PRIVACY POLICY

Welcome to the EXOTIC · Special Top Models platform. Below, you will find the Privacy Policy (hereinafter, the "Policy") under which you may interact with our institutional EXOTIC · Special Top Models WebApp (hereinafter, the "Portal" and/or "EXOTIC · Special Top Models WebApp").

Introduction

EXOTIC · Special Top Models (hereinafter, "EXOTIC · Special Top Models") is firmly committed to respecting and complying with all applicable legal and regulatory provisions. Furthermore, it understands that Personal Data, as an integral part of people's privacy and also fundamental to our activity, must be treated in such a way that not only ensures compliance with legal requirements but also takes measures to generate an environment of trust and security in the public regarding such treatment.

Personal Data" refers to any information or data that allows the identification of a natural person or makes them identifiable.

Scope

Without prejudice to the use of the Portal, this Policy applies to all Personal Data Processing activities carried out by EXOTIC · Special Top Models. It will also apply to those individuals or companies to whom EXOTIC · Special Top Models requires the processing of Personal Data for which it is responsible, including collaborators regarding the use of cookies.

"Personal Data Processing" refers to any operation or technical procedure, automated or not, that allows the collection, recording, organization, storage, preservation, elaboration, modification, extraction, consultation, use, blocking, deletion, communication by transfer or by dissemination, or any other form of processing that facilitates access, correlation, or interconnection of Personal Data.

Details of the holder of personal data banks and the data protection officer

"Banks of Personal Data" refers to the organized set of Personal Data, whether automated or not, regardless of the medium, be it physical, magnetic, digital, optical, or others that are created, regardless of the form or modality of their creation, formation, storage, organization, and access.

Holder of Personal Data Banks

The "Holder of Personal Data Banks" refers to any natural person, private legal entity, or public entity that determines the purpose and content of the Personal Data Bank, its treatment, and security measures. For the purposes of this Policy, the Holder of Personal Data Banks is EXOTIC · Special Top Models.

The details of the person responsible for the Personal Data Banks, appointed by EXOTIC · Special Top Models, are:

Responsible person's name: Jeffer André Céspedes Escobar
- Email: contact@jefferandre.com
- Phone: (+34) 641 08 97 52
- Purpose of Personal Data

A. General Information

EXOTIC · Special Top Models may request Personal Data from its clients, suppliers, employees, applicants, and Portal users (hereinafter, the "Holders of Personal Data") for the following purposes:

- To fulfill obligations arising from contractual and non-contractual relationships with the Holder of Personal Data.
- To communicate commercial information about its business activities, goods, and services to its target audience, based on the consent obtained from the Holder of Personal Data.
- To comply with legal obligations as an employer.
- For surveillance and monitoring purposes for security risk management through video surveillance devices, biometric recording, and others as required.
- To conduct due diligence and manage business risks.
- To transfer Personal Data to related companies.
- To automatically complete documents associated with transactions made by the Holder of Personal Data (natural person to whom the Personal Data correspond) based on the purchased products and/or services used.
- For marketing purposes related to our products and/or services.
- To obtain a Database of potential clients.
- To create customer profiles.
- To disclose information about products and/or services related to our corporate purpose.
- To share information with other companies within our economic group.
- To verify and consult customer information.
- For commercial purposes related to the products and services offered by EXOTIC · Special Top Models and its affiliated companies.

It is expressly established that EXOTIC · Special Top Models recognizes the right of the Holders of Personal Data to express their refusal regarding the use and processing of their Personal Data if they consider that the provided information does not fulfill any of the aforementioned functions or if the provided data is not necessary for establishing a contractual relationship. This is without prejudice to the right to revoke previously granted consent by the Holder of Personal Data or to exercise their right to oppose the use of their data in terms of applicable provisions. These rights will be guaranteed by the company at all times and can be exercised through the procedure established in this Policy.

The Personal Data provided will be incorporated, as applicable, into the Personal Data Banks of EXOTIC · Special Top Models and/or other subsidiary, affiliated, associated companies, or members of the economic group to which it belongs and/or third parties with whom they maintain a contractual relationship.

