS, S.L.

Data controller identification details:
Name: EXPLOTACIONES AGRICOLAS HNOS CHUMBOS, S.L.
Tax ID: B04740064
Registered office: Ctra. Nacional 332, Pol. Ind. Los Pocicos, 1 — 04640 Cuevas de Almanzora (Almería)
Email: contabilidad@explotacioneschumbos.es

2. Purpose of the Ethics Channel

The Ethics Channel or Internal Information System is confidential and may be anonymous. It is intended for employees, customers and other stakeholders connected to the company, with the purpose of handling doubts, disputes or irregularities related to compliance with legislation, internal policies, and voluntary commitments undertaken by the company.

It may be used to report actions or omissions that may constitute infringements of Union law, serious or very serious criminal or administrative offences, as well as any regulatory non-compliance of which information is received.

3. Processing and retention of data

Personal data is collected for the purpose of processing the report or communication and investigating the reported facts, following the procedure established for the channel.

This data will be retained only for the time strictly necessary to decide whether to initiate an investigation. If the data are not within the scope of the system, they will be deleted immediately.

If it is shown that the information provided is not truthful, it will be deleted immediately, unless this lack of truthfulness may constitute a criminal offence, in which case it will be retained for the duration of the judicial proceedings.

In any case, after three months from receipt of the report or communication without an investigation having been initiated, the data will be deleted, unless its retention is necessary to document the operation of the system.

Communications or reports that have not been pursued will be retained only in anonymised form, without being subject to the blocking obligation set out in Article 32 of Organic Law 3/2018.

4. Legal basis

The legal basis for processing the data is the controller's legal obligation, in accordance with Article 6.1.c) of Regulation (EU) 2016/679, Article 8 of Organic Law 3/2018 and Article 11 of Organic Law 7/2021, of May 26.

5. Recipients

Personal data will be used exclusively for the purpose of the Internal Information System. Only the natural person designated as the Ethics Channel Manager will have access to the information.

EXPLOTACIONES AGRÍCOLAS HERMANOS CHUMBOS, S.L. and its System Manager will not communicate or transfer data to third parties, except where required by law. In that case, the information will be made available to Public Administrations, Judges and Courts and State Security Forces for the exercise of their functions.

6. Rights of the data subject

At any time, the data subject may exercise the rights of access, rectification, erasure (right to be forgotten), restriction of processing, objection, portability and not to be subject to automated individualised decisions.

In certain circumstances, the data subject may request restriction of processing, in which case the data will be retained only for the exercise or defense of claims.

To exercise these rights, the data subject may send a written request to:

EXPLOTACIONES AGRÍCOLAS HERMANOS CHUMBOS, S.L.
Ctra. Nacional 332, Pol. Ind. Los Pocicos, 1 — 04640 Cuevas de Almanzora (Almería)
Email: contabilidad@explotacioneschumbos.es

In addition, the data subject may contact the competent Data Protection Supervisory Authority (www.aepd.es) to obtain additional information or file a complaint.

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