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**PRIVACY POLICY**
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Confidentiality and security are paramount values ​​for Rental Ninja, S.L. and, consequently, we assume the commitment to guarantee the privacy of the User at all times and not to collect unnecessary information. Then, we provide you with all the necessary information about our Privacy Policy in relation to the Personal Data we collect from you, explaining:

-   Who is responsible for the processing of your data.
-   For what purposes we collect the data we request.
-   What is the legitimacy for their treatment.
-   How long we keep them.
-   To which recipients the information is communicated.
-   What your rights are.

**1\. RESPONSIBLE FOR THE TREATMENT**
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RENTAL NINJA, S.L.\
B67572370\
C/ Sant Pere mes Alt, 66, Local 1, 08003-Barcelona-Spain\
privacy@rental-ninja.com

Hereinafter "Rental Ninja", "We" or the "Responsible for the Treatment".

This privacy policy covers all data collected and used by us through the website www.rental ninja.com and trough the Platform (hereinafter, the Web, the App or Rental Ninja, indistinctly).

**2\. PERSONAL DATA**
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Personal Data refers to any information or data that can identify you directly or indirectly. The Personal Data includes information such as the name, surname, e-mail address or postal address, amongst others. It could also include unique numeric identifiers such as the IP address of your computer, as well as the information we obtain through cookies.

This privacy policy covers all personal data collected and used by Rental Ninja.

Hereby, the user (you) guarantees that the Personal Data provided is true and accurate and undertakes to notify any change or modification thereof. Any loss or damage caused to the Website, to the Data Controller or to any third party through the communication of erroneous, inaccurate or incomplete information in the registration forms will be the sole responsibility of the user. If a customer were to provide false, incorrect or incomplete data, or if Rental Ninja had reasons to believe that they are false, inaccurate or incomplete, it has the right to deny the customer access and present or future use of the web site or of any of its contents or services.

We may gather or receive your data through our website, the App, forms or social network websites, amongst others. In some cases, you provide us with your Personal Data directly (for example, when you contact us or you register at Rental Ninja), or in other cases we collect them (for example, using cookies to understand how you use our website).

**3\. PURPOSES, LEGITIMACY AND STORAGE DURATION** for the processing of the data sent through:
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### **REGISTRATION FORM**

When you register on Rental Ninja, you will need to introduce your full name, e-mail address, and password. The password shall remain strictly confidential. You undertake not to share the data relating to your account or make them accessible to third parties. You are personally responsible for the use of said data by third parties, including any information or statements made on the Platform, as well as any other action using the account on the Platform.

You guarantee that the data relating to your identity provided through the forms available on our website and/or App are accurate, correct and truthful. Furthermore, you undertake to keep your data updated. In the event that you provide any inaccurate, incorrect or untruthful data or, if Rental Ninja considers that there are reasonable grounds to doubt the truth or accuracy of the same, Rental Ninja may deny you any and all current or future access and use of the Platform, including contents and/or services.

-   Purposes:

-   Managing the registration on the platform.

-   To provide the services correctly.
-   Monitoring the pre-contractual and contractual relationship.
-   Sending invitations to members of the Team
-   Quality and loyalty service.
-   Sending communications regarding the service.

-   Legitimacy: Your express consent and the legitimate interest of Rental Ninja.

-   Storage duration: Until you request to delete them.

### **PAYMENT FORM**

It includes the data of the card with which the payment of the service is made: full name of the holder of the card, numbering of the credit or debit card, expiration date of the credit or debit card and CCV.

-   Purpose: Manage the payment of the service.

-   Legitimacy: The contractual relationship between you and Rental Ninja.

-   Storage duration: For your safety, Rental Ninja has relied on the payment system by credit or debit card to a payment gateway (Strype, card payment and Instant Credit). The bank details entered are encrypted and transmitted securely to the bank's servers and, subsequently, they are verified with the issuing bank to avoid possible fraud and abuse.

   This data entry procedure is guaranteed by SSL encryption technology, so that no third party will have access via internet to this information related to the bank details entered by the user.

### **INSTANT MESSAGING SERVICE**

You have an internal instant messaging system to communicate directly with us. In these cases, you will be free to communicate any type of information, including personal data.

-   Purpose: The data that you communicate through this chat will be treated only to attend your query and answer your requests for information.

-   Legitimacy: The user's consent when requesting information through the chat, as well as our legitimate interest.

-   Storage duration: Once your request has been resolved, if it has not generated any other treatment.

### **SENDING OF E-MAILS**

-   Purpose: To answer your requests for information, attend your requests and respond to your queries or issues. In case of receiving your Curriculum Vitae, your personal and curricular data may be part of our databases to participate in our present and future selection processes.