B. Purpose of Information Obtained Specifically Through the Portal

When accessing the Portal, the browser used on your final device automatically sends information to our website/application server, which is temporarily stored in a log file. We have no influence over this process. The following information is also recorded and stored until automatically deleted:

- The IP address of the Internet device making the request.
- Date and time of access.
- The name and URL of the accessed file.
- The website/application used for access (referring URL).
- The browser used and, if applicable, the operating system of your Internet-accessing computer and your access provider's name.

Our legitimate interest arises from the following purposes for data collection. Please note that the data mentioned in the previous paragraph does not directly indicate your identity, and we draw no conclusions in this regard. We use your final device's IP address and the aforementioned data for the following purposes:

- To ensure a smooth connection establishment.
- To ensure that our website provides a good and consistent user experience.
- To evaluate system security and stability.

Exercising ARCO Rights and Other Rights by Holders of Personal Data

A. General Aspects for Exercising ARCO Rights and Other Rights of Holders of Personal Data

The Holder of Personal Data is responsible for the accuracy, truthfulness, and authenticity of the provided data. Holders of Personal Data shall have the right to access their Personal Data that have been collected, correct them if they are inaccurate or incomplete, request their deletion when they are deemed unnecessary for any of the purposes stated in the Policy, if legally appropriate, and to object to the use or processing of their data, in terms of Personal Data Protection Regulations.

The Holder of Personal Data can exercise their rights of access, information, rectification, cancellation, opposition, and revocation of the use of their Personal Data, or any other rights provided by law, by sending their request to the following email address: contact@exoticmodelagency.com

The request form that the Holder of Personal Data must use is available at the following link, where at least the following information must be provided:

- Full name of the rights holder and a copy of their identification document (ID or Foreigner Identification Card).
- If applicable, identification details of the representative of the Holder of Personal Data, a copy of their identification document (ID or Foreigner Identification Card), and a power of attorney (with legalized signatures) granted by the Holder of Personal Data.
- Specific request giving rise to the application.
- Address and/or email for corresponding notifications.
- Date and signature of the applicant.
- Documents supporting the request, if applicable.

B. Procedure for Exercising Rights Contained in Personal Data Protection Regulations

EXOTIC · Special Top Models will provide the Holder of Personal Data with information electronically, for which the Holder of Personal Data must indicate the email address to which the information should be sent, or through another suitable and reasonable method. EXOTIC · Special Top Models acknowledges that the revocation of authorization does not require any justification from the Holder of Personal Data.

Upon receiving a request, EXOTIC · Special Top Models will have a maximum period of five (5) business days to make observations regarding non-compliance that cannot be rectified automatically, granting the applicant a maximum of five (5) business days to rectify them. Otherwise, the request will be considered as not submitted.

For cases involving the right to information, EXOTIC · Special Top Models will have a period of eight (8) business days to respond to the applicant, counting from the date the request is received.

Regarding the exercise of other rights, such as rectification, cancellation, or opposition, EXOTIC · Special Top Models will have a period of ten (10) business days to respond to the applicant, counting from the date the request is received.

For cases involving the exercise of the right of access, EXOTIC · Special Top Models will have a period of twenty (20) business days to respond to the Holder of Personal Data, counting from the date the request is received. Likewise, if EXOTIC · Special Top Models' response is positive but does not provide the requested information, EXOTIC · Special Top Models will have a period of ten (10) business days to provide the requested access, counting from the day following the date of its response.

Except for the deadline established for exercising the right to information, the deadlines for responding or addressing other rights may be extended once by EXOTIC · Special Models, for a maximum period equal to the initial period, provided that circumstances justify it. In this case, the justification for the extension must be communicated to the Applicant.

Moreover, if the Personal Data entered by the Holder of Personal Data are not necessary for fulfilling obligations resulting from the legal relationship between themselves and EXOTIC · Special Top Models, the former may request EXOTIC · Special Top Models to limit the disclosure, use, and/or transfer of such data through an explicit request following the procedure outlined in this section. If the request is appropriate, EXOTIC · Special Top Models will detail the dispensable Personal Data for the legal relationship it maintains with the Holder of Personal Data, which will be excluded from the Personal Data Bank within ten (10) business days following the submission of the withdrawal request.