-   Legitimation: The user's consent when requesting information through the e-mail address or sending us his/her information and Curriculum Vitae to participate in our selection processes.

-   Storage duration: Until your request is answered by e-mail, if you have not generated a new treatment. In the case of receiving your Curriculum Vitae, your data may be kept for one year maximum for future selection processes.

**Obligation to provide us with your personal data and consequences of not doing so.**

The submission of personal data requires a minimum age of 18 years old and, where applicable, sufficient legal capacity to sign contracts.

The personal data requested is necessary in order to manage your requests and/or provide you with the services that you may contract, whereby if you do not give this to us, we will not be able to correctly attend to you or provide you with the service you have requested.

**4\. RECIPIENTS OF YOUR DATA**
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The Personal Data we collect from you may be treated by the Responsible of the treatment, on the legal basis of the legitimate interest of the company, and/ or to fulfill administrative purposes.

Your personal data may be communicated to:

-   Staff directly related to the Responsible for the treatment.

-   Third parties that provide us with IT services, such as platform providers, housing, maintenance and support services for our databases as well as for our software and applications that could contain data related to you.

-   Third parties that help us provide digital services, such as CRM, web analytics and search engine.

-   Third parties for compliance with a legal regulation.

We will ensure that all communication of your personal information that we carry out ourselves or through third parties to whom your personal data is shared complies with all laws applicable to us.

Throughout the application, Users may find several boxes where they can include information to which user of the Team will have access. In this sense, it is important to inform you that you must not include information that contains personal data of a third party.

**5\. RENTAL NINJA AS DATA PROCESSOR**
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If you as an Agency or Client use the services of Rental Ninja, you undertake to publish on your platform/website a privacy policy for your clients (guests), in accordance with the applicable regulations. In addition, you agree to obtain the consent of your customers (guests) for the use and access of their personal data by Rental Ninja and third parties.

In cases where Rental Ninja acts as a Data Processor, it will store on behalf of the Agency or Data Controller the contact details of its guests, that is: phone number, email and name, as well as a scanned copy of their passport or corresponding identity document, necessary for the execution of the contracted service, as well as for legal imperative and public safety.

Rental Ninja, on behalf of the Data Controller (Agency), will store the personal data of guests in order to use them for the proper provision of the entrusted services.

Rental Ninja does not use the personal information collected from guests for independent marketing purposes. Rental Ninja also does not sell, disclose, share, rent or provide personal information of guests to third parties, despite legal obligations.

The personal data processed by Rental Ninja will be retained for as long as the business relationship with the Agency is maintained and, once it is terminated, during the periods of conservation and prescription of responsibilities provided by law.

In any case, Rental Ninja and the Agency will regulate the processing and access to personal data of guests through a Data Processor Agreement.

In this regard, Rental Ninja shall:

-   Process personal data only on instructions from the Agency for the provision of the service.

-   Ensure the confidentiality of personal data processed on behalf of the Agency.

-   Take the necessary technical and organizational security measures.

-   Not to subcontract the processing of data to other persons in charge without authorization from the Agency. When Rental Ninja uses another processor to carry out certain activities for the Agency's client, it will impose on this other processor, by contract, the same data protection obligations as those stipulated in the mentioned Data Processor Agreement.

-   To assist users, in all that is necessary with respect to the protection of their personal data.

-   To comply with any other obligation that corresponds to him/her in accordance with the data protection regulations.

**6\. RIGHTS REGARDING YOUR PERSONAL DATA**
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Any person can withdraw their consent at any time, when it has been granted for the processing of their data. In no case does the withdrawal of this consent condition the execution of the subscription contract or the relationships generated previously.

Likewise, you can exercise the following rights:

-   Request access to your personal data or rectification when they are inaccurate.
-   Request their deletion when, among other reasons, the data is no longer necessary for the purposes for which they were collected.
-   Request limitation of your treatment in certain circumstances.
-   Request opposition to the processing of your data for reasons related to your particular situation.
-   Request the portability of the data in the cases provided for in the regulations.

Where and how to request your Rights: Through written document addressed to the Responsible of the treatment sent to its postal address or email address (given in Section 1), writing "Personal Data" in the subject line, and specifying the right wished to be exercised and with respect to which specific personal data.

In the event of disagreements with the company in relation to the processing of your data, you may submit a claim with the Spanish Data Protection Agency (www.agpd.es).

**7\. SECURITY OF YOUR PERSONAL DATA**
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With the aim of safeguarding the security of your personal data, we inform you that we have adopted all the necessary technical and organizational measures to guarantee the security of the personal data supplied of your alteration, loss and unauthorized access or treatments.

**8\. CONTACT**
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If you have any questions or concerns about the way we treat and use your personal information or wish to exercise any of the rights described above, please contact privacy@rental-ninja.com.

Publication date: 3rd of June 2021

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